PRIVACY POLICY

Introduction

The Terrapin Group is a market leader working in the arena of politics, property and development, with four different branches (Terrapin Communications, Terrapin Political, Terrapin East and Terrapin Creative) working together to help our clients manage their projects – whether that's obtaining planning permission, issuing public consultations or even helping our clients message their projects on social media. For more information about how we operate, see the relevant sections on our website.

This notice provides information about the types of personal information we collect about you, including when you interact with websites associated with the Terrapin Group. This includes www.terrapingroup.co.uk and the websites where we consult on specific client projects (for example, the whatyouthink sites). We refer to each of these as a group website in this notice. This notice also provides information about how we will use your personal information and your rights over your personal information.

The purpose of this notice is to give you information about:

  1. Whose personal information we use
  2. What personal information we collect
  3. Sources of personal information
  4. How we use your personal information (and the lawful bases for our use)
  5. When we will get in touch
  6. Who we share your personal information with
  7. When and where we transfer your personal information internationally
  8. How we keep your personal information safe
  9. How long we keep your personal information
  10. Your rights in respect of your personal information
  11. Who we are and how to get in touch

This notice sets out the basis on which we will process your personal information. Please read this notice carefully so that you understand your rights in relation to your personal information.

This notice may be updated from time to time. We will post any revised notice on our website and will make reasonable efforts to provide you with a revised notice if we make any substantial updates. It is important you read this notice, so that you are aware of how and why we are using your personal information.

For information about who we are and how to get in touch with us, see section 11 at the end of this notice.

1. Whose personal information we use

We collect and use personal information about the following types of people:

  • Individuals who have signed up to receive our "Musings"
  • Individuals who have contacted the Terrapin Group using the contact form, Feedback or contact details on a group website
  • Individuals who have participated in consultations in relation to specific client projects, for example via group websites (including whatyouthink sites)
  • Individuals who attend our speaker events (speakers and attendees)
  • Policymakers, Local and National Politicians and Local and Central government officials
  • Stakeholders in client projects
  • Visitors to our group websites
  • Our suppliers, clients or prospects who we engage with as part of our normal business operations

If you work for the Terrapin Group then we have a different privacy notice that applies to how we use your personal information. Please contact info@terrapingroup.co.ukfor further information.

2. What personal information we collect

When we use the phrase personal information in this notice we mean any information that relates to you or could be used to identify you. At its simplest, this could be your name and your email address. Personal information will also include any information provided by you (for example, in your correspondence with us or in response to a consultation).

The personal information we collect and use includes (but is not restricted to):

  • Name
  • Contact details (email address and, on occasion, residential address)
  • Employer or associated organisation(s) and role
  • Your communication preferences (for example, when you subscribed to our Musings and if you ever cancel your subscription)
  • Your input into consultations, including on whatyouthink sites and other online consultations
  • Technical information about your interaction with the group websites
  • Any other information that you may give us (for example, if you contact us with a query or a comment)

Certain types of personal information are sensitive and need more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, health information, biometric and genetic data. There are also special rules about the use of criminal information (information about criminal convictions or allegations about criminal convictions).

We will not usually collect these types of personal information about you. We will only process these types of personal information about you if we have a valid reason for doing so and only if the law allows us to do so. For example, if you have any dietary or access restrictions and want to attend a speaker event, we will collect this information so that we can make appropriate arrangements.

You are not under any statutory or contractual requirement to provide us with your personal information. But if you don"t do so, there are certain circumstances where we will not be able to work with you, for example – you won"t be able to receive our Musings if you do not provide your email address. We would not necessarily be able to cater for a special dietary requirement at a speaker event if we were not pre-warned that it existed.

3. Sources of personal information

We will collect your personal information predominantly directly from you and your interaction with us, including from our group websites.

We will collect information indirectly, for example from a client in relation to a specific project.

We will collect information from publicly available sources, for example twitter or LinkedIn.

We also collect certain technical information from you when you interact with our website. For example, we may keep track of the amount of time you spend on pages, or the pages you visit. For more information about this, please see our Cookies Notice.

4. How we use your personal information (and the lawful bases for our use)

Purposes of processing

We process personal information for the following purposes:

  • Provide you with information about the Terrapin Group (where you have requested it) and to communicate with you in general
  • Provide you with our services or receive services from you
  • Send you our Musings
  • Manage your communication preferences
  • Run consultations on behalf of our clients
  • Organise, promote and run speaker events
  • Review and improve how we (and our clients) communicate with the public and government
  • Analyse, evaluate and improve the Terrapin Group"s operations (including our overall strategy)
  • Satisfy legal obligations which are binding on us (for example, reporting to Companies House)
  • Establish, defend or enforce legal claims

There may be more than one purpose for which we wish to use your personal information in any particular circumstance. For example, if you sign up to our Musings, but also respond to a consultation, whether at an exhibition or on a group website.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purposes. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Lawful bases

We will only use personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we have asked for your consent to use your personal information for a specific purpose. For example, we will generally ask for your permission before we send you our Musings. You always have the right to withdraw your consent. Just send us an email or contact us using the details set out in section 11.
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, we have a legitimate interest in running consultations for our clients" projects, including collating and analysing the results.
  • where it is necessary to comply with a legal obligation on us (for example, reporting HMRC or Companies House).

