We take your privacy and the protection of your personal data seriously. We will only store, process and disclose your personal data where we have your consent or have a legitimate interest and in accordance with the law. We will make it clear when we collect personal information and will explain what we intend to do with it.
We do our best to protect your privacy through the appropriate use of information security technology.
This policy does not cover links to other websites that we may provide to you (for example on our website or by email). You should satisfy yourself as to such sites’ privacy policies before using their services.
Who We Are
Name: Exceptional Agency Limited
Company No. 11962445
Registered Address: Exceptional Agency Limited, 5 Technology Park, London NW9 6BX
Person Responsible: Sally Vaughan
Contact Email: firstname.lastname@example.org
Data relating to any prospective clients and suppliers will be reviewed regularly and stored for no more than 1 year after the last communication for the work discussed.
Data relating to our clients and suppliers will be stored in line with HMRC guidance and professional requirements for 6 years after the last communication for work delivered.
In this policy, there are phrases that have specific meanings and they are:
Personal data only includes information relating to natural persons who can be identified or who are identifiable directly from the information in question or who can be indirectly identified from that information in combination with other information.
Personal data may also include special categories of personal data or criminal conviction and offences data. These are considered to be more sensitive and we may only process them in more limited circumstances.
We process your personal data every time we do something with it. This may include;
- Emailing you or someone else in connection with you
- Organising or filing Emails or Contracts
- Retrieving information about you or your Business
- Deleting data
Special Category Data
The UK GDPR defines special category data as:
- personal data revealing racial or ethnic origin
- personal data revealing political opinions
- personal data revealing religious or philosophical beliefs
- personal data revealing trade union membership
- genetic data
- biometric data (where used for identification purposes)
- data concerning health
- data concerning a person’s sex life
- data concerning a person’s sexual orientation
This refers to any potential client that may have enquired about services but not yet booked any services.
This refers to those that have bought goods or services from us and we are currently working with or have previously worked with.
This is anyone that has supplied goods or services to our business or even our client’s business and may include those yet to do business with us.
This may include our support team, including our Virtual Business Support and any Consultants we bring into work on projects with us.
Types of Personal Information
We currently collect and process the following information:
- Personal and business contact information – for example, name, business name
- Contact Information – for example, postal and email address, telephone number
- Other personal information you submit to us
- Other information (including from third parties) that we use to make our own information better or more useful – for example, data about organisations, industries, marketing campaigns and other matters relating to your business
If you contact us to make an enquiry or complaint, we will collect information to enable us to respond.
Why We Have Personal Information and How We Collect It
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have Emailed us in connection with our services
- You have contacted us through a website contact form
- You have bought goods or services from us or someone we represent, and we will collect personal information to manage the contract or sale
- We will only take the personal details required to facilitate the goods or services bought from you
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for holding and processing this information are:
(a) Your consent – You are able to remove your consent at any time. You can do this by contacting email@example.com
(b) We have a contractual obligation
(c) We have a legal obligation
(d) We have a vital interest
(e) We need it to perform a public task
(f) We have a legitimate interest (for example, we are representing you as Agent) and, unless you agree otherwise, we will only contact you in relation to that legitimate interest
Your contact data will only be used for marketing emails if you have opted in to receive them. This can be done via email, post or through our website.
We will not share your data with any third parties outside of the Exceptional Agency Team.
Our team will include our Virtual Business Support, who is based in the United Kingdom and will access and process data on our behalf in line with UK Data Protection Laws. We may also use other carefully chosen third parties in the delivery of our services who can also access and process your data. Therefore, when consenting to us using your data, this may also be provided to those other parties who will not be authorised to use this data for their own or any other purposes.
We may also share data if required by law or any official agency.
How We Store Your Information
Your information is securely stored. Our data is stored in two places:
Emails and files are stored within our Microsoft 365 platform across Outlook and SharePoint.
Client personal and contractual information for both prospective and contracted clients, including those no longer under contract in line with our retention policy, are held securely in our CRM, Capsule.
Client information is tagged for the year worked and will be checked and the data permanently deleted at the end of the data retention period.
Your Data Protection Rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances, including if there is no reason for its continued storage and processing.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- Your right to complain – You have the right to complain to the Information Commissioners Office (ICO), details below.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at firstname.lastname@example.org if you wish to make a request.
How to Complain
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk