Prime Prospects is registered with the UK’s Information Commissioners Office, our registration number is: ZA035141
Prime Prospects is part of CMR Group.com Ltd.
Prime Prospects are committed to keeping all personal data safe and secure and processing it solely for lawful purposes and in accordance with the policies set out below.
2. Our Business
We are a marketing company providing support services to all types of organisations in the public and private sectors. Full details of those services are provided on the website www.primeprospects.net and they summarise into 3 primary categories:
- The provision of contact details of selected businesses or individuals for direct marketing purposes
- Market Research, occasionally supported by a prize draw.
- A range of other services, none of which identify individual businesses or persons.
This document deals exclusively with our privacy policies. To ensure that our products are used in a manner that is fully compliant with the law please see our terms and conditions.
3. What data do we collect and where from?
3.1 Direct Marketing: Prime Prospects does not collect any data for use in our direct marketing services. All data we supply for direct marketing is provided by our partner businesses, each of whom supply us with contact information that has been obtained in compliance with the GDPR directive in Europe, or under other relevant data privacy legislation, as appropriate for the country of residence of the data subject (see further below – Third Party Data).
3.2 Other Marketing: We do, however, collect data for our own marketing and business purposes. To that end we maintain a database containing all or part of the following details for each data subject:
- Full name
- Job Title
- Company Name
- Postal address
- Landline number
- Mobile number
- Email address
- Selected direct marketing preferences
- Details of the usage of any of our products or services, as appropriate
Data subjects are added to this data base through a range of sources as follows:
- as a result of completing one of our registration forms – e.g. see primeprospects.net/start-up-form/
- otherwise enquiring about, or purchasing, a Prime Prospect product or service
- from a business card (or other contact) at a business show or networking event
Whatever the original source of the information was, all our marketing communications offer the recipient the option to be removed from our marketing database and thus not to receive any further communications. This can be achieved by contacting us directly or by registering to opt-out by notifying us through completing the following form www.primeprospects.net/contact/like-hear-us/
We collect do not collect any data of a personal nature, other than when conducting a market research study as outlined below. We do, however, retain a record of emails and all other communications received or sent, in particular full financial records of any transactions conducted with our clients are retained for a minimum of 7 years.
3.3 Market Research: From time to time we may collect information from bona fide research panels, or through an email campaign. Data subjects are invited to participate and are completely free to choose to respond to our surveys or polls. We will normally collect information such as the respondent’s name, contact details and the survey responses as appropriate to that case. Such information is always collected under the code of conduct of the Market Research Society and the results published in aggregate, without revealing any information that can be identified to any individual participant. On occasion the incentive to participate may be a prize draw, in which case the winner may be identified on the Prime Prospect website with their permission.
We also collect anonymised publicly available information from social networking sites such as Facebook and Twitter, for example likes, shares, tweets and posts about Prime Prospects. This information is provided to us by a third party and is fully anonymised so we cannot see who has posted the information. This information is used for internal analysis purposes.
4. Third Party Data
4.1 Partners for Direct Marketing: Prime Prospects resells personal data provided by reputable data providers, each of whom have been vetted by Prime Prospects for compliance with GDPR or other relevant privacy regulation. The data we obtain from these providers has been collected through publicly available records such as the electoral roll, or from surveys or other brands and companies that have obtained consent from the data subject for their data to be used for marketing purposes. This may include such information as:
- Basic demographic information (for example age and gender)
- Location and contact details
- Household status (for example, whether the home is owned or rented)
- Household makeup and composition (for example the number of people in the household, presence and age of children)
- Financial status and information about life stage (for example employment, marital status)
- Media habits (for example, which newspapers read or TV channels preferred)
- Purchasing behaviour and personal interests (for example hobbies or travel)
- Credit information
- Car ownership and usage
4.2 Client Data: On occasion a Prime Prospect client may provide us with a file of their customers together with associated product or service usage history. This would solely be for analytical purposes and we would only retain the file in complete confidence and for the exclusive purpose as contracted with the client. Most frequently the file would be anonymised, but it will include contact information where the purpose is profiling, as outlined in 5.3 below.
5. How do we use data?
5.1 Email marketing: We use email addresses to send various marketing communications to keep clients and potential clients informed of our services (including our newsletter, information about new products, surveys or other important information). We also offer an email marketing services to our clients provided the proposed use is compliant with the legislation.
