Last updated: 07/12/2022
Headland is committed to protecting and respecting your privacy and handling your information in an open and transparent manner.@
- we collect when you visit (i.e. are a “user” of) our company website (http://www.headlandconsultancy.com) (“our site”) – that is both details you give to us (e.g. via forms) and details that we collect automatically using cookies and similar tracking technology (collectively, “cookies”)
- You give us permission to access from third party sources, e.g. your social media and messaging services such as Facebook, LinkedIn and Instagram (“social media”)
- if you are an influencer, journalist, subject/domain expert, blogger, vlogger, and politician or similar (referred to collectively as “influencers“), we collect and process for the purposes of creating and maintaining our “media lists”.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We recommend that you read this privacy notice in full to ensure you are fully informed.
What is Headland and what does Headland do?
Headland Consultancy Limited (“Headland“, “we“, “us“, “our“), is a communications consultancy, specialising in financial and corporate communications, public affairs and campaigning.
We have our registered office at:
1 Suffolk Lane
A big part of what we do has to do with collecting information – mainly about our clients and their respective businesses, competitors and industries. But we also store relevant information about influencers in media lists, because as a communications consultancy, we have a legitimate interest in and relationship with these influencers. This is to ensure that we as well as our clients can engage with influencers in ways that are relevant, timely and targeted, helping to build and sustain a professional and productive working environment for all parties.
We are a data controller for the purpose of Data Protection Legislation (as defined above).
What information do we collect about you and how?
The personal data we collect and process may include:
- your name;
- your contact details such as your email address and telephone number (or any telephone number used to call us);
- your postings on any other social media applications and services that we provide;
- your IP address, your browser type and language;
- if you are a user: Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
- if you are an influencer: your name and contact details, and information about the organisation (e.g. news outlet) that you work at.
The personal information that we may collect about you can be:
- information you give to us. This you may give by filling in forms on http://www.headlandconsultancy.com (our site), e.g. in the ‘contact us’ section or the sign up to our newsletter. It includes information you provide when you register on the site for us to contact you, and when you report a problem with our site. The information you give us may include your name and email. You may also provide information by corresponding with us via phone, e-mail or otherwise. If you contact us, we will keep a copy of that correspondence.
- social media and other third party information. Depending on your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram you might give us permission to access information from those accounts or services. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. If you are an influencer, we may collect information about you for the purposes of adding you to or updating data about you in our media lists. The third-party sources that we will collect this from might include public sources such as LinkedIn pages, newspapers or other publications that you are published in, your YouTube channels and/or any other public profiles that you maintain for professional purposes. We also subscribe to the Roxhill Media database, that helps us target the right influencers (mainly journalists) and generate effective media coverage.
Why do we collect your information?
Website users & social media information: Our primary purpose in collecting user information from our site is to provide you with a safe, smooth, efficient, and customised experience and to provide the services you have requested. We may also use the information that you have provided to ensure that the content on our website is presented in the most effective manner for you and your computer.
We use your information for the following specific purposes:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to send you our newsletter (with your consent, given by joining our mailing list) and to contact you to let you know about our marketing events;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our site safe and secure.
Influencers & social media information: Our primary purpose in collecting information about Influencers is that as a communications consultancy, we have a legitimate interest in this. We want to be able to, and enable our clients to be able to, engage with influencers in meaningful ways.
The purposes for which we use your information include, but are not limited to:
- press releases;
- invitations to meet our team/ the client team;
- annual/ periodical/ one-off press events, e.g. we capture who may be of interest to contact on a specific industry theme or topic that we deem relevant to the influencer’s remit.
What is our legal basis for processing your personal information?
Our legal basis for collecting and using the personal information described above will depend on the type of information and the specific context in which we collect it.
However, we will process your personal data only…
- where the processing is in our legitimate interests and not overridden by your rights – i.e. running and administering our business;
- where the processing is necessary for the performance of a contract – i.e. to provide you with services you have purchased; and/or
- where the processing is necessary to comply with a legal obligation to which we are subject.
