You are consenting to receive (a) Daniel Barnett’s employment law updates and (b) advertising emails promoting Daniel Barnett’s seminars and other services. Those other services include membership of the HR Inner Circle, run by our sister company HR Inner Circle Limited, but we will not share your information with HR Inner Circle Limited.
The employment law bulletins, and advertising emails, are intended to be read by (and are produced for) UK employment lawyers and HR Professionals.
Who is the Data Controller?
The emails are published by Employment Law Services Limited (company 4067549), which will store and process your data. Employment Law Services is the company which owns and operated Daniel Barnett’s employment law email updates. It is the relevant data controller.
What will we do with your data?
We will initially store your email address and first name only, but if you order products from us or give us additional information about yourself, we might also store your occupation, employer or company name, and your address or telephone number, along with information on what products you have bought from us. We will also store your IP address and the date you signed up to the bulletins, so that we can prove (if necessary) that you opted in to receive them.
We will communicate with you by email only unless you provide us with additional contact details (such as address), in which case we may communicate you with by those other means.
What are our Grounds for processing your Data?
We rely on consent and legitimate interests as our grounds for processing your data. By signing up to receive Daniel Barnett’s employment law updates after 15 May 2018 you agreed to the following statement when you clicked on the double opt-in consent link:
If you signed up to receive Daniel Barnett’s employment law updated before 15 May 2018, then you will have clicked a link between 1 April 2018 and 25 May 2018 to signify your consent to continue receiving bulletins after 25 May 2018. The wording on that link stated:
GDPR ReConsent: I would like to continue receiving Daniel Barnett’s employment law updates by email. I agree to also receive advertising emails promoting Daniel Barnett’s seminars and other services. I can unsubscribe from the updates, or any advertisement emails, at any time.
In the event that the above wording is found not to amount to consent to receiving advertisements for the purpose of the GDPR, we rely on legitimate interest as our alternative ground for processing. We will send you (subject to you opting out of any individual campaign) direct marketing emails on employment law information products (mainly seminars, CDs, books and online webinars) which we think are of interest to subscribers to Daniel Barnett’s employment law updates. During a sales campaign, of which there will typically be four a year, we will send you an average of one email a day for the duration of the campaign (typically between 2 and 6 weeks). Every email will contain one, and usually two, prominent links to opt out of that advertising campaign. By including very prominent opt-out links, we think that strikes a fair balance between our legitimate interest in marketing to you (as an employment lawyer or HR Professional), and your interests in not receiving unwanted direct marketing.
If we communicate with you by means other email (such as post or via Facebook Messenger), we will only do so where we have a legitimate interest in so doing.
Do we use tracking or automatic processing?
In our emails, we can track whether you have opened the email or clicked on any link within it. We use this information solely to understand the performance of the newsletter, to draw out general trends, and to monitor the size of our active readership.
We do not use any information at a personal level, except that if you have told us your occupation and/or your closest city, we may use that information to automatically filter you out from receiving irrelevant direct marketing where we do not think we have sufficient legitimate interest in sending it to you. For example, if we are sending direct marketing emails about an employment law seminar in Manchester, and you have told us you live in London, we are likely to exclude you from that direct marketing campaign. Or, for example, if we are sending direct marketing emails about an information product aimed at lawyers, and you have told us you are an HR Professional, we are likely to exclude you from that direct marketing campaign.
From time to time we might email you and ask you to provide a bit more information about yourself – for example, your occupation, or your closest city. You do not have to reply to those emails and are free to ignore them. The only thing we do with the information you give us is use it for the automatic processing described above, to reduce the amount of any direct marketing we send you if we think you won’t be interested.
Who do we share your data with?
Your data will be kept secure and never shared with any third parties (including our advertisers), except for the following organisations (and any similar organisations we may subcontract services to in the future, at which point we will update this policy):-
- Rocket Science Group LLP (more commonly known as ‘MailChimp’), which is the US-based company we use to send emails. We have entered into an agreement with them whereby they agree to store and process your data in accordance with the EU Privacy Shield.
- Dropbox, Inc., which is the US-based company we use to store all our documents. These documents include backups of our subscriber list. Dropbox has ISO 27018 (the internationally recognised standard for leading practices in cloud privacy and data protection), is certified for compliance with the EU Privacy Shield and has undertaken it will comply with the provisions of the GDPR.
- subcontractors to whom we delegate website or database programming and maintenance, or necessary administrative functions.
If we sell our business, or merge with another organisation, then we will probably share your data with them as part of the sale/merger.
Like all organisations, we comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from law enforcement or tax agencies, or as part of a disclosure exercise in litigation.
How long will we keep your data for?
We will keep your information until you withdraw your consent, either by telling us directly or by clicking an ‘unsubscribe’ link which will be at the bottom of every email we send. As set out above, you can also opt out from any advertisement campaigns at any time.
What about your right to make changes, or be deleted?
You can request changes to, or ask to remove, the data we hold about you, and how we use it. Should you wish to do so, or to remove yourself from our records, you can do this at any time by clicking the ‘update profile’ or ‘unsubscribe’ link at the bottom of a Spoon newsletter, or by emailing us at firstname.lastname@example.org. You can ask to see your personal data. We will always comply wherever we can, where the request is proportionate, realistic, and reasonable. We can refuse to comply with a request for erasure if it is manifestly unfounded or excessive, taking into account whether the request is repetitive in nature. You can also request erasure from our records.
What if you have a Complaint?
If you believe your privacy rights have been violated, you may file a complaint with us at email@example.com, or with the Information Commissioner’s office at https://ico.org.uk/. We would prefer you contacted us in the first instance, however, as we take your privacy seriously and can most likely remedy any errors or problems quickly and easily.
Is this policy cast in stone?
No – we will look at the policy from to time and may make changes. Any changes which do not substantially change the existing policy or significantly affect your privacy will not be directly notified to you, but will be updated on our website. Any substantial changes or any changes which significantly affect your privacy will be sent to you by email.