PRIVACY POLICY

Counter Context Limited is committed to protecting the privacy of those that we have contact with. We believe in being open and up front with how we use personal data that is entrusted to us, and we are committed to making Privacy a Priority. If you would like to know more about how we process your personal data, please read our detailed Privacy Policy below.

 

Counter Context makes Privacy a Priority:

We will collect, process, store and share your data safely and securely, by ensuring: 

  • You’re always in control: Your privacy will be respected at all times, and we will put you in control of your privacy with easy-to-use tools and clear choices.

  • We work transparently: We will be transparent about the data we collect and how we use that data so that you can make fully informed choices and decisions.    

  • We operate securely: We will protect the data that you entrust to us via appropriate security measures and controls. We’ll also ensure that other businesses we work with are just as careful with your data.

  • For your benefit: When we do process your data, we will use it to benefit you, to make your experience better and to improve our products and services.

 

1.     WHO WE ARE

“Counter Context Limited” (referred to in this policy as “we”, “us or “our”) is a trading name of:

Counter Context Limited

Floor 4,

1 New Era Square

Sheffield,

S2 4RB

Registered Company Number: 02945735

ICO Registration Number:         ZA030453

We have a Data Protection Team, who can be contacted in the following ways should you have any questions or feedback about the way your data is handled:  

Email:       Jessica.jenkins@countercontext.com

                  

Mail:          Data Protection Team

                  Counter Context Limited

                  Floor 4, 1 New Era Square,

                       Sheffield,

                       S2 4RB

2.     HOW WE COLLECT YOUR PERSONAL DATA

We will collect your personal data in the following ways:

  

·       When you talk with us either over the phone or through email;

·       When you fill out our forms or provide us with feedback;

·       When you contact us via social media;

·       When you subscribe to our newsletters or marketing;

·       When you attend a consultation;

·       From third parties or publicly available sources.

 

3.     PERSONAL DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the table below.

Category of personal data 

Description

Identity data

First name, Surname, DOB, Signature, Gender, Title, Image data, Age, Preferred name.

Contact data

Home telephone number, Mobile phone number, Email address, Postal Addresses.

Message data

Feedback, Questions, Any data that is contained within a message body or a subject from an individual that the recipient was not expecting to be disclosed.

Technical data

IP address, Browser type, The URL which the user originated from, Cookies, Web beacons.

Marketing data

Marketing preferences selected by the individual.

1.     HOW WE USE YOUR PERSONAL DATA

We are only allowed to use your personal data if we have a legal basis to do so, and we are required to inform you of what that legal basis is. We have set out in the table below: the purposes for processing your data, the categories of personal data affected, and the legal ground on which we rely on when we process the personal data.

In some circumstances we can use your personal data if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.

Purposes for processing

Categories of personal data

Legal basis for processing

Legitimate Interests (if applicable)

To conduct statutory and non-statutory consultations.
  • Identity
  • Contact
  • Message
  • Booking

Performance of a Contract

 

Legal Obligation

N/A

To conduct and manage webinar consultations.
  • Identity
  • Contact
  • Message
  • Booking
  • Technical

Performance of a Contract

 

Legitimate Interests

For stakeholders to register to join a webinar consultation so they can discuss and ask questions about a clients project.

To manage incoming general enquiries or complaints.
  • Identity
  • Contact
  • Message

Legitimate Interests

To ensure that enquiries and complaints are managed efficiently.

To talk with you through our social media pages.
  • Identity
  • Message

Legitimate Interests

To be able to respond to members of the public comments on our social media pages.

To conduct stakeholder mapping.
  • Identity
  • Contact
  • Job

Legitimate Interests

To understand stakeholders position in regards to the project.

To administer and manage Counter Context and client websites.
  • Identity
  • Technical

Legitimate Interests

 

Consent

To ensure that the website is secure and is fit for purpose.

To administer articles or newsletters to individuals.
  • Identity
  • Contact
  • Marketing

Consent

N/A

To record stakeholder meetings where necessary.
  • Identity
  •  

Consent

N/A

1.     WHO WE SHARE YOUR PERSONAL DATA WITH

In order to provide you with our services and meet our legal obligations, we only share your personal data with third parties in the following circumstances:

·       To manage and store your personal data;

·       To manage your CV and application process;

·       To conduct in-person and online consultations;

·       To administer Counter Context’s and client websites;

·       To administer feedback forms to stakeholders; 

·       To administer marketing on behalf of Counter Context and our clients.

We’ll never make your personal data available to anyone outside Counter Context for them to use for their own marketing purposes without your prior consent.

 

2.     HOW LONG WE RETAIN YOUR PERSONAL DATA

We will keep your personal data for as long as necessary to allow us to carry out our business functions. This includes satisfying any legal, accounting, or reporting requirements. When we assess how long to retain your personal data, we will consider the following:

·      Any statutory or legal obligations;

·       The purposes for which we originally collected the personal data;

·       The lawful grounds on which we based our processing;

·       The types of personal data we have collected;

·       The amount and categories of your personal data; and

·       Whether the purpose of the processing could reasonably be fulfilled by other means.

For majority of the personal data that is processed regarding stakeholders, this will be processed for a period of 3 years following the conclusion of the engagement.

 At Counter Context, we regularly review the retention of your personal data held within our care to ensure that we are not keeping your personal data for longer than is necessary.

 

3.     HOW WE LOOK AFTER YOUR PERSONAL DATA

 We will protect your personal data that you have provided to us via appropriate security measures and controls. This includes implementing technical and organisational measures to prevent the loss, misuse or alteration of your personal data. Counter Context limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, and they are subject to a duty of confidentiality

 

4.     NOT HAPPY?

If you feel that Counter Context have not upheld your rights, we ask that you contact us by emailing a member of the Data Protection Team.

If you are not satisfied with our response, or believe that we are not processing your personal data in accordance with the law, you have the right to lodge a complaint with the Information Commissioners Office (ICO) by using the details below. We would be grateful for the opportunity to manage your concerns directly before you approach the ICO so please contact us in the first instance.

 

Address:             Information Commissioner's Office
                             Wycliffe House
                             Water Lane
                             Wilmslow
                             Cheshire
                             SK9 5AF

Telephone:        0303 123 1113

 

Website:              https://ico.org.uk/make-a-complaint/