Higginson Strategy Privacy Policy

Please read this Privacy policy. This policy explains who we are, how we process personal data and, if you are the subject of any personal data concerned, what rights you have and how to get in touch with us if you need to. We comply with the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018. We respect the privacy of every person who visits or registers with https://higginsonstrategy.com/ (the “Site”) and agree that any information relating to an identified or identifiable individual (“personal data”) is deserving of protection.

On this Site there may be links to other websites. Please understand that if a particular website has its own privacy policy then that policy – not this Privacy policy – applies.

  1. Who we are
  2. Contact us
  3. How we use your personal data and our legal basis
  4. What personal data we collect and for which purpose
  5. Who we share your personal data with
  6. How long will we keep your personal data
  7. Where we keep your personal data
  8. Confidentiality and security of personal data
  9. Your data subject rights
  10. Contacting the Regulator
  11. Cookies
  12. Privacy Policy Changes

 

1. Who we are

We are Higginson PR Limited, a company incorporated in England and Wales with registration number 10664359 whose registered office is at Aldgate Tower, 2 Leman Street, London, E1 8FA (“Higginson Strategy”, “we”, “us” or “our”). We are the data controller responsible for your personal data via the Site. This means that we decide the purposes and means of the processing of your personal data. We are registered with the Information Commissioner’s Office (“ICO”) under number: ZA496413

2. Contact us

If you have any questions about how your personal data is collected or used please email us at alex@higginsonstrategy.com or write to us at Higginson Strategy, Higginson PR Limited, Aldgate Tower, 2 Leman Street, London, E1 8FA.

3. How we use your personal data and our legal basis

We will only process your personal data in a way that the law allows us to. This means we must have a lawful reason (sometimes called legal basis). Generally we will use your personal data in the following circumstances (but please note that more than one may apply at any given time):

  • To perform a contract we are entering into, or have entered into, with you;
  • If it is in our legitimate interests (or those of a third party) and such interests are not overridden by your fundamental rights and freedoms;
  • When we are subject to a legal or regulatory obligation;
  • When we have your consent which we will collect at the time we ask for your data

We have included a table in Section 4 detailing our legal basis

4. What   personal   data   we collect and for which purpose

We collect and process personal data as follows:

Circumstance: Data: Legal basis
·         If you are a Client (or you work for a client of ours) We collect your individual contact details for example email address and/or mobile number to enable us to communicate with you in relation to the provision of our services (for example, when we design your media strategies or assist in drafting captivating poignant speeches) and other personal data relating to you in the course of providing the services concerned (for example, bank account details or other financial information). Other details for example but without limitation including any regulatory Know Your Client and or Anti Money Laundering regulations (or

similar) information.

·         Performance of a contract

·         Legitimate interest – it is in our legitimate interest to have full details about you in order to provide our services as well as conduct and manage our business

·         If you provide goods or services (or you work for, or are an agent for, someone who supplies goods or services) to us or to any of our clients (for example regarding an                advertising campaign). This may include different people such as actors, performers, as well as sports pundits and others who are involved in licensing, endorsement or promotion or on behalf of us or our clients We collect your individual contact details to enable us, our clients or other suppliers of ours to communicate with you in relation to the provision of goods or services. ·         Performance of a contract

·         Legitimate interest – it is in our legitimate interest to have records of who we are currently working with and for which project

·         When we are accessing your suitability or ability in providing goods or services to us or any of our clients We collect certain personal data to the extent we believe is reasonably necessary to enable our assessment to take place – for example, where we need to confirm your age, address, right to work    in    the    UK,  previous experience, your qualifications. This will be explained in greater detail at the time we collect this information and where appropriate, will be subject to your prior consent. ·         Performance of a contract

·         Legitimate interest – it is in our legitimate interest to have full details about our suppliers in order to analyse, improve and update our services for the benefit of our customers

 

·         When you are invited to, or attend, an event organized by us or managed by us We collect your individual contact details and related information (of anyone attending with you) to facilitate your attendance (for example, dietary or special access requirements). ·         Performance of a contract – where we invite you to attend an event organized by us

·         Legitimate interest – it is in our legitimate interest to have your contact and dietary details provide you with information regarding the event

·         Consent

·         If you are a respondent to any survey, research, interview or other enquiry we carry out We collect personal data for you as part of the survey, although in practice we will normally provide you at the time with more details about how we will process this personal data (and such processing may be subject to a more specific policy which will be provided to you at the time) ·         Consent – where you take part in the survey
·         If you browse our Site When you browse this Site we collect certain information about how you move about the website for analytics purposes to better understand how our Site functions and how to improve its functionality. We keep records of the content of our Site that you have clicked on and then use that information to target advertising on this Site that may be relevant to your interests and those which we have identified based on the content you browsed. This involves the use of cookies. Further information about our Cookie Policy can be found here.  

