MAN BITES DOG – Privacy Notice
Date of last revision: September 2022
Man Bites Dog takes your privacy seriously and is committed to protecting and respecting it.
We want you to understand how we collect and use information about you.
This privacy notice (“Notice”) contains important information on who we are, on how and why we collect, store, use and share personal data, and on your rights in relation to your personal data.
This Notice and our website, https://www.manbitesdog.com (“Website”), are not intended for use by children and we do not knowingly collect personal data in relation to children.
Moore House, Suite A
First Floor, 13 Black Lion Street
Brighton BN1 1ND
Under data protection law, we are known as a “data controller”. This means we are responsible for the way in which we collect and process your personal data and must meet our legal obligations in relation to it. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.
E-mail: [email protected]
Post: at our registered office (see section 1).
Direct interaction with you. For example, when you:
• request information
• engage us to provide services (and communicate with us during the course of our business relationship)
• attend an event that we hold
• register to receive emails or newsletters from us
• take part in competitions or contact us via social media or other means
• contact us (for example, with a question or to provide feedback)
From third parties. For example:
• from publicly available sources, such as LinkedIn
• when you are copied on, or referred to in, an email
• from referees whom we approach in respect of any job application.
From automated technologies. As you use the Website, we collect Technical Data (see definition in section 6 below) about your equipment, browsing actions and patterns. We collect this by using cookies and other similar technologies, subject to receiving your consent for the setting of non-essential cookies. Much of this is not personal data in the legal sense – but, to the extent that it is, we treat it lawfully as such.
Applying for a role
Note that if you apply for a post with us, and provide your CV, we will receive more detailed personal data (if you provide it), including biographical data about institutions you have attended and other posts that you have held.
We also collect Aggregated Data, which is large-scale statistical data. We use it for matters such as understanding the percentage of Website users that look at a particular page. Aggregated Data is not personal data, as it will not reveal your identity. However, if we combine Aggregated Data with your personal data, so that you can be identified, we will treat the combined data as personal data and use it in accordance with this Notice.
We do not ordinarily collect any “special categories” of personal data about you (this is the legal term describing details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Note: do you have to provide personal data?
In general, no – although in some situations we may be unable to provide a service if you do not. If we need to collect personal data by law, or to perform a contract with you, and you do not provide it, we may be unable to proceed.
Whenever we use your personal data, we need what is known as a “lawful basis”. These are prescribed by law and are limited in number. Please see the glossary below for more about lawful bases. Sometimes we may have more than one lawful basis for the same processing activity.
The key moments at which we use personal data are as follows:
• Providing you with services
• Conducting credit control
• Communicating with you about this Notice
• Asking and enabling you to complete a survey
• Sending marketing emails or SMS
• Responding to your questions or any complaints
• Operating, evaluating and improving our business and the Website
• Protecting against fraud and other criminal activity
• Complying with our legal obligations (for example, to HMRC and to comply with requests not to send electronic marketing)
• Participating in legal action
• Evaluating your job application
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we fairly consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, and are lawfully entitled to do so, we will notify you and explain the new legal basis.
We will make sure we have your consent before sending direct-marketing communications to you via email or SMS on our own behalf.
If we are sending marketing communications on behalf of a client, it is the client’s responsibility to obtain such consent from you in a lawful way that enables us to act as their processor in sending communications on their behalf.
You have the right to withdraw consent to e-marketing at any time. This will not affect the lawfulness of marketing that took place prior to the time when we action your withdrawal of consent.
As explained in our Cookies Policy, we will not set non-essential cookies unless we have your consent.
Automated decision-making: please note that we do not make decisions solely by automated means.
Business partners and suppliers.
Like most businesses, we rely on partners to provide some services, and this may require use of personal data. These include:
• suppliers and subcontractors who perform certain services and who need personal data for this purpose
• e-mail and mail service providers
• technical and support partners, such as the businesses that host our Website and who provide technical support and back-up services
• professional advisers, such as lawyers, accountants, auditors and insurers, who require such information to provide services to us or for other lawful purposes
• merger or acquisition partners, to the extent that sharing your personal data is necessary.
We may be required to share personal data with a law-enforcement agency (or similar regulatory body) in connection with an investigation.
HM Revenue & Customs
We are required by law to maintain certain data for a period of years to enable a proper assessment of taxation and similar matters.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (and whether we can achieve those purposes through other means), and the applicable legal, regulatory, tax, accounting and other requirements.
If, having opted in, you later prefer not to receive any direct electronic marketing communications from us, you can opt out at any time. We will give you the option to opt out each time we send a marketing communication by electronic means.
Opting out will not affect our ability to use your personal data for the other purposes set out in this Notice, and it will not affect the lawfulness of electronic marketing carried out prior to the time when we actioned your opt-out request.
Where we do so, we will sure that transfers:
• are made to countries that have been deemed to provide an adequate level of protection to personal data; or
• are carried out under approved standard contractual clauses that enable the transfer.
We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
We may first need to verify your identity (and, in certain cases, verify that you have authority to make the request on another person’s behalf).
In general, we try to deal with genuine requests within one month. Occasionally it may take longer, in which case we will let you know in advance.
You do not have to pay a fee to exercise these rights. However, if your request is excessive, repetitive or unfounded, we may charge a reasonable fee or refuse to comply with your request.
Should you be unsatisfied, you have a right to raise a concern with the UK’s information regulator, the Information Commissioner’s Office: https://ico.org.uk/.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS:
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected (although we may need to verify the accuracy of the new data you provide to us).
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for legal reasons, which will be notified to you, if applicable, at the time.
Object to processing of your personal data where we are relying on a legitimate interest and where this adversely affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to continue to process your information.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy
• Where our use of the data is unlawful, but you do not want us to erase it
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
END OF PRIVACY NOTICE