5. When we will get in touch

When you give us your contact details you may receive follow up information from us directly, including news about the Terrapin Group, as well as about any specific information about which you"ve enquired. Some of these communications are administrative (for example to confirm details about your query) but others are to promote the Terrapin Group and our activities.

We will only send promotional materials to your personal email address where you"ve requested to receive it (for example, if you sign up to our Musings). We may also send promotional materials via email to your work email address (if you work at a company, partnership or other incorporated body) if we feel that you may be interested in hearing more about the Terrapin Group.

You can opt out of receiving promotional materials at any time. To opt out of emails, click on the unsubscribe link at the bottom of our messages.

If at any time you wish to stop or change how we communicate with you, or update the information we hold, please do get in touch, using the contact details set out in section 11.

6. Who we share your personal information with

We use suppliers to help us operate the Terrapin Group. For example, we use a company that provides us with technical support to keep our systems up and running. We have written agreements with our suppliers that require them to keep your personal information safe, and only use any personal information in line with our instructions.

Where you have responded to consultations, whether at exhibitions or on group websites (such as whatyouthink sites), we will share these responses with our relevant client and their relevant sub-contractors. These responses are usually anonymised before we share, but if there is a particular issue raised or your comments require a response, we will share your contact details.

For our speaker events, we will share your personal information (including dietary and access requirements, as appropriate) with the relevant venue.

If we share your information with any other third party, we will let you know in advance where reasonably possible.

There are other circumstances where we may need to share your personal information, for example:

  • if we transfer the running of the Terrapin Group (or any part of it) to another organisation;
  • with our professional advisors e.g. lawyers, where necessary to protect our or a third party"s interests;
  • if we are under any legal or regulatory obligation to do so; and
  • in connection with any legal proceedings or prospective legal proceedings, or in order to establish, exercise or defend our or a third party"s legal rights.

7. When and where we transfer your personal information internationally

The Terrapin Group servers (which store all our information, including your personal information) are all hosted in the UK and/ or the European Economic Area (EEA). However we do use suppliers that operate around the world. This means that it is possible that personal information we collect from you may be transferred to and stored in a location outside of the UK or the EEA.

Certain countries outside of the UK or the EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred outside the UK or EEA to a country which does not offer a similar level of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient appropriately protects your personal information by, for instance, entering into contracts that have been approved by EU authorities. If you have any questions about data transfers, please do get in touch, using any the contact details in section 11.

8. How we keep your personal information safe

The Terrapin Group takes reasonable technical and organisational measures to safeguard your personal information against loss, theft and unauthorised use, access or modification.

Sometimes we include links to other websites. This notice only covers how the Terrapin Group uses personal information, and does not cover these other websites. We encourage you to read the privacy notices on other websites you visit.

9. How long we keep your personal information

We will keep your personal information only for as long as required in connection with the purposes for which it was collected and/or is used. For example we keep consultation responses for four (4) years following the consultation (as this reflects the time period it can take to get planning permission and building to begin). After this point we may anonymise the consultation responses for future analysis.

We may also retain information for longer periods where we are required to do so in accordance with legal or regulatory requirements, such as tax and accounting.

In specific circumstances we may also retain your personal information for longer so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

If you would like further information about this, please contact us using the details at section 11.

10. Your rights in respect of your personal information

When we use your personal information you have the right to:

  • Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that personal information. If we are satisfied that you have a right to see this personal information, and we are able to confirm your identity, we will, except where an exemption applies, provide you with this personal information.
  • Request that we erase the personal information we hold about you, as far as we are legally required to do so.
  • Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
  • To change your mind and withdraw your consent when we rely on consent as a legal basis.
  • Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for research purposes.
  • Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.

There are other rights which are unlikely to apply to our use of your personal information. For example, the right to ask for the provision of your personal information in a machine-readable format (the data portability right) to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are a party; and in either instance, we are processing it using automated means.

If you have any questions about how we process your personal information, please feel free to get in touch via info@terrapingroup.co.uk.

Please note that you also have the right to lodge a complaint with the relevant data protection supervisory authority. For example, in the UK this is the Information Commissioner"s Office at www.ico.org.uk/concerns.

11. Who we are and how to get in touch

The Terrapin Group Limited is a private company limited by shares with a registered office at Bankton Cottage, Turners Hill Road, Crawley Down, West Sussex, RH10 4EY. Our company number is: 08091094.

Questions, comments and requests regarding this notice are welcomed and should be addressed to info@terrapingroup.co.uk.

Dated 29 July 2020

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