Summary

This policy was last reviewed and updated on the 24th May 2018. Our Policies are reviewed to ensure compliance with the current compliance environment and we will notify you of any changes.

BPL Business Media Limited (BPL) is a media and events company in the telecommunications and ICT sector with a focus on connectivity and telephony solutions.

BPL is the owner of the following brands: Comms Dealer, Comms Dealer Sales & Marketing Awards, Comms National Awards, Margin in Voice & Data and Comms Vision which will be referenced throughout. Please note that all brands are interchangeable where applicable and are to be treated as representative of BPL.

As a leading company in this events space, we are committed to protecting the client, reader and attendee information we hold.

As part of that, we take data compliance very seriously and are actively working to ensure the compliance and legitimacy of the information we hold and communicate with directly as a business and through our clients and sponsors.

The purpose of this statement is to be transparent about the information BPL holds and to provide information detailing how we collect, process and store data.

This also provides more information on the appropriate contact should you like to request for any data we hold about you to be either amended, withdrawn from processing or to request deleting of any data we hold about you.

Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed below:

  • 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.)

Marketing and Sales Data

As an organisation which processes business related data, BPL has assessed the six legal bases for lawfully processing personal data and have selected ‘Consent’ where individuals or organisations have requested to receive our media, or have chosen to register to attend our events; and ‘Legitimate Interest’ for wider industry data we hold as the most suitable lawful bases of processing the data for the purpose of marketing.

BPL collects, processes and stores information relating to businesses and decision makers. We believe that the individuals’ data we process are likely to be involved, been involved or have a genuine interest in our media or events and the technologies our clients offer.

Deeming these individuals under the basis of ‘Legitimate Interest’ is based upon specific criteria which includes business sector, business size as well around key business representatives and associated job functions within an organisation. Our typical segmentation includes those within sales, marketing, business development, event co-ordinator, MD, owner (or similar) related job functions; while this list covers the majority, it is by no means a comprehensive list and other variables may apply.

We will only ever collect, process and store essential information required to communicate with the data subjects solely within the business environment. The information collected is:

  • Gender
  • Title
  • First name
  • Last Name
  • Business name
  • Job Function
  • Email address
  • Contact number

Other information we request is business related details such as business address and business sector.

As part of our event or media registration, we may collect data considered as ‘Personally Identifiable Data’ or ‘Sensitive Personal Data’ – this is solely for use in any circulation audits where independent verification may be sought at random among our requested magazine circulation to ensure they are a bone fide requested reader.

The data collected will be used to communicate with these contacts as representatives of their organisation to provide them with relevant industry information & news and information regarding events beneficial to their organisation.

Communication is typically general business communication to facilitate and carry out general media and event operations. Communication is primarily operated via email, via telephone or any other business to business (B2B) platforms or mediums that may be relevant.

When you communicate with BPL to request to receive our media, attend our events or use our brands commercially, we will redirect you to the primary stakeholders who will ask you to provide the necessary contact details.

This information is transferred to us at your request to process and inform you by email, telephone or other channels about our media, events and other services and opportunities which we feel might be of interest to you. Interacting with us to discuss these products and opportunities will be deemed as ‘Legitimate Interest’.

You have the right to object from any methods of correspondence at any time, using the unsubscribe button featured on an email, or by informing us or data protection officer and data manager Sheila Thiyagarajah directly.

How we Procure Data

At BPL we procure data in a small manner variety of ways, collected in line with the lawful basis of ‘Legitimate Interest’. If you have received any correspondence from us, we will have procured/had transferred to us data in one of the following ways:

  • You have requested information from BPL on a previous occasion;
  • Someone has sent us your e-mail address requesting information about our events 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;
  • We have previously met at an event and your business card or contact details were handed to us willingly;
  • 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 the social media to discuss our services;

When we contact you, a member of our team has identified your business and your contact details as an appropriate representative of your organisation, believing that your business would genuinely be interested in the attending or sponsoring our events, receiving or advertising in our media, or selected (industry specific) products or services.

