This Privacy Policy sets out how we keep and process data in a lawful manner, protecting and respecting the rights and interests of others.
We have strong beliefs about right and wrong and aim to serve the needs of our customers and stakeholders without detriment to others.
We are fully compliant with telephone preference service regulations and have committed to decline any business which might require us to cold call people at home, irrespective of their registration status.
We use permission-based techniques for outbound telemarketing and email-marketing, whether on our own behalf or that of our clients. This means we only send information to people who we would expect to find it relevant or who have explicitly expressed an interest in receiving it. Recipients of material we send by email can unsubscribe at any time and we will respect their wishes.
We respect your privacy and the confidentiality of any material shared with us which is not in the public domain. We recognise the value and sensitivity of your commercial information and ensure that any such information you supply is treated in strictest confidence and not passed on to others.
Civitas Online collects receives and processes the following types of data, including personal data to pursue our legitimate interests and those of our customers:
The information we collect and use about individuals is always business-related information. This is primarily collected from publicly available sources, including data supplied to us by reputable third parties, or is provided directly to us by our customers or by the individual’s own business. We also collect information from emails sent to us and from visitors to our websites.
We use cookies to identify you when you visit our website to understand your browsing patterns and better serve your interests. You can turn these off in your browser, although this will restrict your use of our website. By continuing to use our site you are agreeing to our use of cookies in this way.
Use Of Your Data – GDPR and Legitimate Interests Assessment
Civitas Online uses data to carry out Business to Business (B2B) direct marketing, for research and sales purposes.
Business-to-business marketing is a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.
We use your data for the following purposes:
We will only process your personal data where either you have given your explicit consent or where it is in our (or a third party’s) legitimate interests to do so, and provided that doing so does not prejudice your interests, rights or freedoms.
As a provider of sales and marketing services, including direct marketing, to organisations involved in selling their products, services and solutions to other businesses (B2B sales), Civitas Online has a legitimate purpose in processing personal data relating to commercial decision-making in UK organisations, both private and public sector.
This processing is necessary to enable cost-effective provision of valuable services by Civitas Online to its clients. In the absence of Civitas Online and similar high-quality service providers, corporate marketers and business development specialists would have to rely on limited and often out-of-date contact data for their needs, missing out on sales opportunities which would have a detrimental effect on the success of their businesses and the wider economy.
Data is processed in a considered and targeted way to ensure that both data collection and dissemination is as relevant as possible.
The data subjects have decision-making and budgetary responsibilities and can reasonably expect to be contacted with marketing material relating to their professional roles, and the data collected is limited to relevant, business-related information as described under the heading “Information Collected”.
To ensure the individual’s interests, rights and freedoms are put first, in addition to a targeted approach to data collection and usage, we respond immediately to changes in relation to the status and wishes of data subjects. So for instance:
What does this all mean in practice?
We have a legitimate interest in processing data as described in this policy.
For instance, it is legitimate for us to contact (and therefore process contact data relating to) those individuals whose roles, based on job title, job descriptions from Linked In profiles or other public sources, suggest that they may be either:
As an employer processing employee or client data we equally have a legitimate interest in processing employee and customer data where necessary to maintain and manage our stakeholder relationships.
We have a further legitimate interest in contacting individuals who may have an interest in buying our services, either to generate sales or for market research purposes.
You can read the Information Commissioner’s guidance on legitimate interests in full on the ICO website
Your information may be used to send you details of those products or services that we (or our customers) offer that we have identified as likely to be of interest to you.
At the completion of any activity undertaken on behalf of our customers, we will pass the contact details to such customers of those whose businesses are interested in the goods and services offered through the activity.
You will always have the right to opt-out of receiving marketing from us and we will always ensure that we screen any databases against the Corporate Telephone Preference Service prior to contacting businesses.
If you would like to opt-out of any marketing communications from us or limit the channels in which we contact you (such as email, phone or post only), please contact us. We will retain a record of your data to ensure you do not receive any future marketing.
If you wish to request access to personal information we hold about you, request correction to it, erasure of it or in any way affect our use of it, please email us.
We will not normally charge you to exercise your rights in this regard but reserve the right to charge a reasonable fee where time spent doing so requires it.
If you have any complaint about how we have processed your data, we ask that you give us the opportunity to put things right by contacting us first. You have the right to complain to the Information Commissioner if you believe that there is a problem with the way your data is being used. Follow this link to contact the ICO.
We will share your data with our customers where we have a legitimate interest in doing so and where you have expressed an interest in their goods and services. We may also share your data with third parties but only where they process your data on our behalf and in accordance with this Privacy Policy, where we are obliged to disclose personal data by law or where we have your consent.
We will only retain your data for as long as is necessary in accordance with the purposes set out in this Policy, and in any event no longer than 3 years from last contact.
To prevent unauthorised access to, or disclosure of your information, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information we collect. We cannot however take responsibility for protecting any information you provide whilst visiting other websites which may be accessible directly from links on our website.
