- ABOUT US
- THIS POLICY
- WHAT WE DO?
- YOUR INFORMATION
- SHARING YOUR INFORMATION
- STORING YOUR INFORMATION
- YOUR PRIVACY RIGHTS
- CONTACT US
Summary: This Policy applies to the personal data we process as part of our business. Whilst our group of companies will deal with your data in accordance with this Policy, it doesn’t apply to any other companies or organisations that we work with and you are therefore encouraged to check other privacy policies as they may apply to you. This Policy was last updated on 23 January 2020.
All personal data collected about you will be processed by us in accordance with this Policy and the applicable data protection legislation as is in force from time to time. “Personal data” (or “personal information” as the terms may be used interchangeably in this Policy) means information that identifies you as an individual or is capable of doing so.
Additional privacy information applies to certain services we provide (e.g. Fundamental Monitor). This information is provided in the form of specific Privacy Notices, which you are invited to read when registering or subscribing for these services.
We may need to make changes to this Policy from time to time, where we do so we will highlight these changes here. This Policy was last updated on 23 January 2020.
Summary: Our clients work across the asset management, securities services, investment & corporate banking, reinsurance and private banking sectors within the finance industry and separately within high-profile education institutions promoting undergraduate, postgraduate and professional qualifications. The nature of the products and services we provide to our clients drives the nature of the personal data we process.
We provide our clients with media planning and buying services and media intelligence, this includes undertaking market research, event analysis, campaign data analytics and the procurement and placement of advertising on publisher and other websites and via various media platforms.
We also offer our clients other online proprietary services. In order to provide these, we require limited personal information to grant access and monitor usage in accordance with fair usage policies (e.g. Fundamental Monitor).
We also use personal information in the day to day operation of our business, in order to maintain contact with our clients and potential clients as well as for administration, recruitment and employment purposes.
- It being necessary in order to perform or take steps to perform a contract with you or your employer;
- It being processed with your consent;
- It being processed to comply with our legal obligations or
- It being processed where we have a legitimate interest in doing so. Please see below to find out more about legitimate Interests.
If you have any concerns about any processing, we carry out based on our “legitimate interests”, you have the right to object to that processing. For more information on your rights, please see “Your Rights” section below.
In the event that you work for one of our clients, or suppliers, we may also process your employee business contact details (name, business email, job title, business telephone number) so that we may provide our services, undertake day to day management and administration of our clients’ and suppliers’ accounts with regard to the work undertaken, in each case as is necessary to perform our contractual obligations. We process this in the form of emails, client files, invoicing and account records which are securely hosted in the UK. In addition, we retain the same business contact details so as to maintain our business relationship with you, our clients and suppliers and potential clients and suppliers. This data is securely held in our CRM database in the UK. In each case we have a legitimate interest in processing your personal data for these purposes.
As part of our work for our clients we approach, negotiate and instruct media owners, publishers, creative agencies or other suppliers as part of the planning, negotiation and appointment process. During this process it may be necessary for us to share your business contact data (where you work for one of our clients) with such providers which, depending on the account in question, may be located outside of the EEA.
We are able to deliver relevant advertising on behalf of our clients by using cookies (or similar technology). Cookies are tiny text files that are stored on your browser (where you agree) when you visit our clients’ websites or websites of publishers or media owners relevant to our clients’ activities. The cookies we use do not collect your name or any similar information, but instead comprise a unique identifier called a cookie ID: a string of characters that websites and servers associate with the browser on which the cookie is stored.
By associating the cookie ID with the browsing activity undertaken we are able to build a profile and place that information into a “pool” or “segment” within the data management platforms we use, enabling us to show you (or rather the browser associated with the cookie ID) advertisements of interest. Find out more about profiling below. We can do this in a variety of ways, depending on our clients’ advertising strategy, but may include:
- identifying and advertising on websites with audiences our clients’ wish to reach and dealing directly with publishers to establish a campaign;
- matching that cookie ID to a pool or segment which our client is trying to reach and serving advertising in real time to websites with corresponding advertising space for sale
- identifying a cookie ID that has previously visited a client site to serve relevant advertising based on their earlier activity on the client site.
We use Google DoubleClick and Oracle BlueKai cookies and their data management platforms to deliver targeted advertising on behalf of our clients. Where we assemble cookie IDs as part of one of our solutions we act as a data controller. Where we collect cookie IDs to service a specific client’s instructions we do so as a data processor on behalf of our client, the data controller.
Just to reiterate that as part of this process, we do not obtain your name, contact details or any similar information. However, we are able to make inferences from your browsing activity and help our clients to plan their advertising based on this information. For example, if you browse on one of our clients’ websites, you may see an advert from them on another website. We do not profile or pool or segment any information based on or linked to “special category information” being data identifying racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and or biometric data for the purpose of uniquely identifying an individual and data concerning an individual’s health, sex life or sexual orientation.
