Personal data means any information about an individual from which that person can be identified. We collect it because it helps us run our business and serve you better.
We also collect, use and share anonymous data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users reading a particular story, advertisement or other element of the website. However, if we combine or connect anonymous data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Unless they are properly the subject of editorial material in our news and magazine titles or you consent for a specific purpose, we do not collect any Sensitive Data about you. If you use S1 Jobs, you may be invited to upload your curriculum vitae for archiving with us and viewing by permitted organisations. You should avoid including Sensitive Data, but you can amend or delete at any time through your account.
We may need personal data to perform a contract for services you order from us (such as advertising) or to meet a legal obligation on us. If you do not provide it, we may have to cancel your order, but we’ll let you know at the time.
Our websites may include links to third-party websites, applications and plug-ins (such as ‘Facebook recommend’). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. These other organisations may use information about your visit to our websites. For more information on how these organisations use information, please read their privacy policies. We do not control these third-party websites and are not responsible for their privacy statements.
We do not as a rule directly offer children under 16 products or services or obtain information about them (except in news gathering). Children may sometimes be invited to take part in prize competitions and promotions, in which case we will require parental or legal guardian consent.
Data protection in news gathering
We gather information for the production of our news and other information services (“editorial information”). The editorial information is intended for publication and may incorporate extensive personal data about individuals, including Sensitive Personal Data. The free press serves a vital function in an open democratic society and the law recognises its importance by exempting the press from most of the data protection provisions where there is a proper journalistic purpose. We respect the rights of privacy of people who find themselves in the news and we seek to comply with the relevant data protection principles where we reasonably can.
News and features are published in print and online by each of our titles, and also distributed by social media such as Facebook and Twitter. They may be passed for publication by other titles or syndicated to third party publishers in any medium in the UK or around the world. Our websites are focused locally in the UK, but of course they can be viewed from anywhere in the world. After first publication, in print or on the home page of our websites, we will keep copies in publicly accessible paper or searchable online archives. These archives are an important historical record. They are intended to be kept indefinitely. We will not delete, annotate or amend the archives unless the law so requires, or there is an inaccuracy or an important update.
We may also record and store unpublished information about individuals and matters of general interest for any length of time with a view to publication in the future, for example background research in developing stories or longer-term information held for the preparation of an obituary. We seek to review this information at least every seven years and discard it if we think it is no longer relevant or accurate.
On our websites and social media pages, we host facilities where people can post comments about news stories and other matters. These posts are uploaded automatically by the poster without our intervention and may contain personal data. It is the poster who is primarily responsible for this material, but we operate user terms and an acceptable use policy which we may enforce against users on receipt of a complaint. A ‘report this post’ link is provided and we will respond to complaints using that link.
3. HOW YOUR PERSONAL DATA IS COLLECTED
Separately from our news gathering activities, we collect data from and about you in order to run our business.
• When you give us information: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. And you will give us personal data when you:
• purchase from us advertising or other products or services;
• use our website;
• register and comment on our news stories
• subscribe to any of our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• take part in an event we have organised.
Cookies: it’s your choice
Using cookies means we can show more of the ads that are relevant to you and fewer that are not. Cookies control the number of times you see them and measure how effective the ad campaign has been. Effective advertising helps us to keep our websites and their news content free for you to use.
You can find out more about behavioural advertising and how to opt out of it selectively at youronlinechoices.com. If you want to opt out of receiving targeted advertising, this does not mean that you will no longer receive advertising when you are using our websites; it just means that the advertising you see will not be customised for you.
• Marketing messages: When we send emails to you (see marketing in section 4 below), they will contain pixels. Our system uses them to collect Technical Data about the opening of the email and your clicking on any links. They also tell us if you go on to purchase products or services promoted in the email so that we can evaluate the success of the promotion. They are not used for targeting ads.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• When you are online, we may gather Technical Data from cookies used by analytics providers such as Google. (You can opt-out of Google Analytics monitoring your behaviour on our web sites by going to: https://tools.google.com/dlpage/gaoptout/);
• If you log in to our websites via Facebook or Google you are granting permission to share your Facebook or Google Contact and Identity Data with us, your networks and any other information you have chosen to share according to your Facebook or Google account settings; if you log in via Twitter, we receive your avatar (the small picture that appears next to your tweets) and Twitter username.
