Privacy Policy

 

1. Background

(1.1) The Center for Communication & Engagement collects and uses certain Personal Data. CCE is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

(1.2) At CCE, we respect your privacy and we are committed to keeping your Personal Data secure.

(1.3) This Privacy Policy is directed to individuals whose Personal Data we handle in the course of carrying on our commercial PR and communication related activities. Those individuals could be journalists or employees, directors, officers or representatives of a media outlet or other organizations with which we have a business relationship. This Privacy Policy is also directed to visitors to our websites.

2. Overview of circumstances in which we handle your personal data

(2.1) This Privacy Policy explains how we handle Personal Data that we collect in the following ways:

(a) Information that you provide to us;

(b) Information we obtain from other sources; and

(c) Information we receive through CCE Websites.

3. The types of personal data we collect

(3.1) We will collect and process the following Personal Data in the course of carrying on our commercial PR and communication related activities: 

  • Information that you provide to CCE. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for, though such information may include the basic Personal Data referred to above.

  • Information that we collect or generate about you. This may include:

    • files that we may produce as a record of our relationship with our media contacts, including contact history; and

    • any other Personal Data that you provide to us via enquiries, when you interact with us through CCE Websites or during telephone and email communications with us.

  • Information we obtain from other sources. This may include:

    • information from publicly available sources, including bylined articles in newspapers, online sites and magazines; updates on LinkedIn, Twitter and other social media platforms; and other publicly accessible sources; and

    • information received from media and PR agencies acting on our behalf.

4. How we use your information

(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes: 

  • for the management and administration of our business;

  • to keep our records up to date and for the administration and maintenance of Communication Databases storing your Personal Data;

  • to keep you informed via telephone, email and press releases of information about CCE that might be of interest;

  • to call or return a call from journalists and other media contacts following an inquiry;

  • to communicate with you and introduce our spokespeople to journalists;

  • to effectively manage and strengthen our relationship with you;

  • to correct inaccuracies in stories written by journalists; or

  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.

(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where: 

  • we have legal and regulatory obligations that we have to discharge;

  • we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;

  • we have obtained your consent;

  • the use of your Personal Data as described is necessary for our legitimate business interests, such as:

    • allowing us to effectively and efficiently manage and administer the operation of our business and its PR and media relations department; or

    • maintaining compliance with internal policies and procedures.

(4.3) Within CCE, your Personal Data is accessed only by employees of CCE that have a need to access it for the purposes described in this Privacy Policy. 

5. Disclosure of your information to third parties

(5.1) We may share your Personal Data within the CCE for the purposes described above.

(5.2) We may also share your Personal Data outside of the CCE as further described below: 

  • with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;

  • with third party agents and contractors for the purposes of them providing services to us (for example, CCE PR agencies). These third parties will be subject to appropriate data protection obligations; and

  • to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights.

6. How we safeguard your personal data

(6.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value. Your personal banking information is kept confidential through a third party cloud based accounting vendor, Quickbooks.

7. How long we keep your personal data

(7.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:

  • the purpose for which we are using it– we will need to keep the data for as long as is necessary for that purpose; and

  • our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

8. Your rights

(8.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;

  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to CCE;

  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;

  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and

  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

(8.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below.  

9. CCE websites and other websites

(9.1) If you use a CCE Website, we may collect technical information through the use of cookies. For example, what websites were visited by each user, any documents downloaded, security incidents, and prevention measures taken by the gateway. For more information on the cookies used by CCE, please see our Cookie Notice 

(9.2) If you use a CCE Website and follow a link from another website, different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website.

10. Changes to this privacy policy

(10.1) Any changes we make to our Privacy Policy in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy. 

11. Questions and concerns

(11.1) If you have any questions or concerns about CCE’s  handling of your Personal Data, or about this Privacy Policy, please contact us.