Version 1.00, 220518. This policy was last updated on May 22 2018.
This policy explains how we collect and process personal data from and about the following groups of individuals:
Our objective is to ensure that you are never surprised by how your personal data has been used by us. You are therefore encouraged to read this policy. There may be other notices that apply to specific services we provide, which you should also read at the relevant time.
As our business and this website develops, we may need to update this policy. If we intend to make any important changes that affect your rights and interests, we will make sure we bring this to your attention and explain what this means for you beforehand.
If you have any questions in relation to this policy or wish to exercise any of Your rights under data protection law, you should contact our Data Protection Officer Jo Garner by email at firstname.lastname@example.org.
South West News Service Limited (trading as SWNS) is a limited company registered in England and Wales (company no 6561578) and registered as a controller with the ICO under number Z1433952.
Personal data means any data that identifies or can be used to identify a person. It does not include data where the identity has been removed (anonymous data).
The types of personal data that we may collect from or about you will depend on which group you fall into and may include:
Individuals working for our customers and suppliers and agents
Individuals who contribute content to us such as news stories and other media
Visitors to our website
We will only use your personal data when the law allows us to. We will generally rely on one of three legal grounds for using your personal data:
Generally, we do not rely on consent as a legal ground for using your personal data, except in relation to sending you marketing by email or text message. You have the right to withdraw your consent to marketing at any time either by contacting us, clicking the unsubscribe link in an email or replying to a text message with the required words notified to you in each text message.
Specifically, we will use your personal data as follows:
Data protection law strives to achieve a balance between individuals’ right to privacy and freedom of expression. Although we are required to preserve the confidentiality and security of personal data provided to or obtained by us, the Data Protection Act 2018 includes important exemptions from a number of data protection obligations, including the obligation to provide individuals with information about how we process their personal data, for the purposes of journalism, artistic and literary purposes.
In order to rely on the exemption, we must show that we processed your personal data (or that of a third party, where relevant) with a view to publication that we reasonably believe to be in the public interest and that complying with various obligations under data protection law would be incompatible with processing personal data for journalistic purposes.
SWNS honours the Independent Press Standard Organisation Editors’ Code of Practice, even though it is not a member of IPSO.
We will share your personal data with appropriate members of staff within our organisation.
We also share your personal data with:
We do not transfer your personal data outside of the European Economic Area.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those within our organisation that have a need to access it. They will only process your personal data on our instructions and they are required to keep your personal data confidential.
Please note that any correspondence with us by email or telephone is not encrypted. If you have any particular concerns regarding the security of your correspondence with us, please let us know.
We will only keep your personal data for as long as necessary in connection with the purposes we collected it for and to comply with any legal, accounting or reporting requirements. To determine how long we keep your personal data for, we consider the amount, nature and sensitivity of the personal data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.
Any email correspondence that we have had with you will be stored on our email servers, archived and then deleted in accordance with our back-up and retention policies.
If we have paid you anything, we will retain details of the transaction for a period of six years from the date of the transaction order for tax purposes.
We will retain personal data relating to email marketing data until you unsubscribe or your email address has become permanently unavailable. Once you have unsubscribed, we will keep a record of your choice indefinitely to ensure that you do not receive any further emails from us.
We may retain any data that does not identify you indefinitely.
We use various cookies across the suite of SWNS websites.
Cookies help our websites serve you a consistent and efficient experience, as well as perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as social media sharing buttons (“third party cookies”).
If you disable cookies, please be aware that some of the features of our service may not function correctly.
Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).
Types of cookie we use
The table below explains the types of cookies we use on our websites and why we use them. These vary across our suite of websites. For more information on specific site cookies, please contact us.
Description of the cookies on SWNS websites
Essential - Essential for website to perform its basic functions. These include those required to allow registered users to authenticate and perform account related functions.
Functionality - Used to store preferences set by users such as account name, language, and location.
Security - Used to help identify and prevent potential security risks (i.e. security and anti-spam software or plugins).
Analytics - Tools such as Google Analytics collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use this detail to understand how users interact with our sites.
Third Party / Embedded Content - We use a number of third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
Subject to the exemptions noted above, you have a number of rights in relation to the personal data we hold about you:
Access: You have the right to request access to and be provided with a copy of the personal data held about you together with certain information about the processing of such personal data to check that are holding it lawfully
You will not have to pay any fee to exercise any of the above rights though we may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, we will let you know.
To protect the confidentiality of your personal data we will ask you to verify your identity before fulfilling any request in relation to your personal data.