1.1
Thank you for taking the time to read our privacy policy. This explains how Impress Media Services collects and processes your personal data when you visit our website, or use our services.
1.2
It is important that you read this privacy policy carefully. If you have any questions you can contact us on the details given below.
2.1
Impress Media Services is the trading subsidiary of Impress, the Independent Monitor of the Press, which is a Community Interest Company. Impress Media Services is created to support socially responsible organisations build audience trust, navigate technological changes & diversify revenue streams. We create personalised services for their unique needs, including but not limited to strategic income generation, sustainable business development, brand-building & audience growth, operational efficiencies (e.g.: smart use of AI), events management and project management.
2.2
Our main activities are to:
2.3
Impress Media Services is the data controller and is responsible for your personal data.
2.4
We have appointed a Data Privacy Officer to co-ordinate our data protection efforts within the organisation. If you have any questions about this privacy notice or our data protection practices, please contact the Data Privacy Officer using the following contact details:
3.1
Our full details are:
4.1
Personal data means any information about an individual from which that person can be identified or any information about an identifiable individual. It does not include data that cannot be connected to an identifiable individual (anonymous data).
4.2
There are different types of personal data about you that we might collect use, store or transfer. In addition, to these specific categories of data, we might in relation to any interaction collect a range of other “descriptive experiential and activity” data about data subjects, for the purposes outlined below. We have grouped these together as follows, and provided some illustrations of the type of personal data which might fall into each grouping:
4.3
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly link to you as an identifiable individual. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can be linked directly or indirectly to you, we treat the combined data as personal data which will only be used in accordance with this privacy notice.
4.4
We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor will we usually collect any information about criminal convictions. If we need such information, we will ensure that we have a lawful basis for our processing of it.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to carry out our commercial functions, perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services), or proceed with some other activity. In this case, we will inform you of the consequences at the time, but these may include being unable to complete some consulting or contractual activity that you have asked us to undertake.
6.1
We use different methods to collect data from and about you including through:
6.1.1
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you enter into a contract with Impress Media Services or when you request our consultancy services:
6.1.2
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
6.1.3
Generated Data. We may generate Transaction, Usage, Marketing and Communications Data about you, by way of records of the direct and automated interactions that you have with us or our website.
6.1.4
Third parties. We will receive personal data about you from various third parties as set out below:
7.1
We will only use your personal data for the purpose for which we collected it which includes the following:
To conduct market research and analysis
(a) Identity data
(b) Contact data
(c) Technical data
(d) Usage data
(e) Profile data
Legitimate Interests: To better understand market trends, improve products/services, and develop business insights. Data processing is necessary for informed decision-making and competitive analysis.
To develop tailored business strategies
(a) Identity data
(b) Contact data
(c) Technical data
(d) Usage data
(e) Profile data
Legitimate Interests: To create personalised campaigns and strategies that meet customer needs and improve service offerings. Consent may be required for direct marketing communications, depending on jurisdiction.
To collect and process client and customer data
(a) Identity data
(b) Contact data
(c) Technical data
(d) Financial data
(e) Usage data
Contractual Necessity: Required to fulfil agreements with clients/customers.
Legal Obligation: To comply with financial and tax regulations.
Legitimate Interests: To maintain business operations and client relationships.
To monitor and evaluate strategy performance
(a) Identity data
(b) Contact data
(c) Usage data
(d) Communications data
(e) Profile data
Legitimate Interests: To assess the effectiveness of strategies, optimise performance, and improve future delivery. Data helps in refining strategies to better meet client and market demands.
To communicate regularly with clients
(a) Identity data
(b) Contact data
(c) Usage data
(d) Communications data
(e) Profile data
Contractual Necessity: For ongoing client relationship management and service updates.
Legitimate Interests: To provide support, maintain strong client relationships, and inform clients of relevant updates or changes to services. Consent may be required for non-essential communications, like newsletters.
To administer and protect our organisation and this website (including trouble-shooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity data
(b) Contact data
(c) Technical data
Legitimate interests: For running our organisation, provision of administration and IT services, network security, to prevent fraud and in the context of any reorganisation or group restructuring exercise. Necessary to comply with a legal obligation.
To deliver relevant website content, information about our services, seminars, conferences and other events and activities to you
(a) Identity data
(b) Contact data
(c) Technical data
(d) Usage data
(e) Communications data
(f) Profile data
Legitimate interests: To study how potential customers and target audience use our website and services, to develop them, to grow our organisation and to inform our strategy for future engagement with users and other stakeholders.
To use data analytics to improve our website, services, engagement, user relationships and experiences
(a) Technical data
(b) Usage data
Legitimate interests: To define types of users for our services, to keep our website updated and relevant, to develop our organisation and to inform our engagement strategy.
To make suggestions and recommen-dations to you about services that may be of interest to you
(a) Identity data
(b) Contact data
(c) Technical data
(d) Usage data
(e) Communications data
(f) Profile data
Legitimate interests: To provide personalised services and content to meet user needs and interests and to enhance user engagement and retention.
8.1
We may share your personal data with the parties set out below for the purposes set out in the table above.
8.1.1
Internal Third Parties, including:
8.1.2
External Third Parties, which might include:
8.1.3
Third parties to whom we may choose to sell, transfer or merge parts of our organisation or its assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then any new controller may use your personal data in the same way as set out in this privacy policy.
8.2
We will only share personal data with a third party to the minimum extent necessary for the lawful purposes in question, and we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, to the minimum extent necessary and in accordance with our instructions.
Except to the limited extent indicated above, we do not currently intend to transfer, store and process your personal data outside the United Kingdom or the European Economic Area. It may be, from time to time, that it is necessary for us to make a transfer of your personal data to a country (a “third country”) which is neither within the EEA nor a country in relation to which the EU Commission has made a finding of adequacy in connection with its data protection regime. In those circumstances (including the limited circumstances identified above) we ensure that adequate safeguards are in place, which will be appropriately documented in a formal agreement using appropriate safeguards, which may include the model clauses approved by the EU Commission.
10.1
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
10.2
The data security measures that we have in place include:
10.3
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach, in a timely manner, where we are legally required to do so. We will endeavour to work with you and them to minimise the impact of the breach.
11.1
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
11.2
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
11.3
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12.1
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). These rights include the right to:
12.1.1
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can make a data subject access request by e-mailing us at info@impressreg.org.uk with the subject line “Data Subject Access Request” or make a request over the phone.
12.1.2
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Subject Rectification Request” or by telephoning us, using the contact details given above.
12.1.3
Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Subject Erasure Request” or by telephoning us, using the contact details given above.
12.1.4
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Use Objection”, or by telephoning us, using the contact details given above.
12.1.5
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
12.1.6
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
12.1.7
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Use Objection”, or by telephoning us, using the contact details given above.
12.2
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
12.3
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.4
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The privacy notice may be updated from time to time and an updated version will be published to our website. Make sure to check back from time to time to see the current version of this notice, although important changes will be brought to your attention as and when necessary.
A subsidiary of Impress: The Independent Monitor of the Press