This privacy notice describes how Kemps Publishing Ltd (“We or Kemps”) collects and processes Personal Information when we provide “Services” to EITHER our publishing “Clients” OR our Advertising “Customers” where:
“Clients” are defined as organisations for whom we publish Magazines and/or Directories.
“Customers” are defined as individuals or business entities which purchase advertisements to be published in any of our Publications.
In providing our Services, we may be required to process low sensitivity Personal Information of individuals who are EITHER members of one of our Clients OR Advertising Customers. We also process Personal Information of individuals who are employees or contractors of Kemps. This Privacy Notice applies to any individual whose Personal Information we process.
1 SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice describes how Kemps collects and processes Personal Information in the course of providing its Services and it applies to all Personal Information we collect or process.
When we process Personal Information, we act as Controllers and Processors of data and we cooperate with our Clients and sub-contractors to ensure that we comply with the data processing regulations in force at any particular time.
2 PERSONAL INFORMATION WE COLLECT
‘Personal Information’ is information that identifies individuals or relates to an identifiable individual.
We collect Low Sensitivity Personal Information in the following ways:
Our Clients may provide Personal membership Information to us.
Customers may provide information directly to us when placing an advertising order with us.
You can address any questions you may have about the use of your Personal Information to us and we will act upon your instructions in accordance with the Data Protection regulations in force at the time. Where a Customer’s instructions relate to information supplied by one of our Clients, we will communicate the instructions to our Client.
The Personal Information we may collect may include:
Name and contact information
Job title and role
3 LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
We must have a legal basis to process Personal Information. In all cases, the legal basis is that we have a legitimate interest in processing Personal Information on one of the following grounds:
to provide our Publishing Services to our Clients.
to process contact details provided by our Advertising Customers.
with regard to Sensitive Personal Information (employees and subcontractors), to comply with our contractual/legal obligations and internal responsibilities.
4 HOW WE MAY USE PERSONAL INFORMATION
To contact members of our Clients with a view to selling advertising space in our publications in order to satisfy our contractual obligations with our Clients.
To provide the Service and fulfil our contractual obligations to Advertising Customers.
To collect Customers’ financial obligations in relation to the provision of the Services to Customers.
To ensure that Customers can promote their products to their maximum potential across a range of products provided by Kemps.
5 DISCLOSURE OF PERSONAL INFORMATION
We may share Personal information with third parties for the following purposes:
to supply our Printers and Fulfilment House with distribution data in order to meet our contractual obligations to our Clients. Our Printers and Fulfilment House will ONLY use the Personal Information provided by Kemps for the purpose of the publication and distribution of our products.
to disclose Personal Information under any applicable law or regulation.
to facilitate the reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or Assets (including in connection with any bankruptcy or similar proceedings).
6 SECURITY AND RETENTION
Kemps maintains appropriate security measures to protect the security of data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of processing.
We will retain Personal Information for as long as is necessary for the provision of Services to our Clients and Advertising Customers. We will then retain Personal Information for a period of at least 6 years in order to meet our legal obligations with regard to the retention of Accounting records.
7 CHOICE AND ACCESS
Kemps and our Clients are each controllers responsible for the Personal Information we collect and process.
If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us by sending us an email at email@example.com or sending your request by post to the address provided in the “Contact & Comments” section below. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
We will use best endeavours to process your request subject to the overriding legitimate interest and legal requirements tests.
8 CHANGES TO OUR PRIVACY NOTICE
You may request a copy of this privacy notice from us using the contact details set out below.
If we make any fundamental changes to this privacy notice, we will notify or provide a revised version to our Clients and Advertising Customers.
9 CONTACT & COMMENTS
If you have any questions or comments regarding this privacy notice, please contact our Privacy Department at Kemps Publishing Ltd, 11 The Swan Courtyard, Charles Edward Road, Yardley, Birmingham, B26 1BU.