We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
1. Who we are
BRASS MARKETING AGENCY LIMITED collects, uses, and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Data Controller: Brass Agency of Kemp House, 160 City Road, London, EC1V 2XN.
ICO Registration Number: Z5846974
2. Where we are based
We are based in Leeds, West Yorkshire within the European Economic Area.
3. The personal information we collect and use
Information collected by us
As providers of a full range of marketing services we carry out. In the course of preparing and carrying out our marketing services we collect the following personal information when you provide it to us (whether in person, by post, by telephone, email or other electronic correspondence, via our website, or by our operating security policies and procedures in our offices (i.e. by virtue of CCTV operated by our landlord in the office building generally (to which we have access) or to our own CCTV and record keeping within those offices)
- contact number; and
- email address details
As an employer of staff, when you provide it to us we also collect information about employment history, education attainments and information equality monitoring information. We may also collect any further personal data provided by you for the purposes of your engagement.
Each time you visit our websites we may automatically collect the following information :-
• Web usage information (e.g. IP address), your log in details (only as applicable to accessing secure areas of our website), browser type and version, time zone setting, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
• Location, device and demographic information (Google Analytics provides age range and gender information. Find out more about how Google collects demographic data).
4. Information collected from other sources
We also obtain personal information from other sources as follows:
• Before you have engaged our services, personal information such as name and address, phone number and email address, provided to us by an organisation with whom we have relationships.
• Names, addresses, contact details, educational and employment experience and attainments from individuals, recruitment agents and from education establishments such as universities colleges and schools in respect of potential job opportunities, websites, LinkedIn or a specific, direct approach to an organisation.
5. How we use your personal information
• To enable us to create a unique and self-contained file reference for your matter.
• To communicate with you generally and in response to any query you send us.
• To manage our relationship with you (and/or your business), including by maintaining a database of clients and third parties for administration and accounting and relationship management purposes).
• Within documents so that we can advance the matter that we are conducting on your behalf.
• To allow us to comply with statutory and professional obligations to identify clients, and comply with the rules against Money Laundering, Terrorist Financing, Sanctions checks and Criminal Finances – all to minimise the risk of fraud.
• To send you any relevant information on our services and events that may be of interest to you using the email and/or postal addresses which you have provided (but only if you have given us you consent to do so and until that consent is withdrawn).
• To process any job application that you or your representative have submitted.
• To ensure our websites content is presented in the most effective manner for you and your device.
• To ensure our websites content is presented in the most effective manner for you and your device.
• To administer our website and for internal operations including troubleshooting, data analysis, testing research, statistical and survey purposes.
• To ensure we properly administer any attendance /visits to our offices, for security and safety reasons.
• To comply with the professional, legal and regulatory obligations that apply to us or policies that we have in place.
• Such as we feel is necessary to protect our interests and/or to prevent illegal activity.
6. Who we share your personal information with
We routinely share your name and contact details with our third party suppliers when you specifically request us to and when this is necessary to provide the marketing services that you have asked us for, falling within the following categories: –
• HM Revenue and Customs and other national and statutory institutions.
• With our insurers, our bank, and our auditors.
• Our data processors providing email security, shredding, archiving and other business support services.
• Any third party that you ask us to share your information with.
This data sharing enables those suitable third parties to provide additional information and advice to allow the proper assessment of your matter.
Only in exceptional circumstances, will any of those third party recipients be based outside the European Economic Area (see below).
If you engage us to carry out work for you we will share personal information with other representatives acting for other parties to your matter.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
7. Whether information has to be provided by you, and if so why
Brass Agency Ltd will inform you at the point of collecting information from you, whether you are required to provide the information to us. We will not share your personal information with any other third party.
8. How long your personal information will be kept
We will retain your personal data within our files and records either for 6 years, depending on the nature of the matter on which we were engaged by you, and in accordance with our Data Retention Guidelines and the Terms of Retainer between us. The period that we are required to retain financial information by applicable UK tax law is currently 6 years. While the information is held by us as a record for mutual benefit of both you and our company, it will not be actively used or shared with any third parties unless it is required to assist with advancing or defending a legal case, or you have consented to such sharing. Once the data retention period has ended the data will be destroyed. Our archive providers who hold the paper records are instructed to destroy them. Where you or your representative has provided personal information in connection with a specific or potential job opportunity we will retain that information for up to two years before destroying it. This is on the basis it provides a suitable balance between your interests and those of Brass Agency Ltd.
