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PRIVACY POLICY




Home > Privacy Policy

1.INTERPRETATION

 1. Definitions:

 1. 1.  Automated Decision-Making (ADM): when a decision is made which is based
        solely on Automated Processing (including profiling) which produces
        legal effects or significantly affects an individual. The GDPR prohibits
        Automated Decision-Making (unless certain conditions are met) but not
        Automated Processing.
    2.  Automated Processing: any form of automated processing of Personal Data
        consisting of the use of Personal Data to evaluate certain personal
        aspects relating to an individual, in particular to analyse or predict
        aspects concerning that individual’s performance at work, economic
        situation, health, personal preferences, interests, reliability,
        behaviour, location or movements. Profiling is an example of Automated
        Processing.
    3.  Company name: JTF Marketing Limited
    4.  Company Personnel: all employees, workers, contractors, agency workers,
        consultants, directors, members and others.
    5.  Consent: agreement which must be freely given, specific, informed and be
        an unambiguous indication of the Data Subject’s wishes by which they, by
        a statement or by a clear positive action, signify agreement to the
        Processing of Personal Data relating to them.
    6.  Controller: the person or organisation that determines when, why and how
        to process Personal Data. It is responsible for establishing practices
        and policies in line with the GDPR. We are the Controller of all
        Personal Data relating to our Company Personnel and Personal Data used
        in our business for our own commercial purposes.
    7.  Criminal Convictions Data: means personal data relating to criminal
        convictions and offences and includes personal data relating to criminal
        allegations and proceedings.
    8.  Data Subject: a living, identified or identifiable individual about whom
        we hold Personal Data. Data Subjects may be nationals or residents of
        any country and may have legal rights regarding their Personal Data.
    9.  Data Privacy Impact Assessment (DPIA): tools and assessments used to
        identify and reduce risks of a data processing activity. DPIA can be
        carried out as part of Privacy by Design and should be conducted for all
        major system or business change programmes involving the Processing of
        Personal Data.
    10. Data Protection Officer (DPO): the person required to be appointed in
        specific circumstances under the GDPR. Where a mandatory DPO has not
        been appointed, this term means a data protection manager or other
        voluntary appointment of a DPO or refers to the Company data privacy
        team with responsibility for data protection compliance.
    11. EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
    12. Explicit Consent: consent which requires a very clear and specific
        statement (that is, not just action).
    13. General Data Protection Regulation (GDPR): the General Data Protection
        Regulation ((EU) 2016/679). Personal Data is subject to the legal
        safeguards specified in the GDPR.
    14. Personal Data: any information identifying a Data Subject or information
        relating to a Data Subject that we can identify (directly or indirectly)
        from that data alone or in combination with other identifiers we possess
        or can reasonably access. Personal Data includes Special Categories of
        Personal Data and Pseudonymised Personal Data but excludes anonymous
        data or data that has had the identity of an individual permanently
        removed. Personal data can be factual (for example, a name, email
        address, location or date of birth) or an opinion about that person’s
        actions or behaviour.
    15. Personal Data Breach: any act or omission that compromises the security,
        confidentiality, integrity or availability of Personal Data or the
        physical, technical, administrative or organisational safeguards that we
        or our third-party service providers put in place to protect it. The
        loss, or unauthorised access, disclosure or acquisition, of Personal
        Data is a Personal Data Breach.
    16. Privacy by Design: implementing appropriate technical and organisational
        measures in an effective manner to ensure compliance with the GDPR.
    17. Privacy Notices (also referred to as Fair Processing Notices) or Privacy
        Policies: separate notices setting out information that may be provided
        to Data Subjects when the Company collects information about them. These
        notices may take the form of general privacy statements applicable to a
        specific group of individuals (for example, employee privacy notices or
        the website privacy policy) or they may be stand-alone, one-time privacy
        statements covering Processing related to a specific purpose.
    18. Processing or Process: any activity that involves the use of Personal
        Data. It includes obtaining, recording or holding the data, or carrying
        out any operation or set of operations on the data including organising,
        amending, retrieving, using, disclosing, erasing or destroying it.
        Processing also includes transmitting or transferring Personal Data to
        third parties.
    19. Pseudonymisation or Pseudonymised: replacing information that directly
        or indirectly identifies an individual with one or more artificial
        identifiers or pseudonyms so that the person, to whom the data relates,
        cannot be identified without the use of additional information which is
        meant to be kept separately and secure.
    20. Special Categories of Personal Data: information revealing racial or
        ethnic origin, political opinions, religious or similar beliefs, trade
        union membership, physical or mental health conditions, sexual life,
        sexual orientation, biometric or genetic data.

