(Last updated: 22.05.2018)
Spink Limited (Spink) is committed to protecting your privacy and complies with the principles of the relevant data protection regulations, including the Data Protection Act (DPA) and the General Data Protection Regulation (GDPR).
+44 (0) 1444 811 099
The Hay Loft
Balcombe Place Stables
Spink is a member of the PRCA and abides by its Professional Charter as well as the relevant codes of conduct. You can find more information about the PRCA and their professional charter here
What information does Spink collect?
We collect names, email addresses, addresses, telephone numbers, as well as job titles and places of work and photographs.
When working with journalists, we may also collect health information – e.g. if a journalist has a health condition and writes about it. When working with case studies and celebrity case studies we may also collect information about a person’s age, race and ethnicity, marital status, sexuality, sex life and health information. This information is known as ‘special category data’ and we will only do this with the consent of the person whose data we are collecting.
Justification for collecting this information is detailed in our ‘Lawful Basis Record, Legitimate Interest Assessments and Conditions for Special Category Data’ document which we are happy to share with you on request. Please contact us using the details in this document.
How is it collected and who by?
We collect personal data through third party media and contact databases (one-off and subscription contact lists), internet searches and websites, media publications, via social media and through direct communications.
We may also be given data by our clients and organisations that we work with, who will be acting as ‘Data Controllers’ and share data with us as ‘Data Processors’.
Who will it be shared with?
As ‘Data Controllers’, Spink may share your information with ‘Data Processors’ – however, we will notify you that we are going to do this, and where necessary, ask your explicit consent. The ‘Data Processor’ will have to abide by the same conditions that govern how Spink deals with your data.
How Spink use personal data
We use data for a number of different communications functions, central to the operation of a public relations and public affairs agency. These include: communicating news and campaigns to journalists and other interested stakeholder organisations, organising events, engaging with experts and policy makers and raising public awareness of health conditions and products.
Justification for collecting this information is detailed in our ‘Lawful Basis Record, Legitimate Interest Assessments and Conditions for Special Category Data’ document which we are happy to share with you on request, please contact us using the details in this document.
Data Retention Periods
We hold all data indefinitely until it is no longer relevant or necessary for us to do so. We also review our data on an ongoing basis, and all contacts at least annually. We review our data so that we may delete data that we hold which is no longer necessary for us to do so. Where we identify or are alerted that data is inaccurate, it will change or delete it immediately.
Your data and your rights
You have the following rights in relation to our data controlling and data processing activities:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
For a full description of your rights as listed above, please visit the Information Commissioner’s Office website, which you can access by clicking here
How you can access, correct, port and update your information
To find out what information we hold about you, please contact us using the contact details listed below. You can also use these details to let us know of any corrections or updates to the information we hold on you (e.g. a change of email address). You may also ask that we port your information, in which case we will give you the data we hold on you in a .CSV file. We will respond to your request within 28 days, although in practice we aim to do this much more quickly.
Requests are free of charge – we would only consider making a charge if your request is ‘manifestly unfounded or excessive’ as defined by the Information Commissioner’s Office.
How you can withdraw consent for us to use your data, request erasure, restriction of processing or object to our processing
If we have asked you for consent to contact you, you may withdraw your consent at any time by making a request to us using the contact details below. If we have not asked you for consent but you would like to ask that we erase your data, or you would like to object to or request a restriction of processing of your data, then please contact us using the details below. We will respond to your request within 28 days, although in practice we aim to do this much more quickly.
How to lodge a complaint
If you wish to lodge a complaint against us in relation to our data controlling and data processing activities, please contact us in the first instance and we will do everything we can to resolve the issue.
If you are not happy with our response, the responsible authority in the UK is the Information Commissioner’s Office. Please click here to lodge a complaint.
Security and your data
All personal data is stored on a secure electronic content management system. Where possible and practical, we try to avoid holding any physical copies of data at all. Where we do hold physical copies, these are stored and destroyed securely.
Automated Decision Making and Profiling
We do not undertake any automated decision making or profiling.
Children (16 and under)
Our data controlling and processing activities do not require us to regularly collect the data of children. However, we may do this for e.g. case studies. We will only collect a child’s data with the consent of their parent and/or guardian.
Transferring information outside Europe
We will never give your data to anybody outside of Europe without your explicit permission. Even when we have your permission, we will still need to ensure that the ‘Data Processor’ complies with the GDPR and uses the same conditions for data handling and storage that we do.
A cookie is a small piece of information sent by a webserver to a web browser which enables the server to collect information from the browser. Cookies allow us to do things such as count visits and traffic sources so Spink can measure and improve the performance of its website. They help us to know which pages are the most and least popular and see how visitors move around the site.
Most browsers will allow you to turn off cookies, to do this, please click the help page on your web browser.
Spink use the following third-party applications for collecting cookies:
SquareSpace website and analytics
Spink uses Google AdWords to advertise its business. When people interact with our ads (by clicking a text ad or viewing a video ad), AdWords stores a cookie on our domain that contains information about the interaction. When someone converts on our website, the conversion tracking tag that Spink has installed reads this cookie and sends it back to AdWords with the conversion information. AdWords collects information on age, gender, location and device type used to access our website.
Spink uses Google Analytics to help it understand how you use the site and ways that it can improve your experience. These cookies track things such as how long you spend on the site and the pages that you visit so Spink can continue to produce engaging content. For more information on Google Analytics cookies, visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
We use social media plugins on our website that allows you to connect with your social network in various ways. For these to work the following social media sites including; LinkedIn, Facebook, Twitter; will set cookies through our website which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Some of the content on our site may be provided by third parties. This includes Google Maps for interactive mapping, YouTube or Vimeo for hosted video and Flickr for images. When you visit a page containing content from one of these sites a cookie may be set. Spink do not control these cookies and you should check the relevant third-party website for more information about these.
This cookie identifies the sites you visit subsequent to visiting our website and allows better and more relevant ads to be displayed to you. To find out more, visit: https://policies.google.com/technologies/ads
Reviewing the Policy
This policy will be reviewed on an annual basis and as and when necessary following any legislative changes or relevant best practice recommendations. The last review data is specified at the top of this policy.
If you would like to know more about the DPA or the GDPR – which includes the rights and responsibilities of data subjects, controllers and processors, then please visit the Information Commissioner’s Office website by clicking here.
You may also request to see our ‘Lawful Basis Record, Legitimate Interest Assessments and Conditions for Special Category Data’ document. This document includes:
- Our categorisation of the data we hold
- Our lawful basis for collecting and using the data we hold
- Our reasoning and justifications for collecting and using the data we hold (as defined by the GDPR)
- The identification of special category data collection
- The conditions that we collect special category data (as defined by the GDPR)
Should you wish to see this document or have any questions relating to this document, please do not hesitate to contact our Office Manager who will be happy to assist your enquiry.
For more information, to make a request or lodge a complaint, please contact our Office Manager, Clare Beard:
+44 (0) 1444 811 099
The Hay Loft
Balcombe Place Stables