The Purpose of this privacy statement is to explain how Stella Gooch Social processes all personal data to fulfil its data protection responsibilities. Brief definitions of data protection, personal data and processing can be found at the of this statement. The scope of this statement covers all related activities by the staff of Stella Gooch Social which is just referred to as SGS for the remainder of this privacy statement.
The Role of SGS in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the SGS privacy manager (PM) to ensure that it is processed in accordance with the latest UK and EU data protection legislation. The PM can be contacted by email using .
The personal data processed by SGS will only be basic contact information for the purposes of networking, business development, preparing contracts and setting up invoices. Banking details will also be collected for the purpose of paying creditors. With your permission, passwords will be collected for access to your media platforms.
SGS’ duty of confidentiality means that SGS will treat client data with due respect and in confidence. It is only disclosed to staff that need to know it. SGS uses reasonable organisational and technical measures to ensure personal data is safeguarded adequately. SGS also expects the same duty of confidentiality of all third parties with whom it shares personal data, including contractors. Sharing is kept to a minimum and reviewed regularly.
SGS processes personal data using a lawful basis and:
- will use legitimate business interests to respond to your general enquiries
- to comply with any legal obligation
- when it is necessary for the performance of a contract and its prior preparation
- when processing a pre-defined purpose for which your consent has been sought and recorded prior to that processing commencing.
In all cases the processing of personal data by SGS shall be:
- processed fairly, lawfully and transparently
- collected for specified, explicit and legitimate purposes
- adequate, relevant and limited to what is necessary (and no more)
- accurate and, when necessary, updated
- kept for no longer than is necessary
- processed in a manner that ensures appropriate security
SGS will share personal data, but only when absolutely necessary, with some or all of the following third parties:
- Solicitors appointed by SGS
- The Inland Revenue (HMRC)
- Web designers, graphic designers and IT consultants
- Between business professionals that provide relevant services
- Accountants appointed by SGS and only for accounting purposes
- Unspecified recipients but only when compelled to do so for legal reasons
- SGS Sub-contractors, if appointed, who are subject to a data processing agreement
SGS will process your data in different places but mostly within the European Economic Area (EEA). First line personal data processing takes place in the UK, but it is backed up using One Drive/Office 365, Google Drive and Dropbox. Email is processed using a reputable web-based provider and client contacts are stored on both office IT equipment and mobile phones. It should be noted that no personal data is stored on SGS’ website server.
SGS follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:
- Routine correspondence for casual enquiries that do not lead to a contract will be stored for no more than one year after the last contact
- Routine correspondence that leads to a contract, and during a contract, will be stored for no more than 3 years after the contract has ended
- Contact data is stored indefinitely unless you request it is erased and we do not have further justification for retaining it
- Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
- By exception, documentation that includes personal data may be retained beyond this schedule, but only for a specific purpose and only when we believe we have a business legitimate interest, or we have legal obligation to do so
At the end of the retention schedule SGS will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that SGS allows up to 3 months after the retention schedule to complete the action.
The SGS website links to appropriate business websites of interest. If these are used, you should be aware that the SGS has no responsibility for the control, content or handling of your personal data by these other websites.
The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations). For convenience, these rights are shown below:
- Right to be informed as to how your personal data is being processed by us – this is done through this statement or separate SGS privacy notices
- Right to access your personal data held by SGS which is done by making a ‘Data Subject Access Request’ (DSAR) to our PM
- Right to rectification of your personal data if you believe we have collected it incorrectly or it needs to be updated
- Right to erasure of your personal data for which we no longer have a legitimate purpose to process
- Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved
- Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
- Right to object to SGS processing your personal data for which it does not have a legal or contractual obligation
- Rights related to automated decision making and profiling (however SGS does not use these techniques in its decision making)
Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.
Raising concerns, exercising rights or making queries about the way we are processing your personal data can be done by contacting the SGS PM. Please be aware that we will need to verify your identity before responding fully, therefore, you may be asked for proof of ID or other material. Alternatively, you may wish to contact the ICO directly, using the details provided above.
What data protection, personal data and processing means
The term data protection, put simply, means the protection of personal data against misuse and abuse. Personal data means any information relating to an identified or identifiable natural person, also referred to as a ‘data subject’. Processing has a very wide interpretation and means any operation which is performed on personal data or on sets of personal data whether or not by automated means. This includes, inter alia, collection, recording, storage, adaptation, retrieval, actual use, dissemination or otherwise making available, restricting, erasure or destruction.