Our Privacy Notice

Background: 

Breakthrough Communications & Strategies Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

  1. Information About Us

We are Breakthrough Communications & Strategies Limited, known as “Breakthrough Communications”. We are a limited company registered in England under company number 12138602.

Our registered company and main trading address is:

  • Mocatta House, Trafalgar Place, Brighton, BN1 4DU

Our Data Protection Officer is

  • Darren Briddock
  • Email address: darren@breakthroughcomms.co.uk
  • Postal address: Mocatta House, Trafalgar Place, Brighton, BN1 4DU
  1. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  1. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below.

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11. 

  1. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

We may also collect certain data from you as you use our website by using cookies and similar technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.


Data Collected How We Collect the Data
Identity information such as your name You give us the data directly, or we obtain it from publicly available sources.
Contact information including address, email address, telephone number and the organisation’s social media identifiers, computer IP address, etc You give us the data directly, or it is obtained automatically when signing up to hear from us or by completing a survey, or we obtain it from publicly available sources. 
Council and business information including council name or business name, job title etc You give us the data directly, or we obtain it from publicly available sources.
Your views and opinions on matters relating to your council or organisation’s communications and related needs You would give us the data directly.
Payment information including card details, bank account numbers etc You would give us the data directly.
Data from third parties including national and county council associations Given to us by those associations on the basis of a data sharing agreement

 

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Administering our business. Identity information, contact information, council and business information, payment information Contract
Supplying our products and services to you. Identity information, contact information, council and business information, views and opinions expressed Contract
Managing payments for our products and services. Identity information, contact information, council and business information, payment information Contract
Personalising and tailoring our products and services for you. Identity information, contact information, council and business information, views and opinions expressed Contract or Consent
Communicating with you. Identity information, contact information, council and business information, views and opinions expressed Contract or Consent
Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by clicking unsubscribe in emails or writing to us. Identity information, contact information, council and business information, views and opinions expressed Consent

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, post with information, news, and offers on our products and services.

We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Identity information, contact information, council and business information  Consent or Legitimate interest
Your council’s data or organisation’s data is available in publicly available data sources and we consider that we may be able to provide a service to which you might be interested in.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
 

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): 

Type of Data How Long We Keep It
Identity Information 2 years after collection or your last interaction with us whichever is longer
Contact information including address, email address, telephone number and social media identifiers 2 years after collection or your last interaction with us whichever is longer
Council and business information including council name, job title etc. 2 years after collection or your last interaction with us whichever is longer
Views and opinions expressed by you 2 years after collection or your last interaction with us whichever is longer
Payment information including card details, bank account numbers etc 6 years after collection or your last interaction with us whichever is longer
Data from third parties including national and county council associations As long as we are permitted to keep the data by the relevant data controller

 

  1. How and Where Do You Store or Transfer My Personal Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

and

We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

and

We store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We will store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

and

We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
     
  1. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products and services.

Recipient Activity Carried Out Sector Location
National Association of Local Councils Only with your permission, we may share information of which councils use our services or have attended an event that we co-promote with the association. Public Sector UK
County Local Council Associations (various) Only with your permission, we may share information of which councils use our services or have attended an event that we co-promote with the association. Public Sector UK

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Darren Briddock, Data Protection Officer):

Email address: darren@breakthroughcomms.co.uk

Postal Address: Breakthrough Communications, Mocatta House, Trafalgar Place, Brighton, BN1 4DU.
 

  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. 

This Privacy Notice was last updated on 16th March 2021.