TPL Media Data Protection Compliance Statement
TPL Media’s marketing services, including its lead generation program and list rental database, is bound by The General Data Protection Regulation (GDPR). At TPL Media we conduct all lead generation activities in adherence to the existing The Privacy and Electronic Communications (EC Directive) Regulations 2003, alongside the GDPR and Data Protection Act 2018.
TPL Media conducts Data Privacy Impact Assessments on its business operations, processes and systems to assess how these processes affect or might compromise the privacy of the individuals whose data it holds, collects, or processes; evaluating protections and alternative processes to mitigate potential privacy risks. This is in conformance with the legal, regulatory, and policy requirements for privacy.
TPL Media (‘TPL’ or ‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles.
TPL Media are dedicated to safeguarding the personal information under our control and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the Regulation. Our objectives for GDPR compliance have been summarised in this statement and include data protection roles, policies, procedures, controls and measures to ensure ongoing compliance.
Our Approach to Data Protection
- Information Audits – We audit our information across the business to document the personal data we hold, its source, our processing activities and who we have shared the data with.
- Policies & Procedures – We have Data Protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
- Data Protection –Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – Our retention policy and schedule ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – Our data breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and are disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – Where TPL Media stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable. We ensure a strong audit trail of where we have shared consumer data with partners, to enable us to carry out consumer wishes throughout any data chain where TPL Media data has been supplied.
- Subject Access Request (SAR) – Our SAR procedures meets the 30-day timeframe for providing the requested information. This information is provided free of charge. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – TPL Media are operating under the basis of Legitimate Interest. We generate and source consumer data with the specific purpose of facilitating direct marketing from our partners and clients. We provide a clear description of who we are and the purpose of the call or online survey. We ask for interest to receiving marketing communications from our partners within defined categories. We conclude with an opt-in to channels and clarification of who will contact them based on their responses. In accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 any marketing communication we make through marketing calls, emails and texts are only where we have been given explicit permission to do so.
- Privacy Notice – Our Privacy Notice complies with the GDPR, ensuring that all individuals whose personal information we process are informed of our lawful basis for processing their data, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent – Our telephone survey is scripted to ensure that consent is being freely given, specific, informed and unambiguous. We ensure that individuals understand what they are providing, why and how we use it and we give clear, defined ways to consent to us processing their information. We have stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Email Marketing – We ensure that our email lists have been clearly opted-in for marketing; with a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) –we have developed procedures and assessment templates for carrying out impact assessments that comply with the GDPR’s Article 35 requirements. We have implemented documentation that record each assessment, rates the risk posed by the processing activity and implemented mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – Where we use any third-party to process personal information on our behalf, we issue Data Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, site visits (where necessary) to audit the technical and organisational measures in place and compliance with the GDPR.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website http://www.lifestyleresearch.co.uk/ of an individual’s right to access any personal information that TPL Media processes about them and to request information about: –
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances.
TPL Media does not provide data for any of the following regulated activities:
- Personal injury claims
- Financial services & financial product claims (e.g. mis-selling of PPI, pensions, investments etc)
- Housing disrepair claims
- Specified benefit claims e.g. industrial injuries
- Criminal injury claims
- Employment related claims
Information Security & Technical and Organisational Measures
TPL Media takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures
GDPR Roles and Employees
TPL Media have a designated Compliance Manager. TPL Media is a member of the TPL Media Group Data Privacy Team (representative from each group company) to develop and implement our roadmap for continuous compliance with the data protection Regulation.
The team are responsible for promoting awareness of the GDPR across the Group, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.
TPL Media understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. We refresh our employee training program at least once a year, to instill a culture of good data practice throughout TPL Media, ensuring that all employees understand their role in meeting our obligations. The program forms part of our induction and annual training program.
If you have any questions about our compliance to the GDPR, please contact us at firstname.lastname@example.org
Last updated June 2019