2.INTRODUCTION

This Privacy Standard sets out how JTF Marketing Limited (“we”, “our”, “us”,
“the Company”) handle the Personal Data of our customers, suppliers, employees,
workers and other third parties.

This Privacy Standard applies to all Personal Data we Process regardless of the
media on which that data is stored or whether it relates to past or present
employees, workers, customers, clients or supplier contacts, shareholders,
website users or any other Data Subject.

This Privacy Standard applies to all Company Personnel (“you”, “your”). You must
read, understand and comply with this Privacy Standard when Processing Personal
Data on our behalf and attend training on its requirements. This Privacy
Standard sets out what we expect from you for the Company to comply with
applicable law. Your compliance with this Privacy Standard is mandatory. Any
breach of this Privacy Standard may result in disciplinary action.

Where you have a specific responsibility in connection with Processing such as
capturing Consent, reporting a Personal Data Breach, conducting a DPIA as
referenced in this Privacy Standard. 

This Privacy Standard is an internal document and cannot be shared with third
parties, clients or regulators without prior authorisation from the DPO.

3.SCOPE

We recognise that the correct and lawful treatment of Personal Data will
maintain confidence in the organisation and will provide for successful business
operations. Protecting the confidentiality and integrity of Personal Data is a
critical responsibility that we take seriously at all times.

All managers are responsible for ensuring all Company Personnel comply with this
Privacy Standard and need to implement appropriate practices, processes,
controls and training to ensure that compliance.

The DPO is responsible for overseeing this Privacy Standard. That post is held
by James T Fletcher, dataofficer@34.78.222.86.

Please contact the DPO with any questions about the operation of this Privacy
Standard or the GDPR or if you have any concerns that this Privacy Standard is
not being or has not been followed.

4.PERSONAL DATA PROTECTION PRINCIPLES

We adhere to the principles relating to Processing of Personal Data set out in
the GDPR which require Personal Data to be:

 * Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness
   and Transparency);
 * collected only for specified, explicit and legitimate purposes (Purpose
   Limitation);
 * adequate, relevant and limited to what is necessary in relation to the
   purposes for which it is Processed (Data Minimisation);
 * accurate and where necessary kept up to date (Accuracy);
 * not kept in a form which permits identification of Data Subjects for longer
   than is necessary for the purposes for which the data is Processed (Storage
   Limitation);
 * Processed in a manner that ensures its security using appropriate technical
   and organisational measures to protect against unauthorised or unlawful
   Processing and against accidental loss, destruction or damage (Security,
   Integrity and Confidentiality);
 * not transferred to another country without appropriate safeguards being in
   place (Transfer Limitation); and
 * made available to Data Subjects and allow Data Subjects to exercise certain
   rights in relation to their Personal Data (Data Subject’s Rights and
   Requests).

We are responsible for and must be able to demonstrate compliance with the data
protection principles listed above (Accountability).

5.LAWFULNESS, FAIRNESS, TRANSPARENCY

 1. Lawfulness and fairness

Personal data must be Processed lawfully, fairly and in a transparent manner in
relation to the Data Subject.

