Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our contracts are usually with client organisations rather than individuals. To deliver and improve our marketing consultancy services, we need to use information about the people we work with at our clients, such as their names, job titles, contact details, and notes of meetings, decisions and feedback. This is necessary so we can understand our clients’ needs, carry out the work, communicate about progress and improve how we deliver our services. The information is limited to what people would expect a professional services supplier to hold in the course of working with them. We use it only to deliver and improve our services and keep it securely. The people involved benefit from well-run projects and clear communication, and the impact on them is minimal. We therefore consider that our legitimate interest outweighs any risk to them. Where we record or transcribe meetings, we tell participants at the start of the call.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We work with businesses, and our contracts are usually with the client organisation rather than with individuals. To set up and run client accounts, we need to use the names, job titles, work email addresses and phone numbers of the people we deal with at our clients, such as project leads, decision-makers and accounts contacts. This is necessary so we can communicate about the work, agree deliverables, send invoices and receive payment. Without it, we could not deliver our services. The information is limited to business contact details that people would expect a supplier to hold. It is used only to manage our working relationship and is kept securely. The impact on the people involved is minimal, and they benefit from clear, efficient communication about work they are involved in. We therefore consider that our legitimate interest in running client accounts outweighs any risk to them.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We send occasional updates about our services, insights and events to existing and past clients and to business contacts who are likely to find them relevant, such as marketing and business leaders we have worked with or met professionally. Keeping in touch helps us develop our business, and it helps contacts stay informed about support that may be useful to their organisation. We use only business contact details, typically name, job title and work email address. We keep communications relevant and infrequent. Every message identifies us and includes a simple way to unsubscribe, and we stop contacting anyone who opts out. Because people would reasonably expect to hear from a business they have worked with or met in a professional context, and can easily stop it, we consider that the benefits outweigh any impact on them.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We use personal information to respond to enquiries, including those made through our website, by email or by phone, and to handle any queries, complaints or claims about our services. This usually involves the person’s name, contact details, organisation and the details of their enquiry or concern. This is necessary so we can answer questions from prospective clients, resolve issues fairly and promptly, and protect our business by keeping appropriate records if a dispute arises. People contacting us would reasonably expect us to use their details to respond, and we use the information only for that purpose and keep it securely. The benefit to the people involved, getting a prompt and proper response, together with our need to manage our business responsibly, outweighs the minimal impact on them.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.