Birketts Employment Law App Launch Prize Draw – Privacy Policy
- Important information and who we are
Purpose of this privacy policy
Birketts LLP respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you enter the Birketts Employment Law App Launch Prize Draw (the Prize Draw) and tells you about your privacy rights and how the law protects you.
The Prize Draw has a minimum entry age of 18 and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Birketts LLP is the controller and responsible for your personal data (referred to as “Birketts”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
Full name of legal entity: Birketts LLP
Name of DPO: Sarah Ralph
Email address: [email protected]
Postal address: Providence House, 141-145 Princes Street, Ipswich, Suffolk, United Kingdom, IP1 1QJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. - The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name and title (note that your title may indicate your marital status and gender) together with any other identifying information such as your job title and the name of your employer that may be apparent from your email address or email footer and, should you win the Prize Draw, any photos of you with your prize that you may provide to us or permit us to take and a copy of your ID to verify that you are aged 18 or over; and
Contact Data means your email address and any additional contact information that you may include in your email footer such as your telephone number. If you are the winner of the Prize Draw you will also be asked to provide a postal address for delivery of your prize and to state the county in which you reside.
We may also collect, use and share Aggregated Data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may calculate the percentage of entrants to our Prize Draw who work for clients of Birketts. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes 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.
If you fail to provide personal data
If you fail to provide your name and email address you will be unable to enter our Prize Draw. If we notify you that you have won the Prize Draw but you do not provide us with ID to verify that you are aged 18 or over and a postal address within the specified time we will be unable to deliver your prize and will draw a new winner. - How is your personal data collected?
We only collect data that you provide to us when you enter the Prize Draw. If you are the winner of the Prize Draw, we will ask you to provide to us with a postal address for delivery of your prize, ID so that we can verify you are aged 18 or over and a quote and photo of you with your prize that we can share on social media if you consent to us doing so. - How we use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose / Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To enable you to enter our Prize Draw To select a winner of our Prize Draw To notify the winner of our Prize Draw, verify that the winner is aged 18 or over and arrange delivery of the Prize To meet the CAP Code requirement to verify that the prize draw was successfully carried out and, subject to any objection raised by the winner, to provide the surname and county of the winner to any interested parties upon request To demonstrate our compliance with the CAP code to the Advertising Standards Authority (ASA) | (a) Identity (b) Contact | Legitimate interests (the running of a Prize Draw to promote the launch of our Employment Law App and compliance with the CAP Code) |
| To promote our Employment Law App on our website, via social media channels and in our newsletters | (a) Identity (b) Contact | Consent |
Marketing
We will not use your personal data to send you marketing (unless you have already registered to receive marketing from us in accordance with the Birketts Privacy Policy).
If you are the winner of the Prize Draw we will ask you to provide us with a photo of you with your prize and a quote that we can use to promote our Employment Law App via our website, social media channels and in our newsletters but whether or not you chose to do so is entirely up to you. If you do provide a quote and photo you may change your mind and withdraw your consent to our using this at any time by contacting us.
Change of 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. If you wish to get 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.
5. automated decision making
The winner of our Prize Draw is selected by an automated process. Details of all entrants will be added to a spreadsheet and each entrant will be assigned a correspondence row number. An impartial third party will be provided with the total number of rows and will select a row number at random. The entrant with the corresponding row number will be the winner of the Prize Draw. This is an impartial and automated process that ensures that all entrants have an equal chance of winning and enables us to select a winner without sharing any personal data of entrants with any third party.
6. Disclosures of your personal data
If you are the winner of our Prize Draw and agree that we may use your photo and quote to promote our Employment Law App we will share these on our website, via our social media channels and in our newsletters. To ensure that we comply with the CAP Code, we will also share the winner’s surname and county of residence with third parties requesting this information unless the winner has asked that we do not do so (we will remind the winner that they may opt out of this when notifying them that they won the prize draw). We will share personal data about the winner of the prize draw with the Advertising Standards Authority (ASDA) should the ASA request it to verify that we have run the prize draw in accordance with the CAP Code.
We will not otherwise share personal data of anyone entering our Prize Draw with any third parties.
7. International transfers
We do not transfer your personal data outside the UK.
8. Data security
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will retain details of all individuals who enter our prize draw for up to three months after we have delivered the prize before securely deleting it.
We will delete the ID provided by the winner to verify that they are aged 18 or over immediately.
We will retain the winner’s quote and photo (if provided) for so long as we have their consent to use these in the promotion of our Employment Law App.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes the right to:
- 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.
You can find full details of these rights on the Information Commissioner’s Office website at www.ico.org.uk. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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 you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.