The privacy policy for information submitted to or held by Dods.

This policy (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us via the websites set out at this link (“Websites”) or which we collect elsewhere as set out in this Privacy Policy, or that we receive from third parties in compliance with relevant UK data protection legislation (including the Data Protection Act 1998 (DPA) and the General Data Protection Regulations (GDPR))”, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you do not accept the terms of this Privacy Policy, you must not use or access (or continue to use or access) the Websites and must unsubscribe from all correspondence you receive from Dods using the unsubscribe link provided in the emails.

The Websites use cookies, please see our Cookie Policy for further information. Unless you expressly state otherwise, you consent to our use of cookies.

 

1.     ABOUT US

 

1.1          You are providing information to, and the Websites are operated by, Dods Parliamentary Communications Limited or other members of the Dods Group of companies ("Dods"). We are registered in England and Wales under company number 01262354 and have our registered office at 11th Floor, The Shard, 32 London Bridge Street, London SE1 9SG. Our VAT number is GB 792 0679 00.

1.2          Dods is committed to safeguarding and respecting your personal information and privacy. We are registered with the Information Commissioner under the DPA with registration number Z8858854.

1.3          Further information as to the relationships between the Dods Group of companies and how we will share your data is set out below in clauses 3 and 4.

 

2.     INFORMATION WE MAY COLLECT FROM YOU OR THIRD PARTIES

 

2.1          Dods collects and processes the following information about you:

2.1.1      if you or your employer registers to use the Websites: personal information, including your name, username, password, employer, job title, work address, and email address);

2.1.2      if you use the Websites (e.g. when you post comments on articles/group discussions, if available): records of all such use, including your name and username;

2.1.3      if you contact us via the Websites (e.g. if you email us or comment on the Websites): a record of that email or comment, as well as your name and email address;

2.1.4      if you complete surveys for research purposes from time to time: all of your answers provided in such surveys and your name, email address, employer and job title;

2.1.5      when you use the Websites: information transmitted by your computer, including your IP address, browser data, traffic and location data and information we receive from cookies or from our use of website analytics services.

2.1.6      if you correspond with us by phone, email or social media: records of all information you provide on such phone call, email or social media contact, including your name, email address, phone number, gender, address, employer and job title;

2.1.7      if you attend at an event we run and provide us with information in person: your name, email address, phone number, employer and job title;

2.1.8      when you sign up to receive any services from us (including our monitoring service): your name, address, email address, phone number, employer and job title.

2.2          Dods may receive information about you from third party sources including business partners, sub-contractors in technical services, advertising networks, marketing list brokers and information available online in the public domain. We use reasonable endeavours to ensure that the third party has obtained the appropriate consent from any data subject for the processing of such information in accordance with the terms of this Privacy Policy. 

2.3          Dods collects names and business email address contact details for individuals at businesses we consider will be interested in our goods and services. Unless you have requested us to stop such contact pursuant to section 11 of the Data Protection Act 1998, we use such contact details to provide information about our goods and services that we consider you will be interested in.

2.4          Please note that certain information (e.g. a postcode on its own) does not constitute personal data under the Data Protection Act 1998, if it is not possible to identify a particular living individual from such information or other information which is in (or is likely to come into) our possession.

 

3.     HOW WE MAY USE YOUR INFORMATION

 

3.1          We (or our agents or sub-contractors) may use information held about you in the following ways:

3.1.1      to process your registration to use the Websites;

3.1.2      to identify you when you visit the Websites including to assist with logging you in;

3.1.3      to provide our service(s) to you as a user of the Websites (including to send any newsletters/email updates), and to notify you about changes to our services/the Websites;

3.1.4      to monitor and improve the Websites and our services;

3.1.5      to contact you for marketing purposes, unless you have withheld your consent for us to do so or if you subsequently notify us by email that you no longer wish to receive such messages;

3.1.6      to broadcast relevant advertising or messages to you when you access the Websites;

3.1.7      to monitor the pages you access to assist in providing a better service to you;

3.1.8      to ensure that content from the Websites is presented in the most effective manner for you and your computer;

3.1.9      to help diagnose problems with our systems and to administer the Websites;

3.1.10    for research and analysis purposes so that we can monitor and improve the services we provide to you;

3.1.11    to respond to any queries or enquiries you have made;

3.1.12    to prevent fraud and defend our legal rights; and

3.1.13    to contact you to ask for your feedback and comments on our services.

3.2          If the processing of information held about you is necessary in order for us to provide services to you under a contract (including if you sign up to receive our monitoring service), then we will use your information for the purposes of providing such services to you and will not seek any further consent from you.

3.3          If you provide personal information to one of the companies referred to in the left hand column of the following table, then you consent to receiving the marketing communications in the middle column of the same row from that company and the companies in the right hand column of the same row:

Dods Group company

Marketing Communications Sent

Group Companies information shared with

Dods Group PLC

·         Email marketing;

·         PPC advertising;

·         Print advertising;

·         Display advertising;

·         Direct marketing (e.g. printed invitations); and

·         Social media.

None

Dods Parliamentary Communications Limited

·         Email marketing;

·         PPC advertising;

·         Print advertising;

·         Display advertising;

·         Direct marketing (e.g. printed invitations); and

·         Social media.

Holyrood Communications Limited

Dods Group PLC

Holyrood Communications Limited

·         Email marketing;

·         Print advertising;

·         Display advertising;

·         Direct marketing (e.g. printed invitations); and

·         Social media.

