The aim of this policy is to:
How do we collect and process your data?
We will hold your relevant personal information on our internal systems (which include Sharepoint, Quickbooks and Salesseek) for the purposes of working with you, providing you with information about potential services and developments that may be of interest to you, being an employer or a business partner.
The data that we store will include your name and email address, the nature of your organisation and the services that you may be interested in (from Firefly), the nature of the services you provide (as a prospect, client or supplier / partner), employee data, or – in the case of working with press, bloggers, vloggers and the like – the kinds of topics you cover and how best to work with you. We use this information to operate as a business, look after our employees and provide services and information to you.
Our lawful basis for processing your data is either that we have a contract with you, you have consented that we can process your data, or that we have a legitimate interest in processing your data. We do retain data for varying lengths of time depending upon the purpose for which it was collected, but you have the right to request your data at any time, and in most circumstances, to request that it be erased / forgotten.
In some circumstances we may combine data about our clients and prospects with publicly available data from the web, social media sites or from Firefly’s previous experience, respecting NDAs and confidentiality clauses where relevant. This information will not – due to the nature of how it is collected – be sensitive or confidential. However, it does help Firefly provide a more bespoke service and ensure that it has a legitimate interest in processing additional data. For example, if you have contacted Firefly Communications Group to request a quote for commercial PR services, we may store data about the sector that you operate in, your organisations social media activity and press presence.
In some cases, we do buy personal data from other services. This largely falls into two categories – finding new customers (Pearlfinders) and contacting journalists / influencers (ResponseSource, Gorkana). We understand that all of these sources have obtained consent to be contacted under legitimate interest, but you still have the right to withdraw consent through any relevant communication channel and you may request the data that we hold on you.
We only store one special category of personal data, which is health data for our employees, where it is relevant to their employment with Firefly Communications Group, for example, sick leave. This data is stored on Microsoft Sharepoint, encrypted and only accessible to members of the senior management team. It is never shared with third parties or other employees.
If your personal data has changed, please inform us. We will maintain contact at periodic intervals to ensure that the data we hold on you is up to date and correct. We may use your personal data in an analytical way to improve our customer experience and/or the services that we offer. We use web browser cookies on our websites.
If you wish to withdraw consent for us processing any or all of your data, or unsubscribe from some or all communications (for example, on a company-by-company basis if you are a journalist), please contact us through the communications methods at the top of this document
How long do we retain your data for?
|Category||Subcategories||Duration||Data stored includes||Data location|
|Active client (i.e. we work together)||Indefinitely (for as long as we are working together)||Name, email address, financial details (i.e. invoicing address), past interactions over email, details of the services required from us, information about your products, company approach and communications||Sharepoint / Outlook|
|Inactive client (i.e. we used to work together)||5 years||As above||Sharepoint / Outlook / Salesseek|
|Active employee (i.e. you work for Firefly)||Indefinitely (for as long as you work for Firefly)||All data required by your contract with us||Sharepoint / Outlook|
|Inactive employee (i.e. you used to work for Firefly)||5 years||As above||Sharepoint / Outlook|
|Prospect (i.e. we are interested in working with you)||Three years||Name, email address, brief history of enquiry, publicly available data online about your PR strategy and activity||Salesseek / Sharepoint|
|Website visitor||You comment on our blog||Indefinitely / Session||Name, email address, URL, IP address, image, your comment. Your email address and IP address are deleted as soon as our moderators have approved or rejected your comment.||Our website host is currently hosted with Vidahost in Slough, UK. We use WordPress to manage the website.|
|You visit our website||38 months||Google Analytics data including cookies and usage data||Google Analytics|
|You request resources from us (e.g. pdf guide etc.)||Session||Name and email address – this is deleted as soon as our team have responded to your request||Outlook|
|Supplier / Partner||Indefinitely (as long as we would have a legitimate interest in working with you and you are in this field of business)||Name, email address, phone number, background on your services and our working history together||Sharepoint / Outlook|
|Recipient of newsletter||Indefinitely (as long as you stay subscribed) Deleted thereafter||Name, email address, preferred email format, open rate, click rate||Mailchimp|
|Journalists / Influencers / Analysts||Indefinitely – (as long as you are a relevant technology influencer for our clients) Upon leaving journalism / blogging etc – five years||Name, email, publication, business phone number, past stories (regarding this client and more broadly), current ‘beat’ and area of coverage, preferred content and style for communications||Outlook / Sharepoint (and purchased information accessed via Gorkana, ResponseSource)|
|Applicants to Firefly||Three months after your application is unsuccessful or indefinitely if you consent to hear about positions in future||Name, email address, CV, position applied for, relevant opportunities to be notified of||Outlook / Sharepoint|
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online or through electronic means. Data is stored by third parties only as far as is necessary for processing, and appropriate security mechanisms have been put in place to ensure this continues. These include but are not limited to passwords, encryption and access restrictions, depending on the type and sensitivity of the data.
We always try to handle your data sensitively and sensibly, but if you wish to make a complaint about the way we have handled your data you may do so by contacting us at firstname.lastname@example.org, or the ICO Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF. Tel: 0303 123 1113
What is a cookie?
A cookie is a small text file of letters and numbers which is placed and stored on your browser or the hard drive of your computer/mobile device by websites you visit, if you agree. Cookies contain information which is transferred to your computer’s or mobile device’s hard drive. Cookies are not used to identify you personally.
We use the following cookies:
• Strictly necessary cookies. These are cookies required for the operation of our website. They include, for example, cookies which distribute traffic to servers in order to optimise response times.
• Analytical/performance/preference cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring users find what they are looking for easily. This includes use of third party services, for example, Google Analytics.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We work with third party companies that may also place cookies on our website. We do not sell, pass on or share data with other third parties unless specifically requested by you or where we believe that there is a legitimate interest (for example, in finding a partner / supplier in this or another country, or when we judge that a supplier may have a legitimate and helpful interest in working with another supplier, prospect, partner or client). We will carry out a legitimate interest analysis in each case to ensure that data being shared is necessary, and minimises the possibility of breach, harm or disrespect for your data.
We are a small company and are in the process of updating our website to allow you easy granular control over cookies. In the meantime, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you refuse to accept cookies you may not be able to access and/or use all or parts of our website nor all of the functionality offered by our website. To opt out of being tracked by Google Analytics please see http://tools.google.com/dlpage/gaoptout.
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