You may only collect, Process and share Personal Data fairly and lawfully and
for specified purposes. The GDPR restricts our actions regarding Personal Data
to specified lawful purposes. These restrictions are not intended to prevent
Processing, but ensure that we Process Personal Data fairly and without
adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out
below:

 * the Data Subject has given his or her Consent;
 * the Processing is necessary for the performance of a contract with the Data
   Subject;
 * to meet our legal compliance obligations;
 * to protect the Data Subject’s vital interests;
 * to pursue our legitimate interests for purposes where they are not overridden
   because the Processing prejudices the interests or fundamental rights and
   freedoms of Data Subjects. The purposes for which we process Personal Data
   for legitimate interests need to be set out in applicable Privacy Notices.

You must identify and document the legal ground being relied on for each
Processing activity.

6.CONSENT

A Controller must only process Personal Data on the basis of one or more of the
lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate
agreement clearly either by a statement or positive action to the Processing.
Consent requires affirmative action so silence, pre-ticked boxes or inactivity
are unlikely to be sufficient. If Consent is given in a document which deals
with other matters, then the Consent must be kept separate from those other
matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time
and withdrawal must be promptly honoured. Consent may need to be refreshed if
you intend to Process Personal Data for a different and incompatible purpose
which was not disclosed when the Data Subject first consented.

When processing Special Category Data or Criminal Convictions Data, we will
usually rely on a legal basis for processing other than Explicit Consent or
Consent if possible. Where Explicit Consent is relied on, you must issue a
Privacy Notice to the Data Subject to capture Explicit Consent. 

You will need to evidence Consent captured and keep records of all Consents so
that the Company can demonstrate compliance with Consent requirements.

7.TRANSPARENCY (NOTIFYING DATA SUBJECTS)

The GDPR requires Data Controllers to provide detailed, specific information to
Data Subjects depending on whether the information was collected directly from
Data Subjects or from elsewhere. The information must be provided through
appropriate Privacy Notices which must be concise, transparent, intelligible,
easily accessible, and in clear and plain language so that a Data Subject can
easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for
human resources or employment purposes, we must provide the Data Subject with
all the information required by the GDPR including the identity of the
Controller and DPO, how and why we will use, Process, disclose, protect and
retain that Personal Data through a Privacy Notice which must be presented when
the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or
publicly available source), we must provide the Data Subject with all the
information required by the GDPR as soon as possible after collecting or
receiving the data. We must also check that the Personal Data was collected by
the third party in accordance with the GDPR and on a basis which contemplates
our proposed Processing of that Personal Data.

If you are collecting Personal Data from Data Subjects, directly or indirectly,
then you must provide Data Subjects with a Privacy Notice.

8.PURPOSE LIMITATION

Personal Data must be collected only for specified, explicit and legitimate
purposes. It must not be further Processed in any manner incompatible with those
purposes.

You cannot use Personal Data for new, different or incompatible purposes from
that disclosed when it was first obtained unless you have informed the Data
Subject of the new purposes and they have Consented where necessary.

9.DATA MINIMISATION

Personal Data must be adequate, relevant and limited to what is necessary in
relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it.
You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not
collect excessive data. Ensure any Personal Data collected is adequate and
relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified
purposes, it is deleted or anonymised in accordance with the Company’s data
retention guidelines.

10.ACCURACY

Personal Data must be accurate and, where necessary, kept up to date. It must be
corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete,
kept up to date and relevant to the purpose for which we collected it. You must
check the accuracy of any Personal Data at the point of collection and at
regular intervals afterwards. You must take all reasonable steps to destroy or
amend inaccurate or out-of-date Personal Data.

11.STORAGE LIMITATION

Personal Data must not be kept in an identifiable form for longer than is
necessary for the purposes for which the data is processed.

The Company will maintain retention policies and procedures to ensure Personal
Data is deleted after a reasonable time for the purposes for which it was being
held, unless a law requires that data to be kept for a minimum time.  