If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
In most cases, we collect and use your personal information on the basis of our legitimate interests (or those of a third party) in connection with:
- the operation of our site (e.g. we collect information about usage and engagement with our site to improve its functionality, personalisation and security);
- the provision of services and communicating with you or our clients as necessary to provide our services;
- responding to any queries that you submit to us;
- undertaking marketing of our services to relevant decision makers through targeted campaigns;
- detecting or preventing illegal activities; and
- (if you are an influencer) our using your information for the purposes of set out above, incl. compiling and maintaining our media lists and providing you with relevant news bulletins and other information which we consider you might find useful, interesting and/or of relevance to your role as an influencer.
We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are. Where we do process your information on the basis of our legitimate interests, we will consider any consequences or impact it may have on you and will not rely on legitimate interests grounds if we think that our interests are outweighed by any negative impact the activities may have on you.
Who do we share your personal information with?
- We may disclose data to provide our services, to respond to legal requirements, enforce our policies, and protect our rights and property.
- The personal information provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our services, respond to your inquiries or for any other related purposes.
- We may also share your personal information with:
- other companies we have instructed to provide services for us;
- other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
- any successor in interest, in the event of a liquidation or administration of Headland.
- If you are an influencer, we will also share information about you contained in our media lists with relevant clients for specific purposes. However, our policy is to only disclose your name and relevant context information, but not the contact details you have shared with us.
- Generally, we will only ever disclose your personal information to any person with our consent to the disclosure.
Links to other sites
Where do we store your personal information?
Data that you submit via our site and that we collect otherwise (e.g. through your public profiles, on social media) is stored on secure servers owned by or operated for us.
Our site and software are all hosted in the UK and all of our operations are based in the EEA.
Data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our website or to assist in our security or fraud protection activities.
Where recipients are outside the EEA, we ensure that the recipient provides an adequate level of protection for your personal data or the transfer is otherwise permitted under applicable Data Protection Legislation, by methods including using standard contractual clauses.
We do not generally rely on your consent as the legal basis for transferring your personal data to outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time through opting out (see data protection rights chapter).
How do we protect your personal information?
We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.
By way of example, our site is hosted on Microsoft Azure’s fully secure data centres, with intrusion protection and intrusion detection in place with 24×7 monitoring.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. But once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long do we keep your personal information?
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, for as long as necessary to provide you with our services, to maintain your profile as an influencer on our media lists, to keep in contact with you about our services or to comply with applicable legal, tax or accounting requirements.
We will only keep the information we collect about you for as long as required for the purposes set out above. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
We may send you direct marketing communications, and retain your contact information necessary for this purpose, (provided that you have consented to receiving them) for as long as you do not unsubscribe from receiving the same from us.
Where you are an influencer, we will retain your personal information until either
- you request us to cease processing such information in accordance with your data protection rights (these are set out in this Privacy Notice below); or
- you cease to be professionally active for a significant period of time.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because it has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
What are your data protection rights?
You have the following data protection rights (subject to certain conditions and exemptions):
- to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources it was obtained from, whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences).
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that it is inaccurate;
- to ask us to delete your personal data, if you consider we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
You can exercise these rights by contacting us using the contact details provided below.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
Opt in and opt out
Where required by Data Protection Legislation, you will be given a choice when you provide us with your personal information to opt into certain uses we may intend to make of that information, such as sending you our newsletter, information or offers containing updated information about us and our services. You will be able to indicate your consent to each specific proposed use, e.g. as a site user by checking the relevant box to opt in. We will not send you direct marketing, or pass your details to third parties for the purpose of them sending you direct marketing, without your consent.
You also have the option to opt out or “unsubscribe” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. Details of how to unsubscribe will be included on each electronic mailing we send you. Alternatively, just send an email to email@example.com with “URGENT – NEWSLETTER UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email. We will action any opt out request from you without delay, and in any event within one month.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your opt out, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.