EFFECTIVE DATE: MARCH 21, 2018
WHO WE ARE
Kennedy News and Media (“us”, “we”, or “our”) is the data controller in relation to the EU General Data Protection Regulation (GDPR). Our registered office address is 4th Floor Tuition House 27/37 St George’s Road, Wimbledon, London, England, SW19 4EU, with a company number 11268029 and our ICO registration number is ZB112478.
WHAT THIS RELATES TO
This page informs you of our policies regarding the collection, use, and disclosure of personal data and the choices you have associated with that data. It refers to the following groups of individuals: a) website visitors b) those working for our customers and suppliers and c) those featured in our content such as news articles, features, videos and any other media.
Personal data is defined in the UK GDPR as any information relating to an identified or identifiable natural person. The UK GDPR does not apply to personal data that has been anonymised.
THE TYPE OF DATA WE COLLECT
The type of data we collect depends on what group you fit into, as listed above. This can include (but is not limited to and may not always include all of these):
- A) Website visitors: You may choose to provide us with certain personally identifiable information that can be used to contact or identify you such as through, but not limited to, our ‘Contact Us’ form, over email or telephone. Personally identifiable information may include, but is not limited to: Email address, First name and last name, Phone number, Address, State, Province, ZIP/Postal code, City along with Cookies and Usage Data from visiting our website [for more information on Cookies and Usage Data, please see sections listed below].
- B) Those working for our customers and suppliers: your name and contact details along with job title, company and/or publication you work for, and other relevant details relating to your role such as specific department, as well as any correspondence that you may have with us.
- C) Those featured in our content such as news articles, features, videos and any other media: name(s), likeness, any correspondence we have with you, any biographical and similar information about you and any relevant contact details or bank details provided by you.
HOW WE SOURCE THE DATA
Personal data may be sourced in a variety of methods, including:
Direct correspondence: You may provide us with personal data through direct correspondence with us such as by completing forms, or when communicating with us via phone, email, social media, messenger services or other methods of correspondence.
Automated sourcing: This may occur when visiting our website. For more information on Cookies and Usage Data, please see below.
Third parties or publicly available sources: We may source data from third parties or publicly available sources where lawfully necessary for us to conduct our business.
HOW WE USE THE DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where necessary to enter into or where we have already entered into a contract or agreement with you, where necessary for our – or a third party’s – legitimate interests (and when your fundamental rights do not override those legitimate interests), and in order to comply with any legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you such as via email or text message. You have the right to withdraw consent to such marketing communications at any time. For example, our email marketing has an ‘unsubscribe’ tab within each email. Or you can contact us directly to request this at any time.
How we use the data depends on what group you fit into, as listed above. This can include:
- A) Website visitors: To respond to your query if you have contacted us via the ‘Contact Us’ form. For Cookies and Usage Data, see below.
- B) Those working for our customers and suppliers: to contact you when necessary about relevant work or respond to your queries or for any performance of a contract with you or the organisation you represent or any employee or representative of that organisation.
- C) Those featured in our content such as news articles, features, videos and any other media: To contact you to discuss the content or respond to your queries about the content, to make any relevant payments, to investigate, author, publish or syndicate journalistic, artistic, academic or literary works and all necessary correspondence and processing of data that is required to allow this.
We always respect the confidentiality and security of any personal data that is provided to us or obtained by us. However the Data Protection Act 2018 notes important exemptions, particularly in relation to when the personal data is processed for journalistic, academic, artistic or literary purposes. Together, these are known as the ‘special purposes’.
The exemption applies to these special purposes when the controller reasonably believes that compliance with these provisions would be incompatible with the special purposes; the processing is being carried out with a view to the publication of some journalistic, academic, artistic or literary material; and the controller reasonably believes that the publication of the material would be in the public interest, taking into account the special importance of the general public interest in freedom of expression, any specific public interest in the particular subject, and the potential to harm individuals.
While we are not a member of the Independent Press Standard Organisation (IPSO), Kennedy News also takes pride in following IPSO’s Editors’ Code of Practice.
WHO WE SHARE THE DATA WITH
Personal data may be shared with the appropriate staff within Kennedy News and Media.
We may also share your data with: tax authorities; legal, banking, insurance, accounting or auditing services who we rely on; service providers; internet hosts and marketing tools such as for newsletters, where appropriate; any third parties to whom we sell, merge or transfer parts of our business or assets; any third parties we acquire or merge with; any other third parties that have been agreed in correspondence with you.
HOW WE KEEP PERSONAL DATA SECURE
We have appropriate security measures in place to prevent any personal data from being accidentally lost, stolen, used, altered, disclosed or accessed in an unauthorised way. Access is limited to only those within our organisation who need access to the data.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
HOW LONG WE KEEP PERSONAL DATA
We only keep personal data for as long as is necessary for the purposes that we collected it for, as well as to comply with any necessary legal, accounting or reporting requirements. If you wish us to delete any personal data we hold, please see below.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
We also use Google Analytics to collect information about how people use our website.
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Subject to the exemptions outlined above, you may contact us to exercise any of the following rights:
- Request access: You have the right to request access to any personal data held about you. This is known as a Subject Access Request. More information can be found here.[ https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/]
- Request correction: You have the right to request a correction or alteration of any personal data held about you. This may be subject to further checks to ensure the accuracy of the data.
- Request deletion: You have the right to request the deletion of any personal data held about you.
- Request restriction: You have the right to request the restriction of any personal data held about you, to establish the data’s accuracy or our grounds for holding it.
- Object to the processing of your personal data. You can also object to the holding of your data for direct marketing.
- Request transfer: You have the right to request the transfer of any personal data held about you via common electronic means or formats. Note this only applies to data provided with your consent and processed by automated means.
- Right to complain: You have the right to complain about the use of any of your personal data to the Information Commissioner’s Office (ICO).
Please note: If for any reason we are unable to lawfully comply with any of the above requests, for example due to any exemptions that may apply, you will be notified of this where required.
DATA OF OTHER INDIVIDUALS
If you provide Kennedy News and Media with personal data belonging to someone else, you confirm that you are acting on their behalf, that they gave the necessary consents and permissions for you to provide the data and that they gave consent for the data to be processed for the purposes and in the ways that we agreed with you or outlined here.
HOW TO CONTACT US
All queries will be responded to within 30 days.