You must not keep Personal Data in a form which permits the identification of
the Data Subject for longer than needed for the legitimate business purpose or
purposes for which we originally collected it including for the purpose of
satisfying any legal, accounting or reporting requirements.

You will take all reasonable steps to destroy or erase from our systems all
Personal Data that we no longer require in accordance with all the Company’s
applicable records retention schedules and policies. This includes requiring
third parties to delete that data where applicable.

You will ensure Data Subjects are informed of the period for which data is
stored and how that period is determined in any applicable Privacy Notice.

12.SECURITY INTEGRITY AND CONFIDENTIALITY

 1. Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational
measures against unauthorised or unlawful Processing, and against accidental
loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size,
scope and business, our available resources, the amount of Personal Data that we
own or maintain on behalf of others and identified risks (including use of
encryption and Pseudonymisation where applicable). We will regularly evaluate
and test the effectiveness of those safeguards to ensure security of our
Processing of Personal Data. You are responsible for protecting the Personal
Data we hold. You must implement reasonable and appropriate security measures
against unlawful or unauthorised Processing of Personal Data and against the
accidental loss of, or damage to, Personal Data. You must exercise particular
care in protecting Special Categories of Personal Data and Criminal Convictions
Data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the
security of all Personal Data from the point of collection to the point of
destruction. You may only transfer Personal Data to third-party service
providers who agree to comply with the required policies and procedures and who
agree to put adequate measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and
availability of the Personal Data, defined as follows:

 * Confidentiality means that only people who have a need to know and are
   authorised to use the Personal Data can access it;
 * Integrity means that Personal Data is accurate and suitable for the purpose
   for which it is processed; and
 * Availability means that authorised users are able to access the Personal Data
   when they need it for authorised purposes.

You must comply with and not attempt to circumvent the administrative, physical
and technical safeguards we implement and maintain in accordance with the GDPR
and relevant standards to protect Personal Data.

13.REPORTING A PERSONAL DATA BREACH

The GDPR requires Controllers to notify any Personal Data Breach to the
applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach
and will notify Data Subjects or any applicable regulator where we are legally
required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt
to investigate the matter yourself. Immediately contact the person or team
designated as the key point of contact for Personal Data Breaches (the DPO). You
should preserve all evidence relating to the potential Personal Data Breach.

14.TRANSFER LIMITATION

The GDPR restricts data transfers to countries outside the EEA to ensure that
the level of data protection afforded to individuals by the GDPR is not
undermined. You transfer Personal Data originating in one country across borders
when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the EEA if one of the following
conditions applies:

 * the European Commission has issued a decision confirming that the country to
   which we transfer the Personal Data ensures an adequate level of protection
   for the Data Subject’s rights and freedoms;
 * appropriate safeguards are in place such as binding corporate rules (BCR),
   standard contractual clauses approved by the European Commission, an approved
   code of conduct or a certification mechanism, a copy of which can be obtained
   from the DPO;
 * the Data Subject has provided Explicit Consent to the proposed transfer after
   being informed of any potential risks; or
 * the transfer is necessary for one of the other reasons set out in the GDPR
   including the performance of a contract between us and the Data Subject,
   reasons of public interest, to establish, exercise or defend legal claims or
   to protect the vital interests of the Data Subject where the Data Subject is
   physically or legally incapable of giving Consent and, in some limited cases,
   for our legitimate interest.