Data subjects can opt out of receiving marketing emails at any time by following the instructions to unsubscribe in any of our email marketing communications.
5.2 Other Marketing: We will also use postal and telephone contacting, both for our own marketing purposes and on behalf of our clients, provided the data subjects have provided appropriate consent.
5.3 Profiling: We offer our clients ‘customer profiling’ to help them understand more about the persons or businesses who purchase their products or services. This is for our client to be able to identify persons with similar characteristics to their customers and then to go on to promote their business to them, either through targeted advertising or direct marketing. This service is offered in conjunction with the third party data providers as discussed in 4.1. Profiling works by sharing some or all of the contact information from our clients’ customer file with the personal data held by the third party data providers; combining the data when there is a match on the contact data across the two files. The file of matched records is then analysed to understand the characteristics of customers accordingly and the results presented to the client in aggregated form only.
6. What is our legal basis for processing data?
Although some of the data is processed as a result of informed consent, primarily we process data on the basis that it is in our legitimate interests, or the legitimate interests of our clients. This will normally be for the purpose of providing information on products and services of relevance to the data subject or with the objective to improve the products or services offered.
Data subjects have the right to object to us processing their data for the purposes set out above and, unless we have a compelling lawful reason to continue processing, we will stop any further activity immediately.
7. Who do we share personal data with?
Unless we are provided with specific further consent we do not share the information we collect with any other organisation, with the exception of our clients’ accounts information, which is shared with our external accountants.
Thus, the only personnel with access to our information are our staff and our IT service provider, who helps us to manage our IT systems and ensure that they are secure.
The exception to this is only where we are required to do so by law or to protect or enforce our rights or the rights of any third party.
8. The rights of Data Subjects:
Prime Prospects are committed to upholding the following rights of data subjects. However, in some circumstances we may request proof of identity before complying with specific requirements. In any event we will need to collect the name, address, email address, phone number and any relevant information in order that we may respond to any request. Where necessary we use such information solely for the purpose of responding to the request. We normally respond as soon as we can and in any event within one month of receiving a request and any necessary proof of identity or further information. If the request is particularly difficult or complex, we may require longer to respond in which case we will inform the data subject within the 30 day deadline.
8.1 Freedom of information (Subject Access Request): On request we will provide any data subject with a copy of all or part of the information we hold on them as determined by their written request.
8.2 Processing Data: Data Subjects have the right to stop us from processing all or part of any personal data where we are relying on legitimate interests as the legal basis of our processing.
8.3 Inaccurate Data: Prime Prospects will promptly correct any inaccuracies we are informed of, provided we are satisfied that the new data is accurate.
8.4 Transfer: We will transfer information held on any data subject to another organisation when requested provided we have received confirmation of their identity from the data subject making the request and also confirmation from the receiving company that they agree to accept the data in a standard format.
8.5 Data Removal: On request we will delete all or part of the information we hold on a data subject and we will inform the third party, whenever they were the source of the data. This right is known as the ‘right to be forgotten’ and we uphold that right other than in the circumstance where we are required to retain the data by law or it is required to protect or enforce our rights or the rights of any third party.
9. Security Procedures
Prime Prospects have a number of processes in place to ensure that the data we hold will not be stolen or otherwise compromised. These include:
9.1 Encryption: All data files containing personal data files are encrypted as are any files despatched to our customers.
9.2 Access: Files are maintained on password protected personal computers with passwords changed every 60 days. All access is restricted to employees, each of whom is trained in our data privacy policies and whose employment contracts specify their adherence to these policies.
We do not provide any external access to our primary databases, the majority of which are maintained on our internal computers. Some client owned files are maintained in secure environments on the cloud to facilitate their access.
We employ sophisticated anti-viral software to ensure our systems remain secure and confidential.
9.3 Office Security: Our offices are locked at all times and entry is accessible only to authorised staff with keys or by invitation when members of staff are present.
9.4 Waste Disposal: Paper waste is shredded before disposal and all obsolete storage media is data-wiped and destroyed by licensed 3rd-parties with certification. Similarly, any redundant hard drives will be certified as destroyed by licensed 3rd-parties.
10. Administrative Details:
Data subjects who are dissatisfied with an explanation from our DPO have the right to complain to the Information Commissioner’s Office (ICO), which regulates data protection compliance in the UK. For more information visit https://ico.org.uk/
Policy updated on 25 May 2018