WHO IS LIMINAL COMMUNICATIONS LTD?
Liminal Communications Ltd, trading under the name Liminal, (whose registered address is 136 High Holborn, WC1V 6PX) and registered company number 05439193) provides public relations and communications advice and support to companies, predominantly in the financial services industry.
Part of our work involves collecting and storing contact details of journalists for whom our clients’ information is likely to be relevant.
Liminal is a ‘data controller’ in respect of the personal information that it collects and stores from both journalists and clients.
WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We only collect basic personal data about journalists, but also clients and prospective clients, including name, email, phone number as well as in some cases brief biographical details or career history.
We collect this personal information about journalists by a number of means including:
- Downloading information from specialist industry databases
- Identifying bylines in papers, online sites and magazines
- By communicating with journalists when we hear of a move within the industry
- By following journalists updating their status on various platforms including LinkedIn, Twitter and other sites.
We collect the personal information about our clients and prospective clients when we engage with them about using Liminal’s services.
WHAT IS THE PURPOSE OF COLLECTING THE PERSONAL DATA AS WELL AS THE LEGAL BASIS FOR THE PROCESSING?
We collect, store and handle the personal information of journalists, clients and prospective clients for our legitimate interest in communicating with them about information and services that we believe to be relevant to them in a professional context.
Liminal serves the interests of journalists who write about the kinds of companies and sectors we represent. We keep journalists informed of relevant corporate and industry news via telephone, emails and press releases / marketing updates. The relationship between PR companies like Liminal and journalists is established and respected.
In the case of clients, we also collect, store and handle personal information of individuals working at client companies, in order to provide the services requested by the client, and in doing so fulfilling our contractual obligation to them.
We only collect personal data from journalists, clients and prospective clients that we need in order to provide and oversee these services to them. We believe in and carry out a policy of data minimisation. Liminal holds no sensitive data on journalists, clients or prospective clients (eg religious views, health history or criminal records).
WHAT DO WE DO WITH YOUR DATA?
All the personal data that we handle is processed by our staff in the UK and The Netherlands. However for the purposes of IT hosting and maintenance this information is located on servers within the European Union. We do not carry out any automated decision making which is likely to have a legal or similar effect on you. All our staff are aware of our data protection policies.
Journalists’ personal information can only be accessed via a secure and password protected online platform. Access to their personal details are restricted to only those individuals working in account teams where the client is relevant to the journalist in question.
Clients’ and prospective clients’ personal information can only be accessed via a secure and password protected online platform, by those individuals who have a legitimate interest in doing so. Typically this would include carrying out contracted work requested by the client, or some administrative functions such as invoicing.
We take appropriate technical and organisational measures to safeguard the personal information that you provide to us but no transit on over the internet can ever be guaranteed so we cannot guarantee the security of any information that you transfer over the internet to us.
HOW WE SHARE YOUR PERSONAL INFORMATION AND WHO WE SHARE IT WITH
We generally do not disclose personal information of journalists or clients to third parties. The exceptions would be:
- Providing client contact details to journalists in the event that the client has indicated they wish to be contacted directly by the journalist in question.
- Providing journalist contact details to clients in the event that the journalist has indicated they wish to be contacted directly by the client in question.
- Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified afterwards via e-mail and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
HOW LONG DO WE KEEP YOUR DATA?
Liminal constantly checks to see if the journalists on our media lists are still working at an outlet or covering a sector that means they will likely continue to be interested in our client base. If this is no longer the case, we remove that journalist from the relevant databases as appropriate. We will also remove their data if requested by the journalist to do so.
For our clients we hold their data so long as they are in an agreed contract with Liminal, and for a period of three years thereafter in the event that they wish to resume services during this period. If they wish any of their data to be removed, we will remove this from our systems.
WHAT ARE YOUR RIGHTS IN RELATION TO THE PERSONAL INFORMATION THAT WE HOLD?
You have the following rights:
- to ask us to provide you with copies of personal information that we hold about you at any time, subject to a fee specified by law;
- to ask us to update or correct any out of date or incorrect personal information that we hold about you (in accordance with applicable data protection legislation);
- (where we are handling your personal information in order to perform a contract between us) to request that we send you (or another data controller) your personal information in a structured, commonly used and machine-readable format (in accordance with applicable data protection laws); and
- the right to opt-out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
If you want to exercise any of these rights, please write to us (either by post or e-mail) at the address specified below.
If you object to our processing of your personal information for certain purposes or you want us to stop using or to delete your personal information, you can contact us and tell us why. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we’ll let you know and tell you why.
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. Please contact us at julian@Liminal.com.
If you are not satisfied with our response or believe we are not processing your personal information accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk/ or seek a remedy through local courts if you believe your rights have been breached.
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