15.DATA SUBJECT’S RIGHTS AND REQUESTS

Data Subjects have rights when it comes to how we handle their Personal Data.
These include rights to:

 * withdraw Consent to Processing at any time;
 * receive certain information about the Data Controller’s Processing
   activities;
 * request access to their Personal Data that we hold;
 * prevent our use of their Personal Data for direct marketing purposes;
 * ask us to erase Personal Data if it is no longer necessary in relation to the
   purposes for which it was collected or Processed or to rectify inaccurate
   data or to complete incomplete data;
 * restrict Processing in specific circumstances;
 * challenge Processing which has been justified on the basis of our legitimate
   interests or in the public interest;
 * request a copy of an agreement under which Personal Data is transferred
   outside of the EEA;
 * object to decisions based solely on Automated Processing, including profiling
   (ADM);
 * prevent Processing that is likely to cause damage or distress to the Data
   Subject or anyone else;
 * be notified of a Personal Data Breach which is likely to result in high risk
   to their rights and freedoms;
 * make a complaint to the supervisory authority;
 * in limited circumstances, receive or ask for their Personal Data to be
   transferred to a third party in a structured, commonly used and
   machine-readable format.

You must verify the identity of an individual requesting data under any of the
rights listed above (do not allow third parties to persuade you into disclosing
Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to your
supervisor.

16.ACCOUNTABILITY

The Controller must implement appropriate technical and organisational measures
in an effective manner, to ensure compliance with data protection principles.
The Controller is responsible for, and must be able to demonstrate, compliance
with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to
document GDPR compliance including:

 * appointing a suitably qualified DPO (where necessary) and an executive
   accountable for data privacy;
 * implementing Privacy by Design when Processing Personal Data and completing
   DPIAs where Processing presents a high risk to rights and freedoms of Data
   Subjects;
 * integrating data protection into internal documents including this Privacy
   Standard or Privacy Notices;
 * regularly training Company Personnel on the GDPR, this Privacy Standard, and
   data protection matters including, for example, Data Subject’s rights,
   Consent, legal basis, DPIA and Personal Data Breaches. The Company must
   maintain a record of training attendance by Company Personnel; and
 * regularly testing the privacy measures implemented and conducting periodic
   reviews and audits to assess compliance, including using results of testing
   to demonstrate compliance improvement effort.

17.RECORD KEEPING

The GDPR requires us to keep full and accurate records of all our data
Processing activities.

You must keep and maintain accurate corporate records reflecting our Processing
including records of Data Subjects’ Consents and procedures for obtaining
Consents.

These records should include, at a minimum, the name and contact details of the
Controller and the DPO, clear descriptions of the Personal Data types, Data
Subject types, Processing activities, Processing purposes, third-party
recipients of the Personal Data, Personal Data storage locations, Personal Data
transfers, the Personal Data’s retention period and a description of the
security measures in place. To create the records, data maps should be created
which should include the detail set out above together with appropriate data
flows.

18.TRAINING AND AUDIT

We are required to ensure all Company Personnel have undergone adequate training
to enable them to comply with data privacy laws. We must also regularly test our
systems and processes to assess compliance.

You must undergo all mandatory data privacy related training and ensure your
team undergo similar mandatory training.

You must regularly review all the systems and processes under your control to
ensure they comply with this Privacy Standard and check that adequate governance
controls and resources are in place to ensure proper use and protection of
Personal Data.

19.PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA)

We are required to implement Privacy by Design measures when Processing Personal
Data by implementing appropriate technical and organisational measures (like
Pseudonymisation) in an effective manner, to ensure compliance with data privacy
principles.

You must assess what Privacy by Design measures can be implemented on all
programmes, systems or processes that Process Personal Data by taking into
account the following:

 * the state of the art;
 * the cost of implementation;
 * the nature, scope, context and purposes of Processing; and
 * the risks of varying likelihood and severity for rights and freedoms of Data
   Subjects posed by the Processing.

Data controllers must also conduct DPIAs in respect to high-risk Processing.

You should conduct a DPIA (and discuss your findings with the DPO) when
implementing major system or business change programs involving the Processing
of Personal Data including:

 * use of new technologies (programs, systems or processes), or changing
   technologies (programs, systems or processes);
 * Automated Processing including profiling and ADM;
 * large-scale Processing of Special Categories of Personal Data or Criminal
   Convictions Data; and
 * large-scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

 * a description of the Processing, its purposes and the Data Controller’s
   legitimate interests if appropriate;
 * an assessment of the necessity and proportionality of the Processing in
   relation to its purpose;
 * an assessment of the risk to individuals; and
 * the risk mitigation measures in place and demonstration of compliance.

