The purpose of this statement is to provide information regarding how and why White Rabbit Consultancy collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.
Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed as follows:
Consent – the individual has given clear consent for you to process their personal data for a specific purpose
Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)
Vital Interests – the processing is necessary to protect someone’s life
Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful basis for processing personal data can be found at ico.org.uk
For your information White Rabbit Consultancy is comprised of: White Rabbit Consultancy, Creatal and Masero Digital.
White Rabbit Consultancy Marketing and Sales Data
As an organisation that processes business related data, White Rabbit Consultancy has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of White Rabbit Consultancy marketing and sales.
White Rabbit Consultancy collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in White Rabbit Consultancy’s products and/or services. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical segmentation includes those within marketing, sales, business development, Finance, MD and owner related job functions, although this list is not exhaustive and other variables may apply.
We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIn) as well as business IP and physical address. Other business-related data may also be processed including business name, job function, and turnover, however we will never collect further personal data such as those classed under ‘Special Categories of Personal Data’.
The data collected will be used to communicate marketing and sales messages relating to White Rabbit Consultancy’s products and services, based upon the job function held by the data subject. White Rabbit Consultancy specifically only sends messages to those we believe are likely to be interested in White Rabbit Consultancy’s products and services based upon the organisation they are employed by and based upon their job function within that organisation. Messages from White Rabbit Consultancy could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.
When you send White Rabbit Consultancy an enquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other White Rabbit Consultancy products and services that we feel may be of interest to you. It is deemed that if you have visited one of White Rabbit Consultancy websites and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.
How We Procure Data
At White Rabbit Consultancy we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:
You have requested information from White Rabbit Consultancy on a previous occasion
Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you.
You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
We have previously met at an event and your business card or contact details were handed to us willingly
You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
You have previously connected with a member of our team via LinkedIn and discussed our services
A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in White Rabbit Consultancy’s products and/or services. And based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our products and services.
Your data has been purchased from a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles and the legal basis for our processing of this data has been established and verified.
Email Marketing Tracking
Tracking email opens
When we send marketing emails promoting any of White Rabbit Consultancy’s products and services we employ a common software technology called beacons. Beacons are tiny 1px x 1px graphics with a unique identifier, similar in function to cookies, and are used to track if you have opened a marketing email. We use these in our HTML-based emails to let us know which emails have been opened by recipients. They allow us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.
Tracking email clicks
When we send marketing emails promoting any of White Rabbit Consultancy’s products and services we personalise each link in each email with unique code to enable us to track whether the recipient has clicked on the link in the email. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.
Legitimate Interest Assessment (LIA)
White Rabbit Consultancy has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based on that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding White Rabbit Consultancy and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from White Rabbit Consultancy in a direct marketing or sales capacity, could be legitimately interested in White Rabbit Consultancy’s solution. It is also deemed that direct marketing and sales is necessary in the context of promoting White Rabbit Consultancy to professionals in business in order to increase awareness of our products and services.
Per the ICO guidance, White Rabbit Consultancy can confirm:
We have checked that legitimate interests is the most appropriate basis
We understand our responsibility to protect the individual’s interests
We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
We have identified the relevant legitimate interests
We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
We only use individuals’ data in ways they would reasonably expect
We are not using people’s data in ways they would find intrusive or which could cause them harm
We do not process the data of children
We have considered safeguards to reduce the impact where possible
We will always ensure there is an opt-out / ability to object
Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
We keep our LIA under review every six months, and will repeat it if circumstances change
We include information about our legitimate interests in this privacy notice
White Rabbit Consultancy has an in-house data verification, which is responsible for ensuring the validity and quality of the data contained within White Rabbit Consultancy’s CRM system.
Data Storage & Retention
The data held within White Rabbit Consultancy’s CRM system is processed and stored in the UK within a secure environment.
We will use your data to update you with details of our product and service offerings, However, we will delete your data should you no longer show interest in these details at a time 5 years after the last verifiable contact we have with you.
We will use your data to update you with details of our product and service offerings, However, we will delete your data should you no longer show interest in these details at a time 5 years after the last verifiable contact we have with you.
Security of Personal Data
Appropriate measures
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.
Secure storage
We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.
Password storage
Any passwords you provide us will be stored by us in encrypted form.
Financial transactions
Data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
Acknowledgement of you transmitting unencrypted data
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of that data sent over the internet
Providing Your Personal Data to Others
In this Section, we provide you with information about which third parties we may pass your data to.
Our group companies
We may share your personal data within our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as is reasonably necessary for the purposes set out in this policy.
Our technical providers
Your personal data may be stored in our data centre, on our telephony system and servers where it may be accessed by third party administrators insofar as is reasonably necessary for the safe and efficient storage of your data. We may use third parties such as email service providers and campaign analytics services who may process your personal data at our request in order to maximise the efficiency of our communications with you.
Our payment providers
Financial transactions relating to our website and services may be handled by our payment services providers, PayPal and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
Our productivity and communication application providers
We may use your personal data in our internal productivity and communication applications insofar as is reasonably necessary for the purposes of proper administration of our website and business.
For compliance with a legal obligation
In addition to the specific disclosures of personal data set out in this Privacy Policy, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Right to Object
In all correspondence with you we will give you the right to object from receiving further correspondence from White Rabbit Consultancy. On any emails you receive from White Rabbit Consultancy there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you receive a telephone call from us, you have the right to request not to receive any further calls. White Rabbit Consultancy has a company wide CRM system. Your request to object will be logged within our CRM system to ensure that you do not receive any further calls.
Should you wish to object to receiving communication from White Rabbit Consultancy, you can do so in a variety of ways:
Please click the ‘unsubscribe’ link at the bottom of every email
If you have received a call, please tell the representative that you do not wish to receive any further communication
Please call 03300 581 580
You can also make your request by emailing:
Or by writing to:
Data Compliance, White Rabbit Consultancy, Upper Suite, 128 Sackville Road, Brighton & Hove, Sussex, BN3 7AA
All requests will be processed within 30 days. Your details will be added to a suppression file to ensure that your details cannot be processed by White Rabbit Consultancy’s CRM system in the future. Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.
Right to Request Erasure
It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from White Rabbit Consultancy’s CRM system. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from White Rabbit Consultancy. If you do not wish for us to contact you again about White Rabbit Consultancy products and services, we would recommend you request to object rather than make a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days.
Please make your request in writing by emailing:
Or by writing to:
Data Compliance, White Rabbit Consultancy, Upper Suite, 128 Sackville Road, Brighton & Hove, Sussex, BN3 7AA
Right to Access
You may request that we send you all of the data we hold that relates to you. Please make your request in writing;
By emailing:
Or by writing to:
Data Compliance, White Rabbit Consultancy, Upper Suite, 128 Sackville Road, Brighton & Hove, Sussex, BN3 7AA
We will process and respond to your request within 30 days, this service will be free of charge.
Under the GDPR you have a number of data privacy Rights including those listed above. For more information on these rights please see the website of the Information Commissioner’s Office at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
This policy was last reviewed and updated on the 18th June 2019. Policies are periodically reviewed to ensure compliance with the current compliance environment.
For questions relating to this policy, please contact:
For further information on the GDPR as well as other Data Protection and Data Privacy issues and regulations please visit www.ico.org.uk
White Rabbit Consultancy is registered with the Dun & Bradstreet under DUNS Number: 212964300
