Any questions relating to data privacy with Totally Communications or this policy should be sent by email to: email@example.com or by writing to Totally Communications – Unit 801 Highgate Studios, 53 – 79 Highgate Road, Kentish Town, London NW5 1TL
Alternatively, you can call our Data Compliance Officer on 020 7284 9730
What personal Information is held
We may collect and process the following data from you:
– Information you consent to provide Totally Communications that is required to carry out our obligations arising from any contracts entered between you and us, or potential contracts that may be in liaison between you and us.
– Information that you consent to provide by filling in forms on our website, or as part of any direct marketing or sales activities. This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address and interests.
Note: Clear consent information is supplied at point of collection to provide information on the use of data; and a record of the consent is taken at point of collection.
– If you contact us by telephone or in writing, we may keep a copy of your correspondence or communication.
If you have provided us with the personal data of another person, there is a clear requirement imposed by Totally Communications for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place. Records will be retained as evidence of this consent.
How will we use the information we hold about you?
We use information held about you in the following ways:
Performance of a contract – We use information held about you to carry out our obligations arising from any contracts entered into between you and us; and to notify you about changes to our services.
Legitimate Interests – We use information held about you to provide you with information, products and/or services that you request from us or which we feel may interest you if relevant to the products or services currently being supplied as part of a contract with Totally Communications, or in relation to a previous contract with Totally Communications whereby you are happy to continue to receive such information;
Consent (Direct Marketing) – We use information held about you to provide you with information on products and/or services that you request from us, or which we feel may interest you where you have consented to be contacted for such purposes. Where consent has been provided to Totally Communications, it is a recognised right of the Data Subject that this consent can also be withdrawn. Should you wish to withdraw consent, please email firstname.lastname@example.org or by writing to Data Compliance Officer, Totally Communications, Unit 801 Highgate Studios, 53 – 79 Highgate Road, Kentish Town, London NW5 1TL. Alternatively, you can call our Data Compliance Officer on 020 7284 9730
We will not share your data with third parties for other marketing purposes unless we have your express consent to do so.
Your rights relating to Personal Data
You have the right to ask us to cease processing your personal data for marketing purposes. We will seek consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can also exercise your right to prevent such processing by contacting us at email@example.com.
GDPR gives you the right to access information held about you. Your right of access can be exercised at any time. Totally Communications operate both a Data Subjects Rights procedure and a Subject Access Rights Procedure to ensure that all rights exercised by data subjects relating to personal data are managed appropriately.
From time to time, our website may contain links to and from our strategic partner(s), partner network(s), strategic sponsor(s), advertiser(s) and affiliate(s). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Retention of your information
We take appropriate measures to ensure that any information collected from you is kept secure.
Totally Communications operate a clear Retention Policy and associated Retention Schedule to ensure personal data is kept only for so long as is necessary for the purpose for which such information is used.
If any of your personal data changes, or if you have any questions about how we use data which relates to you, please contact us by email at firstname.lastname@example.org or by writing to Data Compliance Officer, Totally Communications, Unit 801 Highgate Studios, 53 – 79 Highgate Road, Kentish Town, London NW5 1TL. Alternatively, you can call our Data Compliance Officer on 020 7284 9730. We normally update your personal data within seven (7) working days of any new or updated personal data being provided to us, to ensure that the personal data we hold about you is as accurate and up to date as possible.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
As part of our GDPR compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection. The use of non-disclosure agreements form part of our third-party data sharing controls.
We may disclose your personal information to third parties
– in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
– if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
– if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or
– to protect the rights, property or safety of Totally Communications plc, our customers or others.
Totally Communications has risk assessed where personal information may be transferred outside the EEA. As part of our own due diligence we have identified that personal data held for and by Totally Communications resides in the EU. Totally Communications will continue to monitor this for Totally Communications considering any 3rd party provider changes in the future. Should a requirement for data to be transferred outside of the EU in future, Totally Communications will implement controls and safeguards to ensure that equal to or greater data protection measures are enforced and records retained to evidence this.
Information Security of your information
We recognise that information security is an integral part of Data Protection, and as such we ensure that sufficient information security controls are applied, communicated and monitored wherever personal data resides within Totally Communications.
Information Security awareness activities are conducted with all staff to include the deployment of an Information Security Employee Handbook.
As part of our internal supply chain controls, we ensure that any sub-processors, key suppliers or partners are subject to Non-Disclosure/ Contractual confidentiality and Data Protection requirements, and we proactively check and monitor the data protection and information security compliance with these interested parties.