If your data has been obtained prior to the implementation and enforcement of the legislation General Data Protection Regulation (GDPR), Regulation 2016/679 (EC) 25 May 2018, by a registered third-party, your information would have been segmented by industry and sector and based upon typical and existing profiles. Due diligence checks will be conducted in accordance with GDPR compliance, typically through a Legitimate Interest Assessment (LIA) form as advised by the ICO.

Legitimate Interest Assessment (LIA)

BPL as advised by the ICO has carried out a Legitimate Interest Assessment (LIA) form. Resulting from the assessment form, we can confirm that the rights and freedoms of the data subjects would not be overridden or bring about any harm to the data subject by our correspondence. Assessing the sector and job functions in combination with our grounds for processing personal data specifically and only with a business environment, we believe any individual who receives correspondence in a direct marketing, sales capacity or through a client who interact within the same sector, could be legitimately interested in BPL Broadcasts exhibitions or services.

The communication is solely for the purpose of promoting our exhibitions/services with a view to generate business for us, and the individual who is being contacted as a representative within a business/organisation.

Legitimate Interest Assessment Checklist

  • We have checked that ‘legitimate interest(s)’ is the most appropriate basis
  • We understand our responsibility to protect the individual’s interests
  • We have conducted a legitimate interest 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 every six months, and will repeat it if circumstances change
  • We include information about our legitimate interests in our privacy notice

BPL has an in-house data manager who is responsible for ensuring the validity and quality of data we hold – this includes regular data cleaning.

Data Storage and Retention

The data held by BPL is processed and stored in-house, within the in a secure environment and is uploaded to our mailing tool Dynamail which is a product of CircData.

CircData is also based in the UK, holds the data in a secure environment and in no-way interacts with the data. They also comply with the GDPR legislations.

Any inaccurate or invalid data is purged from our records during frequent data cleaning.

Request to Object

In all correspondence with you we will give you the right to object from receiving further correspondence from BPL. On any emails you receive from BPL there will be the option to ‘unsubscribe’ from receiving any further email correspondence on a campaign and global level. If you receive a telephone call from us, you have the right to request not to receive any further calls. Your request to object will be logged within our company records to ensure that you do not receive any further calls.

Should you wish to object to receiving communication from BPL Broadcast, you can do so in a variety of ways:

  • Clicking the ‘unsubscribe’ link at the bottom of every email;
  • If you have received a call, please tell the representative that you do not wish to receive any further communication;

Call us on +44 (0)1895 454 411 and ask to speak with a team member or request to speak with the Data Manager Sheila Thiyagarajah. You can also contact the Data Manager directly by calling +44 (0)1895 454 469.

You can also make your request by emailing: sheila@bpl-business.com

Or by writing to:

BPL Business Media Limited Data Compliance,
2nd Floor Market House,
High Street, Uxbridge, Middlesex, UB8 1JN.

All requests will be processed within 14 days. Your details will be added to a suppression file to ensure that your details cannot be processed by the BPL in the future. Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for Deletion

If you request deletion we will aim to remove your record within 14 days.

It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from BPL Broadcast records. If you are removed from our records, this also impacts our suppression files. In this circumstance there is a risk that your data may be processed again in the future if your details are re-added by a team member who genuinely believes that your business would legitimately have an interest in either our exhibitions or services or you decide to re-subscribe to communications.

If you do not wish for us to contact you again, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed and therefore cannot be processed.

Please make your request in writing;

You can email to: sheila@bpl-business.com

Or by writing to:

BPL Business Media Limited Data Compliance,
2nd Floor Market House,
High Street, Uxbridge, Middlesex, UB8 1JN.

Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for Data Held

You may request that we send you all of the data we hold that relates to you. We may ask you a question about your record so as to confirm your identity; a precautionary step which will ensure we are dealing with the individual who has requested their information.

There is no charge for requesting your information.

Please make your request in writing;

You can email to: sheila@bpl-business.com

Or by writing to:

BPL Business Media Limited Data Compliance,
2nd Floor Market House,
High Street, Uxbridge, Middlesex, UB8 1JN.

Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

For questions relating to this policy, please contact the Data Manager Sheila Thiyagarajah - sheila@bpl-business.com