1.0 About this Policy
1.1 Document Control
The document is to be reviewed annually and updated.
1.2 Policy Purpose
The purpose of the Red-Fern Media Privacy Policy and Statement is to ensure that all personnel whom we deal with either as prospective customers, customers, suppliers or employees fully understand the company’s commitment to meet or exceed all the GDPR legislation that is relevant to the company and the services it provides.
If you have any questions about this privacy notice or how we use your personal data, please contact our compliance team:
In Writing:
Data Manager
Red-Fern Media Limited
Unit 9,
Slater Terrace,
Trafalgar St,
Burnley,
BB11 1BU
By Email: [email protected]
1.3 Distribution
All published on website.
2.0 The Policy
2.1 Introduction
The EU General Data Protection Regulations (GDPR) require all companies to treat personal information collected or handled securely and maintain accurate records as to how this information is stored and used. Red-Fern Media recognise that your privacy is important. This document details the information regarding personal data that Red-Fern Media collects, stores and uses.
Red-Fern Media will comply in full with the principals of the GDPR that requires that personal data shall be:
– Processed lawfully, fairly and in a transparent manner in relation to individuals;
– Collected for specified, explicit and legitimate purposes and not further processed
in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
– Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
– Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
– Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
– Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2.2 How we collect personal information
Red-Fern Media collect personal information via the following means:
1. Personal Meetings
2. Telephone Calls
3. Online web and printed Forms
4. Research or referrals.
5. Transferred by a Third Party in relation to services offered (e.g. Mail Fulfilment).
6. Employee details during Induction and employment.
As of the 1st July 2017 we are in the process of re-obtaining positive permission for all personal information held and stored in order to comply with the GDPR.
2.3 The type of personal information we collect and store
The Type of Information Collected and Stored by Red-Fern Media:
– Name
– Work Title
– Email address
– Employer
– Employers address
– Telephone Number
– Bank Account Details restricted to Account Name, Sort Code and Account Number
– Additional Personal Information such as hobbies, interests, family details etc – used to establish rapport.
The Type of Personal Information transferred to Red-Fern Media:
The information that is required by Red-Fern Media is often a subset of a much larger data set that may contain a much wider set of personal information than that required by Red-Fern Media to fulfil their services. This information may include:
– Name
– Work Title
– Home Address
– Family Details
– Income Details
– Email address
– Telephone Number
– Mobile Number
2.4 How we use personal information
Red-Fern Media may use your personal information to:
– Administer and pay our employees
– Contact our customers relating to past present and future sales.
– Collect Payments and send Invoices and Statements.
– Administer and Personalise our websites or emails.
– Send marketing information.
– Supply products and services.
Red-Fern Media employs a “need to know” policy of sharing information between its employees, agents or subcontractors and will only disclose sufficient information to allow our employees, agents or subcontractors to complete their objectives and as such these parties will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the uses described above Red-Fern Media may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
Direct Marketing Communications
We strive to make sure we provide only interesting and relevant marketing communications. And you can opt-out at any time.
If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.
To help make our emails more interesting and relevant, we often receive a confirmation when you open an email from Red-Fern Media Limited if your computer supports such capabilities.
You have a right to opt-out of our direct marketing communications at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication.
2.5 How we insure your personal information is kept secure
Red-Fern Media will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
All employee information will be kept and stored securely on secure servers and accessed by Password Protected Payroll, Accounting and Time Recording software.
All customer and Supplier details will be kept stored securely on secure servers and accessed by Password Protected CMS, and accounting Software.
Client Website Data
All Red-Fern Media client data for hosted websites, is held by our hosting company suppliers secure servers. Whilst the data held within clients websites is owned, retained and is the responsibility of the client, Red-Fern Media can control and have access to this data. Red-Fern Media will never use this data for any other purpose than in the interest of the client owning the data. If a client wishes to know which hosting company holds the data, where the data is stored and who has access to this data, please email [email protected] or call 01282 936000 and our compliance team will give you the details required.
If a client wishes to delete data from their website it is their responsibility as the website owner. If a client wishes to task Red-Fern Media with deleting this data, an hourly charge of £60 will be applied to book this work in and actioned.
This is how we will protect your data
In order to protect the personal data collected from you by Red-Fern Media Limited against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors and other support staff are obligated to observe confidentiality and data privacy.
