Privacy and confidentiality policy

GBP values the privacy of those who provide Personal Data to it and recognises the importance of protecting Confidential Information.  This privacy and confidentiality policy (the “Policy”) describes how and why we collect, store and use Personal Data and Confidential Information, and provides information about individuals’ rights.

This Policy applies to both Personal Data supplied to GBP either by an individual or by others and to Confidential Information supplied by clients or prospective clients. We may use Personal Data and Confidential Information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.

This Policy is an important document. We recommend that you read it carefully and retain a copy for your future reference.

In this Policy, we use the terms:

“Confidential Information” refers to information supplied to GBP by a client or prospective client, which is identified as being confidential at the time of disclosure or would be regarded as confidential by a reasonable person or is protected by a regulatory obligation of confidentiality;

“Personal Data” has the meaning set out in EU Regulation 2016/679 (the “GDPR”). This includes any information about an individual from which that person can be identified;

“we”, “us”, and “our” (and other similar terms) refer to – as the relevant context dictates TO GBP or contracting party (or parties) as referred to in any contract we enter into with you.

“you” and “your” (and other similar terms) refer to – as the relevant context dictates – our clients, individuals associated with our clients, contacts, suppliers, job applicants, staff and visitors to the GBP website, www.gbpltd.com.

Under certain circumstances you have the following rights:

• the right to ask us to provide you, or a third party, with copies of the Personal Data we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
• the right to request erasure, anonymisation or blocking of your Personal Data that is processed in breach of the law;
• the right to object on legitimate grounds to the processing of your Personal Data. In certain circumstances we may not be able to stop using your Personal Data. If that is the case, we’ll let you know and explain why; and
• withdrawal of consent – when Personal Data are processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Data where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact the relevant Data Controller as set out below.

To exercise such rights and if you have any questions about how we collect, store and use Personal Data, then please contact us using the details as set out in the “Data Controller contact information” section below.

We will only process Personal Data where we have a lawful reason for doing so.  The lawful basis for processing Personal Data by us will be one of the following:

• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• the processing is necessary in order for us to comply with our legal or regulatory obligations (such as compliance with anti-money laundering legislation and for conflict checking purposes);
• the processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services);
• processing is necessary for the establishment, exercise or defence of legal claims; or
• the data subject has given consent to the processing of his or her Personal Data for one or more specific purposes*

*This applies to marketing communications in the Netherlands and Germany.

We aim to be transparent about why and how we collect and process Personal Data.  For further information on our processing activities please review the relevant section below:

Collection

GBP process Personal Data about contacts using MS Office applications.  Personal Data that is collected, added to and processed:  name, email address, job title, telephone number, area of business, job role, jurisdiction, language, seniority, other business contact information, and information relating to the strength of your business relationship with our We may cross-reference our marketing records against publicly available information, including LinkedIn and professional profiles published on your organisation’s website, to ensure that the records we hold remain accurate and up to date.

Use

For contact and communication purposes: we may use your contact information to send you updates that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about us and the services provided that we believe may be of interest to you.  You can specify your contact preferences by subsequently advising us of your contact preferences using options provided on all of our marketing emails or the contact details as set out in the “Data Controller contact information” section below.
Performing analytics – such as trends, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress.
Utilising artificial intelligence to research news feeds, sites, posts etc and performing analytics to assist us in contacting you with relevant information.

Retention

Personal Data is retained in MS Office applications such as Excel for as long as it is necessary for the purposes set out above (being the length of the business relationship).  If a business contact requests to be forgotten their contact details will be deleted from our systems.  If a business contact opts out of receiving marketing materials or otherwise objects to any processing carried out for marketing purposes their details will still be retained (as we will need to retain a record of their request not to be contacted) but marketing materials will no longer be sent, and the processing that is subject to the objection will cease.

Collection

We request that our clients only provide Personal Data which is necessary for us to carry out our services.

If we need Personal Data in respect of individuals associated with clients in order to provide our services we ask our clients to provide this Policy to the data subjects.

In the majority of circumstances we will collect Personal Data from our clients or from third parties acting on behalf of our clients.

