EU General Data Protection Regulation (GDPR)
PSi complies with the EU General Data Protection Regulation (GDPR) as a data controller and processor when it comes into force on 25 May 2018.
At PSi we do not just see data as an ‘asset’. We see it as a window to our audiences, and we want each reader, delegate, subscriber, sponsor or advertiser to have confidence in the way we handle their data. We also see data as an opportunity – we use it to help our customers deliver engaging, relevant content that helps everyone learn and develop – and ultimately do their jobs better.
Our Data Controller Marek ensures that we both comply and excel in data best practice, and he would love to hear from you to discuss anything in this statement. Please drop him a line at email@example.com
PSi is committed to transparency in terms of how we use our audience and partner data. We have privacy policies on each of our websites, and clear T&Cs for event websites and all other commercial contracts. Any data that we collect either helps enhance your experience with our brands or helps fund the provision of great content.
Consent and legitimate interest
Article 6(1)(f) of the GDPR legislation states:
“1.Processing shall be lawful only if and to the extent that at least one of the following applies:
(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
The litmus test for our data interactions are the rights and interests of the individual – these can’t be compromised in any way.
By relying on legitimate interest rather than consent to process personal data, PSi takes on extra responsibility for considering and protecting people’s rights and interests, and we guarantee that we will always take this seriously.
Methodology and Frequency of Research
We make all reasonable attempts at re-verifying and updating each organisation and all related structural and management data every six months. Though due to reorganisations, mergers and restructures this is not possible in every case.
For Elected Representatives and senior staff representing Public and Public Service Bodies, a significant proportion of updating and validation is done via official websites and via direct requests and communication with the bodies represented.
Additionally organisations are called by our PSi research team. Often the bulk of the information held is verified/updated by one, or a small number, of people (typically at switchboard/receptionist level in smaller organisations and within a central department in larger organisations) within the subject organisation to save the time of each department and/or post holder and to help try and ensure a level of efficient accuracy. In each case we identify ourselves as calling from PSi and provide details of the PSi website which includes a prominent link to this document.
Beyond our scheduled six monthly cycle of research, we are alerted to organisational, structural and post holder changes on a regular basis by data users, in particular by our users within Local and Central Government bodies and NHS.
In accordance with the relevant data protection provisions we process all information upon receipt of the data from the information holder and the assumed authority of that individual within the relevant organisation to have the authority to share the data of the individuals within that organisation.
Data Export and License
Any data shared is in compliance with the Information Commissioner's Office Checklist, our Terms and Conditions and this Statement.
In all cases the rights of the individual whose personal data is associated with a post listed on our database is considered and put in the context of both reasonable expectation of those fulfilling senior, important, budget holding and influential roles within Public Bodies/those providing Public Services and those rights and legitimate interests of other Public and Commercial Bodies who wish to discuss aspects and responsibilities of the roles directly or to provide details of relevant documents, events, services and publications that will be beneficial to the Post Holders.
No personal data is ever sold to third parties and where any personal data relating to a post holder is licensed for a set period or purpose for use by an PSi client (user) a consultation with the user is made available to ensure suitability, and in addition, the following conditions relating to direct communication with a post holder must be met;
- The user is Supplier/Body offering or conducting relevant research, services or work
- The means, content and amount of communication is appropriate, relevant and not excessive
- The users contact information is always available and clear to the post holder
- A clear and unambiguous opportunity to stop any further communication is offered
- All data is screened against any necessary official preference services before use
- All data supplied can only be held and used for a prescribed period and purpose
- All data held must be done so securely and not transferred to any third parties without consent
- All requests to remove data is respected and a record held to prevent further use
PSi is a business-to-business media company, and much of the data we collect and hold are business contacts that we send newsletters to under The Privacy and Electronic Communications Regulations 2003 (PECR) rules or using legitimate interests. However, we value our content and we know our audiences do too, which is why we now have preference centres for each brand to allow readers to explicitly opt-in to receive exactly what they want, when they want it. There are no pre-ticked boxes – everything requires an opt-in and we will date and time stamp that opt-in as well, to show when consent was obtained. We have encouraged all of our readers to update their preferences but it’s a work in progress, so if you are receiving emails that you do not feel are useful to you then simply click on the unsubscribe links, or email Marek and he will adjust things for you.
If you are a sole trader or partner, you are technically categorised as a ‘consumer’, so we need explicit consent from you. If you haven’t provided it and have dropped off one of our mailing lists, just sign up again and tick the boxes so we know your preferences.
We have clear T&Cs when you sign up to an event. Whether you’re a paying or free delegate, we always make it clear that your data may be shared with the event sponsors. We also make it easy for you to see details of our sponsors (again, you can email Marek if you don’t think it’s sufficiently clear). In exchange for sharing a bit of information about who you are, you get to experience a PSi events that we hope will help you and your business.
If you are a paid subscriber to one of our titles, we need to hold your data to ensure you get the services that you have paid for. We will only contact you for other reasons if there is a legitimate interest, for example a reader event that is specific to that we think you might want to hear about. We work with third parties when handling and processing this data, and we ensure that they also meet our strict data standards. If your experience is anything other than excellent, please let Marek know.
Advertising and sponsorship
PSi works hard to provide relevant and engaging content across its portfolio of brands, but funding great content often requires the support of advertisers and sponsors. We are committed to ensuring all of our commercial partners operate under the same data standards as we do, and if personal data is shared with them, this will be explicitly stated upfront and you will always have the opportunity to opt out.
Handling unsubscribe or subject access requests
All of our emails – whether to individual or business domains – have simple, highly visible unsubscribe links. We will record and act on any unsubscribe requests. This applies even if we have sent that individual or business address an email with their consent or under PECR rules. All subject access requests will be dealt with under GDPR rules – just drop Marek an email if you would like to know what data of yours we hold.
Managing brand-specific communications under the GDPR
At PSi, we have established successful business brands, which include:
Counter Terror Business - launched in 2010, is a specialist publication distributed to heads of security, intelligence officers, procurement officials and department heads in local and central government. Its target audience includes the Intelligence Services, Police, Home Office, Ministry of Defence, Border Control, Customs, Aviation and Port Authorities.
Government Business – GB deals with the 'business end' of government's requirements. GB's pages contain need-to-know features, news and case studies that explain the commercial issues affecting local and central government.
Education Business - Education Business magazine, published monthly, provides a link between those that supply schools and those that procure products and services on their behalf. Editorial content focuses on the latest advancements in education and features contributions from government ministers, industry associations and respected educators.
Health Business - Health Business is published six times a year. HB's pages contain need-to-know features, news and case studies that explain the administrative and commercial issues affecting healthcare and hospital management.
GREENFLEET® - The provision of a regular information source for transport and fleet managers is essential to increase environmental and product knowledge, and to assist in making informed decisions on the latest vehicles, fuels and technologies that reduce carbon emissions. GreenFleet®, along with its website at greenfleet.net, occupies this role.
PSi creates newsletters under the PSi brands listed above. These provide a round-up of the latest articles from our news websites, providing unrivalled insight into the markets they serve. They also include highlights from our clients, top stories from our business brands, and updates about upcoming events. If you have any queries regarding this statement or would like to discuss its content further, please contact us on: 020 8532 0055.