Any access to your data that is stored at our company only takes place through an encrypted connection. By using the most up-to-date firewall systems, we provide the best possible protection for your data. Our website, as well as our internal Customer Management System (CMS) is encrypted using a SSL/TSL (Secure Sockets Layer/ Transport Layer Security) connection. SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers.
Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.
All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation. You must not use any false identity in email or other network communications and you must not attempt or participate in the unauthorised entry or viewing of another user’s account or into another system.
2.6 What we will do in the event of data being compromised
If at any time we become aware that your data has been compromised, or that a breach of our systems and controls has occurred, which has an impact on the security of your data, we will notify the Information Commissioner’s Office, and you, without undue delay.
2.7 Our lawful basis for processing this data
If the personal information has been collected by Red-Fern Media we will ensure we have your permission to use the data necessary for the fulfilment of services provided or in order to take steps to procuring further orders.
If the personal information is transferred to Red-Fern Media for the purposes of fulfilling a service we will obtain a statement from the transferee that they have the consent of all personnel to which the information refers before entering into a contract.
2.8 Data Retention
All data transferred to us by third parties will be stored in a restricted area of our secure server.
It will be held there until either the data is no longer required or the transferee has requested us to destroy the data. Data transferred to us will be disposed of using an electronic shredder. Data that has not been used will be destroyed by secure means after a period no greater than 12 months.
All data collected on employees will be held for at least 5 years after employment ceases for archiving purposes unless requested to do otherwise
All data collected on customers or potential customers will be held whilst ever that data is considered useful or unless requested to do otherwise. The Data will be reviewed at least annually.
2.9 Your rights
All personnel that Red-Fern Media hold personal information on have the following rights:
– The right to be informed of the data being held.
– The rights of access to the information being held.
– The rights to rectification of any errors in the information being held.
– The rights to have the information destroyed.
– The rights to restrict the use of information.
Subject Access Request
You can request a copy of the data we hold on you at any time and will provide it within 1 month of receiving your request in writing, if not sooner.
You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 Inc. VAT when a request is manifestly unfounded, excessive or repetitive.
We will provide this information in a structured, commonly used and machine-readable forms such as a CSV file or PDF file where possible. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Where possible, we will provide this information via remote access to a secure self-service system, such as our Customer Account area, which would provide you with direct access to your information.
If you would like to submit a Subject Access Request, please contact our compliance team in writing to:
Data Manager
Red-Fern Media Limited
Unit 9,
Slater Terrace,
Trafalgar St,
Burnley,
BB11 1BU
We will respond to your request without delay and at the latest, within 1 month of receipt of your request.
2.10 Updating this statement
Red-Fern Media may update this privacy policy from time to time and will ensure that the latest version is held on our web site www.red-fern.co.uk.
You should check this page occasionally to ensure you are familiar with any changes.
2.11 Contacting Red-Fern Media
If you have any questions about this privacy policy or personal information that Red-Fern Media holds please direct your enquiries as follows:
– By email to [email protected]
– By post to Data Security, Red-Fern Media Limited, Unit 9, Slater Terrace, Trafalgar St, Burnley, BB11 1BU
2.12 Making a complaint
If you have a concern about Red-Fern Media’s information rights practices, you should report it to the ICO by accessing by either e-mailing [email protected] or accessing their web site www.ico.org.uk
2.13 Our Use of Cookies
1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
2. By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third Party Cookies are used on Our Site for to allow our website to use this information to present you with customized Web pages and to also track which pages you may have visited. For more details, please refer to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
3. All Cookies used by and on Our Site are used in accordance with current Cookie Law.
4. Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
5. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
6. The following Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Strictly Necessary |
| __hstc | The main cookie for tracking visitors. It contains: the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session) | |
| hubspotutk | This cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. | |
| __hssc | Cookie for keeping track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp. | Yes |
| __hssrc | Whenever HubSpot changes the session cookie, this cookie is also set. We set it simply to the value “1”, and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session. | Yes |
| __hs_opt_out | This cookie is used by the opt-in privacy policy to remember not to ask the user to accept cookies again. This cookie is set when you give users the choice to opt out of cookies. | Yes |
| __hs_do_not_track | This cookie is set when you give users the choice to opt out of cookies and they choose to do so. It disables tracking and personalisation. | Yes |
| __hs_testcookie | This cookie used to test whether the visitor has support for cookies enabled. | Yes |
| hsPagesViewedThisSession | This cookie used to keep track of page views in a session. |