Lawful basis for processing
Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:
- Consent – the individual has given clear consent for you to process their personal data for a specific purpose.
- Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
- Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations).
- Vital Interests – the processing is necessary to protect someone’s life.
- Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
- Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful basis for processing personal data can be found at ico.org.uk.
Where we get your personal information
If you have received correspondence from us, we will have procured your data in one of the following ways in line with either ‘legal contract’, ‘consent’, or ‘legitimate interest’ basis for processing:
- You have entered into a contract to use our services, attended one of our events, or purchased one of our products
- You have requested information from Integer Research on a previous occasion
- We have previously met at an event and your business card or contact details were handed to us willingly
- Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you
- You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
- You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
- You have previously connected with a member of our team via LinkedIn or other social media or app based services and discussed our services
- Through our own research, through our partnerships and from third parties that provide it to us (e.g., your employer, where appropriate in the context of providing services; credit reference agencies to the extent necessary to detect and prevent fraud; law enforcement authorities to the extent necessary to investigate actual or suspected criminal activity).
Information Integer collects passively:
As you navigate through a Web site, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection. This site may use Internet Protocol (IP) addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, identify companies accessing our systems, and administer and improve the site.
“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the Web site visitors find most valuable, and customizing the Web site based on your preferences. This site uses persistent cookies.
“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Web site server information such as the IP address and browser type related to the visitor’s computer. This site does use Internet tags.
“Navigational data” (“log files,” “server logs,” and “clickstream” data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. This site uses navigational data.
Information Integer processes for Marketing and Sales
As an organisation that processes business related data, Integer Research has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of Integer Research’s marketing and sales.
Integer Research collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in Integer Research products. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical segmentation includes those within marketing, sales, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.
We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIn) as well as business IP address. Other business related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive Personal Data’.
The data collected will be used to communicate marketing and sales messages relating to the Integer Research products, based upon the job function held by the data subject. Integer Research specifically only sends messages to those we believe are likely to be interested in Integer Research products and services based upon the organisation they are employed by and based upon their job function within that organisation. Messages from Integer Research could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.
When you send Integer Research an enquiry, fill in a form requesting information, or register an account on our website you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Integer Research products and services that we feel may be of interest to you, it is deemed that as you have visited the Integer Research website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods listed further below.
Legitimate Interest Assessment (LIA)
Integer Research has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence from Integer Research and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Integer Research in a direct marketing or sales capacity, could be legitimately interested in Integer’s products and services. It is also deemed that direct marketing and sales is necessary in the context of promoting Integer Research to professionals in business in order to increase awareness of our services in the marketplace.
Per the ICO guidance, Integer Research can confirm:
- We have checked that ‘legitimate interests’ is the most appropriate basis
- We understand our responsibility to protect the individual’s interests
- We have conducted a ‘legitimate interests’ assessment (LIA) and kept a record of it, to ensure that we can justify our decision
- We have identified the relevant legitimate interests
- We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
- We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
- We only use individuals’ data in ways they would reasonably expect
- We are not using people’s data in ways they would find intrusive or which could cause them harm
- We do not process the data of children
- We have considered safeguards to reduce the impact where possible
- We will always ensure there is an opt-out / ability to object
- Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
- We keep our LIA under review regularly, and will repeat it if circumstances change
- We include information about our legitimate interests in our privacy notice
Integer Research has an in-house data verification team, who are responsible for ensuring the validity and quality of the data contained within the Integer Research CRM system. The team continually review and cleanse the data held within the CRM system. Any records found to be out of date are placed into a deletion queue which is securely purged regularly.
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