Dods Parliamentary Communications Limited

Dods Group PLC

 

3.4          We (or our agents or sub-contractors) may use, process and share personal data:

3.4.1      where we have the appropriate consent;

3.4.2      where necessary for:

3.4.2.1         performance of any contract to which the data subject is party (and taking steps at the data subject’s request with a view to entering a contract);

3.4.2.2         compliance with any legal obligation;

3.4.2.3         protection of the vital interests of the data subject;

3.4.2.4         administration of justice or performance of a task carried out in the public interest or in the exercise of our official authority; and/or

3.4.2.5         our legitimate interests; and/or

3.4.3      in respect of sensitive (as defined by the DPA), and/or special categories of (as defined by the GDPR), personal data:

3.4.3.1         where necessary for protection of vital interest (where consent cannot be given or where it is not reasonable to expect consent to be obtained or where consent is unreasonable withheld);

3.4.3.2         where necessary for, or in connection with, legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights; and/or

3.4.3.3         where the data has been made public as result of steps deliberately taken by the data subject.

 

4.     DISCLOSURE OF YOUR INFORMATION

 

4.1          We may disclose your personal information to third parties in the following circumstances:

4.1.1      unless you have withheld your consent for us to do so, or if you subsequently notify us by email that you no longer wish us to do so, if you provide personal information to one of the companies referred to in the left hand column of the table set out at clause 3.3 above, then you consent to your information being shared with the companies in the right hand column of the same row for the purposes of receiving the marketing communications in the middle column of the same row;

4.1.2      to service providers who manage aspects of our operations (for example third parties who provide technical services to the Websites or who assist us in providing services to you under a contract);

4.1.3      if Dods or substantially all of its assets are acquired by a third party, in which case personal data held by us may be transferred;

4.1.4      if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the Websites’ terms of use and/or other agreements between you and us; or

4.1.5      to protect the rights, property or safety of Dods or any other third party.

4.2          We may also pass aggregated information on the use of the Websites to third parties but this will not include information which could be used to identify you.

4.3          If you register to attend an event we organise, we may provide the contact information you provide to sponsors of the event which may contact you from time to time for marketing purposes. A list of event sponsors will be available on each event website.

 

5.     MARKETING COMMUNICATIONS

 

5.1          We may contact relevant business addresses (e.g. firstname.surname@business.co.uk) for marketing purposes without prior agreement, provided we believe the messages will be of interest and relevance to you.

5.2          You have the right at any time to ask us not to use your personal data for marketing purposes (including the disclosure of personal data to third parties for marketing purposes). If you do not wish to receive such communications or wish to object to such transfer to third parties for marketing purposes or to our direct marketing, please contact us at datacontroller@dods.co.uk.

 

6.     IP ADDRESSES AND COOKIES

 

6.1          We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to gather aggregate information. We may also use such aggregate information to help us and/or advertisers reach the kind of audience they want to target. This is statistical data about our users' browsing actions and patterns, and does not identify you/any individual.

6.2          The Websites use cookies to distinguish you from other users of the Websites. This helps us to provide you with a good experience when you browse the Websites and also allows us to improve the Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

 

7.     STORAGE AND SECURITY OF YOUR INFORMATION

 

7.1          Although we will try to protect your personal information, we cannot guarantee the security of your data transmitted to the Websites and any transmission is at your own risk.

7.2          Once we have received your information, we will use, and keep up to date, strict and appropriate measures, procedures and security features (technical or otherwise) to ensure the security of personal information and to try to prevent access by unauthorised persons and any unlawful processing, accidental loss, destruction or damage, including the implementation of an appropriate system security policy.

 

8.     LINKS TO OTHER WEBSITES

 

8.1          The Websites may contain links to other websites owned and operated by third parties. These third party websites will have their own privacy policies that will govern the use of any personal information you submit whilst visiting these. We do not accept any responsibility or liability for these policies or the privacy practices of such third party websites. Please check the policies before submitting any personal information to these websites. Your use of third-party websites is at your own risk.

 

9.     ACCESS TO INFORMATION

 

9.1          We aim to keep any personal information we hold up to date, accurate and error free. Please help us to keep your information accurate and up to date by notifying us of any relevant changes in the personal data we hold about you. You can also ask us to correct any personal data we hold about you.

9.2          You have certain rights to see information we hold about you. Any request (known as subject access requests) for such information may be subject to a fee specified by law (currently £10). Any such request must be made in writing sent to 11th Floor, The Shard, 32 London Bridge Street, London SE1 9SG or datacontroller@dods.co.uk.

 

10.  INTERNATIONAL TRANSFERS OF DATA

 

10.1        The only personal data which we transfer out of the European Economic Area is publicly available personal data, which is sent to the United States, and you hereby consent to such transfer of personal data. We will take all reasonable steps in order to ensure that your personal data is treated securely and in accordance with this Privacy Policy and UK data protection legislation.

 

11.  CHILDREN

 

11.1        We do not and will not knowingly collect information from any unsupervised person under the age of 16. If you are under the age of 16, you must not use the Websites or submit any personal data to us unless you have the consent of, and are supervised by, a parent or guardian.

 

12.  CHANGES TO OUR PRIVACY POLICY

 

12.1        We keep this Privacy Policy under review and may occasionally make changes to it (including if necessary as a result of development of the Websites, changes to technologies, legal or regulatory changes etc). If we change this Privacy Policy we will post the changes on this page so that you will be aware of them. Your continued use of the Websites after any such changes will constitute your acceptance of the updated Privacy Policy. You should regularly check this page to determine if the Privacy Policy has been updated and to review those changes before deciding whether or not to access (or continue to access) the Websites.

 

13.  CONTACT

 

13.1        Questions, comments and requests regarding this Privacy Policy or our practices relating to use of your personal information are very welcome and should be addressed to datacontroller@dods.co.uk.