9. Reasons we can collect and use your personal information
Under the General Data Protection Regulations we can only “process” (i.e. collect, use, store, manipulate) personal data, if we can demonstrate at least one a specified legal grounds for doing so. We rely on several of the specified legal grounds, as follows:
(1) Performance of or entry into a contract.
If we are to act for you we rely on contract as the lawful basis on which we collect and use your personal data such as name, address, contact details, and other information pertinent to your matter.
(2) Compliance with a legal obligation to which we are subject
For example in respect of information collected to comply with Anti Money Laundering legislation, Counter–Terrorism and Tax Evasion.
(3) We have a legitimate interest in doing so
As a legal services provider, in circumstances where our legitimate interests are not overridden by your (or the relevant individuals) interests or fundamental rights or freedoms we may retain personal information on that ground. Such legitimate interests will include our interests in managing our relationships with clients administering visits to our offices and ascertaining achievement of proper standards and compliance with policies and procedures.
They may also include retention of file records including personal data beyond the time for which our contractual basis for retention has expired, because for the protection of our company and the client where a legal liability may subsists for up to fifteen years from the completion of the transaction. On the basis that the risk of potential harm to you of retaining the personal information is outweighed by the benefit to us and also to you of being able to recreate the history and documents of the transaction or matter
(4) Where processing of “special category personal data” is necessary in the context of the establishment , exercise or defence of legal claims
In such circumstances we rely on express consent received from you and/or our assessment that special category personal information held within the matter file is necessary for the establishment, exercise and or defence of legal rights – so as to allow claims to be advanced within a suitable limitation period. As we will explain when we collect that consent, you may withdraw it at any time in accordance with the information we will provide.
10. Consequences of our use of your personal information
We maintain strict security procedures as to how your personal information is stored and used, as to who sees it, to help prevent any unauthorised person getting hold of it. We also have security and cyber security measures in place and under constant review.
As a consequence, although we cannot provide an absolute guarantee that your information is secure, on balance we do not envisage that:
• the use of personal information to promote your matter or enquiry; or
• its retention to comply with contract, our legal obligations and our professional indemnity insurers guidance
will have any adverse effect to or for you as our client or user of our website services.
11. Transfer of your information out of the EEA
We will not transfer your personal information to third parties located outside the UK or the European Economic Area (EEA), save where we are specifically instructed to do so.
Countries outside the United Kingdom and EEA do not have the same data protection laws, and where it is necessary to send personal data to such countries we will ensure we do so in accordance with the provisions of the General Data Protection Regulation which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information about such transfers please contact our Company Secretary, who is our Responsible Officer (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the United Kingdom.
12. Your rights
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
• fair processing of information and transparency over how we use your use personal information
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• in certain situations only, to require the erasure of personal information concerning you
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email, [email protected] or write to us at Company Secretary, Brass Agency Limited, Moorfield House, Alma Road, Leeds, LS6 2AH.
Before we can process your request we will need:-
• enough information to identify you (e.g. your name and file reference number);
• proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill) – this is to prevent unauthorised access; and
• the information to which your request relates.
Please note – that if an access request is unfounded, excessive, or especially repetitive, we may charge a reasonable fee for meeting that request. Similarly we may charge a reasonable fee (based on the administrative costs of doing so ) for dealing with requests for further copies of the same information.
If you would like to unsubscribe from any email Brass Agency newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email/newsletter. It may take up to 5 working days for this to take place.
13. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We secure our website with a 256-bit SSL certificate which is verified by a trusted third party. This ensures that your connection to our website is private and secure at all times.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. How to complain
We hope that our Company Secretary can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on 25th May 2018.
We may change this privacy notice from time to time, when we do we will inform you by email.
How to contact us
Please contact our Company Secretary if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact our Company Secretary please use the following details:
Email: [email protected]
Address: Moorfield House, Alma Road, Leeds, LS6 2AH
Tel: 0113 230 4000
Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).