We take data privacy seriously

1.0 General Information

This privacy notice tells you what to expect us to do with your personal information when you make contact with us or use one of our services.

• Why we are able to process your information
• What purpose we are processing it for
• Whether you have to provide it to us
• How long we store it for
• whether there are other recipients of your personal information
• Whether we intend to transfer it to another country
• Whether we do automated decision-making or profiling

The first part of the notice is information we need to tell everybody.

1.1 Controllers contact details

Pro-Active Business Information Ltd is the controller for the personal information we process, unless otherwise stated. There are many ways you can contact us, including by phone, email and post.

1.2 Data Protection Officer contact details

Our Data Protection Officer is John Noble. You can contact him at dpo@pro-activeuk.com or via our postal address (please mark the envelope ‘Data Protection Officer’).

1.3 How do we get information?

We receive personal information in a number of ways, detailed as follows:

• You made an enquiry to us about our products and services either via telephone or our website
• You subscribe to our emails
• You are representing your organisation
• We have sourced your information as part of our marketing activities
• We sometimes source information from 3rd Party data suppliers
• You are a registered user on the dataXchange platform

1.4 Your data protection rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which mean you may not always receive all the information we process.

Your right to rectification.You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure.You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing.You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing.You have the right to object to processing if we are processing your information because the process forms part of our public tasks, or is in our legitimate interests.

Your right to data portability.This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

1.5 Sharing your information

We will not share your information with third parties for marketing purposes.

Third Party Service Providers working on our behalf:We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

Please be reassured that we will not release your information to third parties beyond the Pro-Active Network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

1.6 Your right to complain

We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us at dpo@pro-activeuk.com and we’ll respond.

If you remain dissatisfied, you can make a complaint about the way we process your personal information to the UK supervisory authority at https://ico.org.uk/make-a-complaint.

1.7 Changes to this Privacy Notice

We keep our privacy notice under regular review to make sure it is up to date and accurate.

This current version was approved March 2019

1.8 How you can contact us

Telephone.When you call our main office telephone number, we don’t audio record any calls, but we might make notes to help us answer your query.

Email.We’ll also monitor any emails sent to us, including file attachments, for viruses or malicious software. You must ensure that any email you send is within the bounds of the law.

Social media.If you send a message via social media (ie. LinkedIn) that needs a response from us, we may process it in our CRM as an enquiry or a complaint. When contacting Pro-Active through a social media platform, we suggest you also familiarise yourself with the privacy information of that platform.

1.9 Visitors to our Website

Analytics.When you visit our site, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Website Forms.If we do collect personal data through our website, we’ll be upfront about this. We’ll make it clear when we collect personal information and we’ll explain what we intend to do with it.

Cookies.We use cookies to protect our website forms, such as CSRF tokens. These are not used for marketing purposes but are there to prevent website attacks.

Purpose and legal basis for processing.The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

What are your rights?As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

1.10 Visitors to our Office

We meet visitors at our head office, including:

• Customers
• Job applicants
• Suppliers
• Tradespeople
• Stakeholders

We ask all visitors to sign in and out at reception.

The purpose for processing this information is for security and safety reasons. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Closed-circuit television (CCTV) operates outside the building for security purposes.

2.0 Information about how we use your information

As a Data Controller (when you interact with us directly), this section of the privacy notice provides information about how and why we use your information.

As a Data Processor (where we are processing your information on behalf of a Data Controller), we provide marketing support services to other organisations and we may be processing your data on their behalf