GDPR 2018 PRIVACY NOTICE
Accolade Europe Ltd
This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as the Electoral Roll, LinkedIn and Companies House data.
Accolade Europe Limited (Accolade) is a UK based marketing agency working in the Business to Business marketing (B2B) sector.
Accolade uses business related information in 3 key ways:
- We research organisations and individuals working in certain job roles and compile contact databases that are used to market our Client’s offerings or to carry out market research. We act on behalf of our Clients in the capacity of data processor. When working exclusively as a data processor, Accolade will be acting on the instruction of its Client and will work hard to ensure that the Client is fully GDPR compliant.
- We are provided with lists by our business partners in order to work on Campaigns for them where we market our Client’s offerings or to carry out market research.
- We collect information from our Clients to provide quotations, make telephone contact and to email you marketing information which the agency believes may be of interest to you and your business. In you making initial contact you consent to Accolade maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to stop promoting our services to you.
Some personal data may be collected from the forms and surveys completed, for example, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. Accolade may from time to time use such information to identify its visitors. Accolade may also collect statistics about the behaviour of visitors to its website.
Accolade uses Google Analytics to identify visitors to our website. This does not provide us with details of individual users, only the names of organisations whose servers were used to access the site such as companies and Internet Service Providers.
Any information that Accolade holds about you and your business encompasses all the details we hold about you and any third-party information we have obtained about you from public sources and conversations with you such as telephone conversations and email conversations.
Accolade will only collect the information needed so that it can market our Clients’ offerings or provide our Clients with PR and marketing services. Any contact lists that we build are used for a Client’s campaign or to market to our own clients. Accolade does not sell or broker marketing lists, although coincidentally there may be times when your information could be contained in data that Accolade has purchased from a third-party list broker, on behalf of a Client.
Legal basis for processing any personal data
To meet Accolade’s contractual obligations to Clients in providing market research and marketing services, and to also respond to marketing enquiries made to Accolade.
Legitimate interests pursued by Accolade and/or its Clients
To promote the research, marketing and GDPR services offered by Accolade and/or to market the services and/or products offered by Accolade’s Clients.
Through agreeing to this privacy notice you are consenting to Accolade processing your personal data for the purposes outlined in the Notice. You can withdraw consent at any time by emailing firstname.lastname@example.org or by phoning +44 (0) 20 7372 2200 or writing to us at The Data Processor, Accolade Business Services Limited, One Kingdom Street, Paddington Central, London W2 6BD.
Accolade will on occasions pass your Personal Information to our Clients exclusively to process work on their behalf. Accolade requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. However, Accolade may also disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Accolade, its Clients and/or the wider community.
Accolade will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.
Data is held in the United Kingdom using one server in a secure alarmed location and passwords are needed to access the data. Some data is backed up to a secure Carbonite Server in the USA. Data is transferred between Accolade and our Clients using a secure DropBox facilility.