Once an individual has participated in our research, we hold their responses (including any comments or opinions on relevant market information), together with additional details where relevant, such as the type of assets under management, business size/number of clients and whether any incentive has been received to participate. All responses are held only with the consent of the respondent, and used in an anonymous, aggregated format. When we recruit participants, we provide the opportunity to decline participation and/or to be contacted for these purposes again. You also have the right to object to our processing of your data for these purposes. We do not ask for any special category (sensitive) personal data (e.g. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and or biometric data for the purpose of uniquely identifying an individual and data concerning an individual’s health, sex life or sexual orientation) to be submitted as part of any response; nonetheless we ask for explicit consent to enable us to retain responses for our market research purposes.
We hold the personal data we use for these purposes securely. We work with third parties, such as Qualtrics LLC, who assist us with contacting respondents and storing the resulting data. Qualtrics is required to hold this data securely in their data center in Canada (a territory recognised as having adequate data protection measures the by the European Commission). We also work with panel providers who distribute our surveys to their panelists based on their data and permissions (which is not shared with us). We ask all panel providers to confirm that the personal data they use for these purposes is compliant with all applicable data protection and privacy legislation. We may pass your contact information on to an incentive provider (as set out in our email to you), but only where you agree to take part in the research in question and only for the purpose of providing the incentive in question.
Where we undertake market research specifically for a client using client data, we act as a data processor and process that data in compliance with the requirements of the client data controller.
- Personal details such as name, address, date and place of birth;
- Work history/job data; previous employers, positions, dates, etc.;
- Compensation; basic salary, benefits, bonuses, etc.;
- Education and work history including professional qualifications and skills;
- Employer feedback / references to include regulated references where necessary;
- Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
- Photographs and images from recorded assessments or from onsite CCTV;
- Results of Pre-employment screening checks (e.g. credit history, criminal records check where permitted under local law);
- Assessment results e.g. Psychometric assessment results, results from gamification and video or telephone assessment.
- Processing your personal data to ensure we are complying with our legal obligations. For example, checking your eligibility to work in the UK before employment starts. We may also collect some sensitive personal data (e.g. disability information) in order to make reasonable adjustments to enable our candidates to apply for jobs and to ensure that we comply with regulatory obligations placed on us with regard to our hiring.
- Processing where we have legitimate interest in doing so, specifically in allowing us to manage and administer the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We may also need to process personal data from job applicants to respond to and defend against legal claims.
- Processing, where applicable, other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, for equal opportunities monitoring purposes.
- Processing, where applicable, information about criminal convictions and offences where relevant to the position in question.
We may share your personal information with:
- our suppliers, as described above, under contract where it is necessary for their provision of services to us and/or to provide our services to you;
- prospective partners or professional advisors in the event of any business reorganization, merger, sale, joint venture or similar, under strict confidentiality obligations;
- third parties where it is (or we reasonably believe, it is) necessary for legal or regulatory purposes, or we are under a duty to disclose your personal information to comply with a legal obligation or process or to enforce or apply our terms and conditions, other agreement or protect the rights or safety of clients, employees, or others. This includes exchanging information with other companies, governmental departments and organisations for fraud protection and credit risk reduction; and
- our clients or media partners (but only in an aggregated non-personally identifiable form) where we provide research, data analytics, or advertising placement.
We only transfer personal data to countries outside the European Economic Area (EEA) where appropriate legal safeguards are in place or where we have consent to do so.
Storing, Securing and Retaining your personal dataWe employ appropriate security measures to protect your personal information from unauthorised access, accidental loss, disclosure and destruction. We require that our suppliers and service providers also use appropriate security measures when processing your personal information on our behalf and that they only do so in ways and for the purposes we’ve agreed; not for their own uses. We reserve the right to check their security measures and processing activities. We may need to transfer your personal information to other companies within the Fundamental Media Group, suppliers or service providers based outside of the UK and outside of the EEA. We will only do this where we need to do this, for example where our servers or service providers are based outside of this area and where appropriate safeguards are in place to protect your data or we have your consent to do so. A transfer outside of the EEA will also occur if you access any of our online applications, such as Fundamental Monitor, from outside of the EEA. Personal Data is shared within the Fundamental Group of companies under the EC Model Clauses. Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- for as long as we provide our services to you and then for as long as someone could bring a claim against us related to those services; and/or
- for as long as we have reasonable business needs to do so, such as providing our services to our clients, maintaining our relationships with our clients and potential clients, for as long as our research projects remain live and their results relevant, and a period thereafter in which we may need to validate the findings and for managing our business operations; and/or
- in line with legal and regulatory requirements or guidance.
The Privacy Manager
Fundamental Media Limited
31-41 Worship Street