Use

• Providing GBP residual stock transactions: we will use and disclose Personal Data in such a manner as we believe is reasonably necessary to provide our services, for example we may need to instruct overseas companies on your behalf (including correspondence with you), to liaise with other residual stock professional service providers and logistics companies in relation to matters that we are handling
• Administration: to collect our fees or costs in connection with other legal enforcement, we will use Personal Data to agree payment arrangements, and to collect our fees and costs owing to us in connection with legal enforcement.
• Managing client relationships: providing clients with information on our services and updates that we consider may be relevant to them; arranging and hosting events; and identifying where we may make improvements in service delivery.
• Client engagement: as part of our client onboarding process we carry out certain background searches to verify whether or not there are any potential issues that may mean we cannot work with a particular company or individual (for instance to identify criminal convictions, politically exposed persons, sanctions or other potential reputational issues).
• Compliance with relevant regulations: this may include use of your Personal Data (e.g. evidence of your identity) in order to fulfil our obligations to check the identity of our clients in compliance with anti-money laundering law and regulations.

Retention

Our general retention period for documentation created for the purpose of providing our services is 7 years. In some instances, there are legal and regulatory exceptions which may require documentation to be held for longer or shorter periods. . If you require further information please contact us using the details as set out in the “Data Controller contact information” section below.

Please refer to information made available when applying online for further details as to how Personal Data is collected, processed and how long it is retained for.

Collection

Personal Data, including name, email address, telephone number and other business contact information, may be collected from PR agencies or from databases that we subscribe to.

Use

• Press releases and joint press releases from our clients/organisations that we are working with.
• Invitations to meet GBP staff.
• Press party.
• To highlight any spokespeople who may be of interest on a specific industry theme or topic relevant to the journalist.
• Business trips may require the use of the Personal Data to assist us with travel arrangements.
• Internal communications.

Retention

Personal Data will be retained for as long as it is necessary for the purposes of the above, or if you advise us you no longer wish to be contacted your Personal Data will be removed from our contact lists.

Collection

Personal Data, including name, email address, telephone number and other business contact information, is collected to receive services from suppliers, to manage the relationship with the supplier, and for the provision of services to our clients.

Use

• To receive services from our suppliers: please note that we will use and disclose their Personal Data in such manner as we believe is reasonably necessary to receive and to review the provision of those services from suppliers.
• Services to clients: if a supplier is assisting us in delivering services to our clients we will process Personal Data to manage that relationship.
• Administration: to agree payment arrangements with our suppliers, and to make payments to them.

Retention

A general retention period of 7 years will be applied unless there are any legal and or regulatory exceptions which may require documentation to be held for shorter or longer periods.  If you require further information please contact us using the details as set out in the “Data Controller contact information” section below.

Personal Data in relation to staff will be held on various internal systems and applications. A privacy notice which sets out the purposes for which Personal Data will be processed and contains information on data subject rights is provided to staff at the commencement of employment.

Collection

We do not routinely monitor IP addresses for visitors to our website. Personal Data will be collected if you use our online contact form and/or to receive our marketing literature.

Use

Business contacts: if you have signed up to attend one of our events or to receive our marketing literature please see the paragraph above headed ‘Business contacts’.

On occasion, we may need to share your Personal Datawith third parties. We will only share Personal Data where we are legally permitted to do so.

Where you supply us with Personal Data as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Data in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Data to third parties such as:

• credit-checking agencies for credit control reasons;
• events: we may need to pass on your Personal Data (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose;
• business partners, service providers and other affiliated third parties: to enable us to provide our services to you. Our arrangements with external service providers currently cover the provision of support services including IT (including but not limited to our cloud technology providers) and events management, marketing and business development and facilities management;
• disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Data under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.

We will only share Confidential Information where we are legally permitted to do so.

Where you supply us with Confidential Information, we will assume, unless you instruct us otherwise in writing, that we can disclose your Confidential Information in such manner as we believe is reasonably necessary to provide the services which you have requested from us.

We have in place appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful use, and against accidental loss, damage or destruction.

We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.

The GBP website, www.gbpltd.com, may link to other, unaffiliated third party websites.  Please note that GBP is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites.  You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Data.

This Policy was last updated in August 2022.  Please check back regularly to keep informed of updates to this Policy.

UK

Global Brand Partners Limited
The Old Mill
Blisworth Hill Farm
Stoke Road
Blisworth
NN7 3DB

Email:  Privacy.UK@gbpltd.com

While we hope that you will not need to, if you want to complain about our use of Personal Data please send an email detailing your complaint to Privacy.UK@gbpltd.com

You also have the right to lodge a complaint with the relevant supervisory authority. Please see further details below:

UK

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
Tel: 0303 123 1113
Tel:  029 2067 8400 (calls in Welsh)
Email: casework@ico.org.uk