·         Legitimate interests – it is in our legitimate interests to let you know about our services, promotions or adverts that we consider may be of relevance to you (and which may be tailored to your individual interests)

·         If you apply for a job with us We collect certain personal data to the extent we believe is reasonably necessary to enable our assessment to take place – for example your qualifications, experience,   previous  criminal history and right to work in the UK. Some of this data may be deemed (“special data”) and in the circumstances we will require your explicit consent. Other details for example but without limitation including any regulatory Know Your Client and or Anti Money Laundering regulations (or similar) information. ·         Performance of a contract

5. Who we share your personal data with

We only share your personal data with those who we reasonably believe require access. In doing so we may share your personal data with:

  • Members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
  • Appropriate third-parties including:
    • Our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings which we may have in the normal course of business with you or person that you work for;
    • Our auditors, legal advisors and other professional advisors or service providers;
    • Credit or other similar rating agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for;
    • Our Ad partners and advertising networks that require certain data in order to select and serve relevant ads to you and others. Note we do not disclose information about identifiable individuals to our advertisers, but will provide aggregate data about our Further information concerning cookie tracking can be found here;
    • In the event that we sell or buy any business assets, in such case we may disclose certain personal data to the prospective seller or the buyer of such business subject to the terms of this Privacy Policy;
    • If we or substantially all our assets are acquired by a third party, in which case personal data held by us and our customers will be one of those transferred assets; and
    • When we are under a legal or regulatory duty to disclose your personal data, or to enforce our terms of business and other This includes sharing information with other companies and organisations for the purpose of child protection, fraud protection, or credit risk reduction.

6. How long will we keep your personal data

We are very careful about the personal information we store and we will not keep your information in a manner and form that identifies you for longer than is strictly necessary for the purposes set out in this Privacy Policy or applicable law. There are certain instance where we are required to keep your information for a minimum period – for example under UK Tax law there is a six-year period of retention for some personal data. For more information on our retention schedules please contact alex@higginsonstrategy.com.

7. Where we keep your personal data

All our data servers are based in England. However we may transfer your personal data to a location (for example, to a secure server) outside the United Kingdom or European Economic Area if we consider it reasonably necessary or desirable for the purposes set out in this Privacy Policy.

In such cases, we will ensure that we safeguard your privacy rights and that such transfers:

  • Will only be made to recipients where the European Commission has issued an “adequacy decision” (this is a European Commission decision that confirms a country has adequate safeguards in place for the protection of personal data);
  • Carried out under standard data protection contractual clauses that have been approved the European Commission or by the adoption of EU-US Privacy

8. Confidentiality and security of personal data

We have a number of security measures in place designed to prevent data loss, to preserve data integrity, and to regulate our access to the data. We maintain technical, organizational and administrative measures (appropriate to the risk) to protect personal data within our organisation. Your personal data is only available to a limited number of personnel who need access to this information to perform their duties.

We regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. However, whilst we use all reasonable commercial endeavors to ensure your information remains secure, we cannot guarantee the security of the data transmitted to us. Any transmission over the internet is at your own risk.

For more information on how we ensure that your data remains secure and how we prevent unauthorized access please contact us by email at alex@higginsonstrategy.com.

9. Your data subject rights

This section helps explain your data protection rights. To submit a Data Subject Access Request (“DSAR”) please get in touch with alex@higginsonstrategy.com. Under the GDPR you have the right to:

  • Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific
  • Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about
  • Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose for which it was originally
  • Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest its accuracy, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal right. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift a temporary processing restriction.
  • Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if this is technically
  • Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected
  • Right to Object to Direct Marketing including Profiling – You can object to our use of your Personal Data for direct marketing purposes, including We may need to keep some minimal information (such as your email address) to comply with your request to cease marketing to you.
  • Right to Withdraw Consent – You can withdraw consent that you have previously given to one or more specified purposes to process your personal This will not affect the lawfulness of any processing carried out before you withdrew your consent. It may mean we are not able to provide certain products or services to you and we will inform you if this is the case.

We will not charge a fee for you to exercise any of these rights. However, we may charge a reasonable fee under certain circumstances for example where your request is clearly unfounded, repetitive or excessive. Your rights are subject to certain limitations prescribed by law. Further information about your rights can be found on the Information Commissioner’s Office (“ICO”) website.

 

10. Contacting the Regulator

In the event you have a compliant or unhappy with the way in which we have dealt with your DSAR then you should contact the ICO. You can contact them on their website, or by telephone on 0303 123 1113.

11. Cookies

Our Site makes use cookies. For more information on which cookies we use and how we use them, please see our cookie policy available here.

 

12. Privacy Policy Changes

We may make changes to this Privacy Policy from time to time. We advise you to refer back to this Privacy Policy to review changes. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email (where you have opted-in) of any significant changes.