Our privacy policy

Newington is a communications agency specialising in public and corporate affairs.  We pride ourselves on our ethical approach and we are therefore committed to being open and transparent about how we use data, ensuring it is kept safe, using it only for its intended purpose, and answering any questions that you may have.

This privacy policy sets out how we will meet those commitments and what you can expect from us.  To speak to us about any aspect of this privacy policy, please contact juliaraew@newingtoncomms.co.uk.

What data we collect and why

All personal data is processed by Newington in reference to and in accordance with the Privacy and Electronic Communications Regulations, and the General Data Protection Regulation (GDPR).  We will only use your personal data when the law allows us to either because we have a legitimate interest in processing it or because we have received active consent to do so. 

Most commonly, we will use your personal data where it is necessary for our legitimate interests and your interests and where fundamental rights do not override those interests. 

We define a legitimate interest as the interest of our business in managing our commercial operations and in conducting our enterprise.  It can apply to our staff, our clients and people that we come into contact with during our day-to-day business. 

In determining whether we have a legitimate interest in processing your personal data, we will consider your rights and any potential impact on you (both positive and negative). 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 by law).

We may also use your personal data in instances where we have received active consent to do so for a specific purpose. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Consent can be withdrawn at any time and if you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.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, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

In the course of conducting our business, we process several different types of data, including:

  • Contact information
  • Financial information
  • Opinion information
  • Public voting record information
  • Usage information.

We use this data for the purpose of:

  • Managing stakeholder relationships on our own behalf and on behalf of our clients
  • Invoicing clients and paying suppliers
  • Directing and measuring campaigns on behalf of our clients.

This is important for us in terms of business growth/development, record keeping and demonstrating value to our clients. 

 

How we collect and use personal data

Website cookies and Google Analytics

Newington collects information about you each time you come to any part of our website. We collect information about the time, date, duration and your usage of the website through cookies. 

We use two types of cookie: 

  • Session cookies, which are temporary cookies that remain in the cookie file of your computer until you close your browser (at which point they are deleted).
  • Persistent or stored cookies that remain permanently on the cookie file of your computer.

We use Google Analytics to measure a wide range of site metrics and use this non-personalised information to inform how we can improve our website and our service(s).

None of the data that we gather through our website can be traced to you as an individual and the information cannot be used for marketing on an individual basis unless you actively opt-in.

We occasionally work with third parties to undertake additional analysis of our website.  No personal information about you is shared with these third parties, but they may place a unique cookie on your browser for the purpose of better understanding how our website is used.

 

Wifi

When you use Newington Wi-Fi we may collect data about:

  • Your device
  • The volume of data which you use
  • The websites and applications which you access
  • Your usage by access time, frequency and location. 

Third parties

We work closely with other organisations, such as business partners, sub-contractors, analytics providers, search information providers, and we may receive information about you from them. 

We will only use information received from third parties in accordance with the law and where we believe we have a legitimate interest to do so. 

Where we have a legitimate interest, we may share your information with selected third parties including:

  • Event venues, attendees, speakers, sponsors and organisers
  • Online service providers such as event booking systems, marketing systems and survey tools
  • Newington’s payroll and benefits providers, as well as building management (internal staff only).

We may also share your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others.

Our website and communications may include links to third party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third party websites and are not responsible for their privacy statements.  We encourage you to read the privacy notice of every website you visit.

We will only share your personal data with a third party company to use for marketing purposes where we have received your express opt-in consent.  If you give us your express opt-in consent to share your data with a third party company for marketing purposes, you can still ask the third party to stop sending you marketing messages at any time.

Newington mailing lists

We send regular e-newsletters as well as topical political analysis and event invitations to people when we believe we have a legitimate interest to do so or when we have received active consent to do so.  When determining whether we have a legitimate interest in contacting you, we will consider, in particular, the relevance of the communication’s contents to you or your organisation. 

We use a third-party provider, MailChimp, to deliver our e-newsletters and some of our event invitations. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our communications. For more information, please see MailChimp’s privacy notice.

To remove your contact details from any of our contact data bases, please email Juliaraew@newingtoncomms.co.uk.

On behalf of our clients

We collect data on behalf of our clients where we have active consent from the individual concerned or a legitimate interest to do so.  We use this data for the purpose of good record keeping and to help inform and guide our work so that all communication undertaken by or on behalf of a client is relevant and appropriately targeted.  We actively manage the storage of this information in accordance with our data protection policy so that it is secure and accessible only for lawful purpose.

Here are four examples of services that we provide which help illustrate how we collect and use data on behalf of our clients.

A public exhibition about a proposed housing development: can provide an opportunity for local residents and business owners to learn more about how the plans may affect their community, to speak to the developer, and to provide initial feedback to help inform its design.  Where attendees choose to leave their contact details so that they can be kept updated on the development’s progress, we will hold these details securely for this purpose.  These contact details will be deleted from this database in the event that the individual unsubscribes from receiving updates.

A briefing about a proposed legislative development: can provide an opportunity for politicians, public officials and industry stakeholders to learn more about how the policy may affect a sector of the British economy.  Where we believe there is a legitimate interest in updating specific stakeholders about the legislation’s progress, we will hold contact details securely for this purpose.  These contact details will be deleted from this database in the event that an individual says they do not wish to be contacted again unless there is a legal justification to keep them.

A press release about a company development: can provide an opportunity for journalists to learn more about how it may affect their readers.  Where we believe there is a legitimate interest in updating specific journalists about the consequences of this company development, we will hold these details securely for this purpose.  These contact details will be deleted from this database in the event that the reporter says they do not wish to be contacted again about this topic.

A public-facing digital campaign: can provide an opportunity for the public to be kept informed about the progress of a campaign. Where users sign up to receive updates about a campaign, we will hold their contact details securely for this purpose. These contact details will be retained for the duration of the campaign and will be deleted from the database in the event that an individual unsubscribes from receiving updates.

International transfers

We do not transfer personal data outside the European Economic Area (EEA).

How we protect data

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition we limit access to personal data to those employees, agents, contractors and other third parties who have a business and need to know.  They will only process personal data on instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected data breach and will notify any persons affected and any applicable regulator of a breach where we are legally required to do so.

How long we store data

We only retain personal data for as long as necessary to fulfil the purpose we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirement.  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 personal data, the purpose for which we process the personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

While different retention periods apply for different types of data, the longest we will normally hold any personal data is 6 years.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights are listed below:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please email  juliaraew@newingtoncomms.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What to do if you have a complaint

We are committed to dealing with any queries or concerns about our handling of data as quickly as possible.  You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. To raise a complaint, please email juliaraew@newingtoncomms.co.uk.