• Financial Data, specifically credit reference information from consumer credit reporting agencies, such as Experian (experian.co.uk/consumer/privacy).
• Identity and Contact Data from data brokers or aggregators, such as 118 (118information.co.uk/privacy/.
• Identity and Contact Data from publicly availability sources such as Companies House and the Electoral Register.
• Identity, Contact and Profile Data from surveys and polls where you have consented to your information being used.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. The law recognises that a business has legitimate interests in using personal data to deliver its services provided it does not interfere unduly with the rights of individuals. We have concluded after careful consideration that our legitimate interests cover most of our collection and use of personal data. Those legitimate interests are as follows:
• to enhance your experience by providing services customised to you personally;
• to sell advertising space (including targeted advertising as described above) in order to fund our free-to-access news services;
• to market services to you; and
• to monitor and improve our services
We also need to gather data and contact you in order to perform any contract for advertising or other products and services we are about to enter into or have entered into with you. This includes registering you as a customer and managing our relationship with you. We may email you occasionally with information or questions about your registration, your subscription or postings or with system updates. Sometimes we may need to use your personal data to fulfil a legal obligation, often for your and our benefit, such as fraud prevention. Generally, we do not rely on your consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you (see below).
You will receive marketing communications from us by email or text if you have requested information from us or purchased products or services from us, or if you provided us with your details when you registered for an account, entered a competition or other promotion and, in each case, you have not opted out of receiving that marketing. You may also receive marketing communications from us by post or telephone. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We will make sure it is clear when you can make these choices, for example, by giving you boxes to tick if you want to receive marketing.
• Third-party marketing
We will not share your personal contact data with any person outside our company for their own marketing purposes unless you have clearly agreed or it is lawful for us to do so. We lawfully share the contact details of local businesses with 118, the information services company, who may use them to for telephone marketing.
• Opting out
You can ask us to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase.
• Change of purpose
We will use only personal information consistently with the purposes for which it was originally collected and we will tell you if we plan to use it for a different purpose. We will make sure we delete personal data securely when usage ends.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share details of our customers with agents or sub-contractors who help us deliver our services. This includes the following third parties:
2AdPro, a provider of design, marketing communications and ad production solutions;
ABC Auditing, performance measurement
Amplify My Sales Ltd, a marketing adviser
IBM, IT support
MediaForce Group, an advertising sales agency
Any external sub-contractors who access your information in the course of providing services on our behalf will be governed by contractual restrictions to make sure that they protect your information.
If you are attending an event organised by us or an event partner, data may be shared for event administration purposes.
We also disclose personal data where required by law to HM Revenue & Customs, regulators and other authorities in the UK. If we acquire another business or sell the whole or part of our business, the new owner may use your data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. INTERNATIONAL TRANSFERS
If we transfer your personal data outside the European Economic Area, we ensure a similar degree of data privacy protection is afforded to it by applying one of the following safeguards where necessary:
• Specific contracts approved by the European Commission which give personal data the same protection it has in Europe (“EU model contracts”).
• We may transfer data to the US if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Although our parent company, Gannett Co, Inc. is based in the US, we do not transfer customer personal data to it. Some of the business data we transfer to 2AdPro at its base in in India may include personal data, and it is the subject of EU model contracts.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law, for tax and other purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers. We will review our marketing contact lists and delete those contacts where there has been no activity for three years. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. In particular, see our editorial policy in section 2 above.
Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not normally have to pay a fee, but we may charge a reasonable sum if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
As a security measure, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS PRIVACY NOTICE