20.AUTOMATED PROCESSING (INCLUDING PROFILING) AND AUTOMATED DECISION-MAKING

Generally, ADM is prohibited when a decision has a legal or similar significant
effect on an individual unless:

 * a Data Subject has Explicitly Consented;
 * the Processing is authorised by law; or
 * the Processing is necessary for the performance of or entering into a
   contract.

If certain types of Special Categories of Personal Data or Criminal Convictions
Data are being processed, then grounds (b) or (c) will not be allowed but the
Special Categories of Personal Data and Criminal Convictions Data can be
Processed where it is necessary (unless less intrusive means can be used) for
substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including
profiling), then Data Subjects must be informed when you first communicate with
them of their right to object. This right must be explicitly brought to their
attention and presented clearly and separately from other information. Further,
suitable measures must be put in place to safeguard the Data Subject’s rights
and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision
making or profiling, the significance and envisaged consequences and give the
Data Subject the right to request human intervention, express their point of
view or challenge the decision.

A DPIA must be carried out before any Automated Processing (including profiling)
or ADM activities are undertaken.

21.DIRECT MARKETING

We are subject to certain rules and privacy laws when marketing to our
customers.

For example, a Data Subject’s prior consent is required for electronic direct
marketing (for example, by email, text or automated calls). The limited
exception for existing customers known as “soft opt-in” allows organisations to
send marketing texts or emails if they have obtained contact details in the
course of a sale to that person, they are marketing similar products or
services, and they gave the person an opportunity to opt out of marketing when
first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data
Subject in an intelligible manner so that it is clearly distinguishable from
other information.

A Data Subject’s objection to direct marketing must be promptly honoured. If a
customer opts out at any time, their details should be suppressed as soon as
possible. Suppression involves retaining just enough information to ensure that
marketing preferences are respected in the future.

22.SHARING PERSONAL DATA

Generally we are not allowed to share Personal Data with third parties unless
certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or
representative of our group (which includes our subsidiaries and our ultimate
holding company along with its subsidiaries) if the recipient has a job-related
need to know the information and the transfer complies with any applicable
cross-border transfer restrictions.

You may only share the Personal Data we hold with third parties, such as our
service providers, if:

 * they have a need to know the information for the purposes of providing the
   contracted services;
 * sharing the Personal Data complies with the Privacy Notice provided to the
   Data Subject and, if required, the Data Subject’s Consent has been obtained;
 * the third party has agreed to comply with the required data security
   standards, policies and procedures and put adequate security measures in
   place;
 * the transfer complies with any applicable cross-border transfer restrictions;
   and
 * a fully executed written contract that contains GDPR-approved third party
   clauses has been obtained.

23.CHANGES TO THIS PRIVACY STANDARD

We keep this Privacy Standard under regular review. This version was last
updated on 7th February 2019.

This Privacy Standard does not override any applicable national data privacy
laws and regulations in countries where the Company operates.


CONSULTANCY & SERVICES

 * Marketing automation implementation
 * Marketo email templates
 * Lead nurturing campaigns
 * Lead scoring models
 * ROI & reporting
 * Managed Marketo Engage services


INSIGHTS & TRAINING

 * Insights & blog
 * Marketo training
 * Marketo Certification Training
 * Guide to gating content
 * Marketing automation toolkit
 * Marketo vs Hubspot


COMPANY & LEGAL

 * Contact us
 * About Us
 * Our Customers
 * Partners
 * Privacy Policy
 * Terms & Conditions
 * Cookie Policy

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Language:
 * English
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JTF Marketing Limited is a company registered in England and Wales with company
number 09747166 and VAT Registration number: GB 242658401. Registered Office:
201 Borough High Street, London, SE1 1JA.

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