Fair Processing Notice and Privacy Policy (‘Policy’)

Randall’s Monitoring Ltd (‘we’, ‘our’, ‘us’, ‘the company’) is committed to protecting the privacy and security of personal information. This Policy explains how we collect and use information about you. By using your information, we are able to provide the news, content, products and services you are interested in. The use of your information helps us understand what your needs and interests are, to provide you with relevant content, and to let you know about our services.

For the purpose of data protection legislation, we are a Data Controller.

For the purposes of this Policy:

‘Clients’ includes natural persons who have engaged us to provide services to them in their personal capacity or on behalf of a company, partnership, charity, trust, estate, agency, department, corporate body of any description or any other group or organisation;

‘Subscribers’ includes natural persons that have signed up to receive our marketing communications and briefings;

‘Suppliers’ includes persons and organisations with whom we have a relationship, contractual or otherwise.

We adhere to the requirements as set out in data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Data protection legislation states that personal information we hold about you must be:

  • processed lawfully, fairly and in a transparent manner; collected for a specific purpose;
  • relevant to the purposes we have explained to you;
  • accurate and kept up to date;
  • held only as long as is necessary for the purposes that we have explained to you; and
  • kept securely.

Who we are and what we do

We are a political and parliamentary information monitoring service providing online services, by email and website. If you have questions about this Policy or our privacy practices, please contact us in the following ways:

  • Postal address: Our registered company address is St George’s House, 14 George Street, Huntingdon, Cambridgeshire, PE29 3GH
  • Postal address: Our operational address is 27 Birchfield Close, Addlestone, Surrey KT15 1QZ
  • Our telephone number is 020 7235 2999
  • Our email address is: info@randallsmonitoring.co.uk

The type of personal information we collect

We collect personal data, which is information that relates to an identified or identifiable individual.

In terms of our Clients and Subscribers, we hold all or some of the following data:

  • Name
  • Technical data including IP addresses and cookie identifiers
  • Company name and contact details
  • Job title
  • Schedule of interests/preference
  • Email correspondence between us and you
  • Transactional data and financial data
  • Marketing and Communications Data

In terms of our Suppliers, we hold the following data:

  • Name
  • Company address
  • Email address
  • Postal address
  • Telephone number
  • Work-related email correspondence between us and you

In terms of Parliamentarians (which includes Members of the House of Commons and Members of the House of Lords, elected Members from Scotland, Wales, Northern Ireland and the Greater London Assembly), we hold the following data which may include special category data:

How we obtain personal information and why we have it

We typically collect information directly from our Clients and Subscribers when you subscribe to our services or request services from us.

As you interact with your website, we will automatically collect technical data about to track use of the website, to compile statistical reports on website activity, and generally to enhance your experience of using the site. This information may be obtained from an analytics provider such as Google.

We will also receive personal information about parliamentarians from publicly available sources, such as, Parliament.uk data APIs, available press articles, public record speeches, press releases and Hansard/Official Report contributions.

Randall’s holds personal information to:

  • supply Subscribers and Clients with our services; and;
  • Supply Subscribers and Clients with access to relevant and up to date information on Parliamentarians.

We may provide links to websites of other organisations, in order to provide our Clients and Subscribers with further information and primary source access. This Policy does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.

We operate a contact management system to post content to our website. We don’t have any access to personal information that is uploaded by our Clients or Subscribers on to the system.

Lawful basis

For us to legally process your personal information we need to have the lawful basis. Your personal information will be processed under one of the following bases;

  1. Your consent. You have given us clear and informed consent to process your personal information for a specific purpose. You are able to withdraw your consent at any time.
  2. Performance of Contract.  This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  3. Legitimate Interest.  This means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

How we store your personal information

Any personal information that we hold about Clients or Subscribers is securely stored online using password -protected services, with up-to-date software security. The bulk of our client data is stored in a Microsoft 365 environment to which only directly employed Staff have access. All access is audited, and password controlled.

Our paper records are limited to those required by statute, covering invoicing and contractual information.  These are securely stored.

Who we share your personal data with

We may share your personal data with the parties listed below.

  • Other companies that may form a group of companies with us from time to time acting a joint controllers or independent controllers.
  • Service providers acting as processors based who provide IT and system administration services.  Such providers may be based in countries where data laws provide less protection.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers.
  • HM Revenue & Customs, regulators and other authorities.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the UK. Occasionally Customers or Subscribers to our services will be based outside of the UK and we will transfer information to them that may contain publicly available information that may contain personal data (such as the name, biographical and professional contact details of parliamentarians, copies of public record speeches, and Hansard/Official Report contributions, press articles, all of which are publicly available.)  In doing so we rely on an exception to the restrictions on transfers as we make the restricted transfer from a public register which is open to the public in general and we have a legitimate interest in doing so and the effect on individuals is proportionate.

Retaining information

We keep your personal information for no longer than is necessary.  We will then dispose your information by deleting from our systems if electronic or shredding if held in paper format.  All data on clients will be erased from our systems within two months of the end of a contract. If you have supplied your personal data in order to obtain a copy of a briefing from our Insights page, we will store that data for no more than six months.

With regards to data relating to Parliamentarians, this is kept as an archive in our online systems but deleted when the person involved no longer has a public role. 

We will only retain any information if a business need exists. It is not kept longer than is necessary for the purpose for which it was collected.  

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including:

Your right of access – You have the right to ask us for copies of the personal data we hold about you.

Your right to rectification – You have the right to ask us to rectify personal data that we hold about you if you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to delete or remove your personal data.

Your right to restriction of processing – You have the right to ask us to suspend the processing of your personal data in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

Your right to data portability – You have the right to ask us to transfer your personal data to a third party, or to you.

You are not required to pay any charge for exercising your rights. If you make a request, we try to respond to all legitimate requests within a month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please contact us at info@randallsmonitoring.co.uk / 020 7235 2999 if you wish to make a request.

Cookies

Cookies are small text files placed on your device (mobile, tablet, desktop computer etc.) to collect information and enable certain website functions, such as maintaining state. They are used to track visitor use of the website, to compile statistical reports on website activity, and generally to enhance your experience of using the site. Cookies may be set and accessed by third-party data processors, including Google Analytics (privacy policy). For further information please visit aboutcookies.org.uk.

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, some of our website features may not function correctly as a result.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at info@randallsmonitoring.co.uk / 020 7235 2999.

You can also complain to the ICO if you are unhappy with how we have used your personal data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

August 2023 Revision