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This document aims to explore the appropriateness of the legal basis of ‘Legitimate Interest’ for the processing of personal data by Steven Hunt – Alesco Development. with respect to the GDPR and the rights of the individuals whose data is processed and stored by the Steven Hunt – Alesco Development.

1. Why does Steven Hunt – Alesco Development need to process personal data?

There are three main areas of data processing that the Steven Hunt – Alesco Development undertake, these are:

  1. Administrative and commercial data processing (Data Controller)
  2. Business development and marketing data processing and (Data Controller)

Taking each of these areas in turn, this document aims to explore:

  1. The objectives of data processing
  2. The relevance and importance of data processing to the business
  3. The impact on the individuals whose data is processed
  4. The expectation of the individual that their data would be processed and
  5. The rights of the individual whose data is processed

1.1. Administrative and commercial data processing (Data Controller)

Steven Hunt – Alesco Development processes supplier and customer’ data for legitimate and common business purposes, in situations which are not necessary for the performance of the business, but are nevertheless customary, or necessary for operational and administrative purposes and to otherwise manage relationship and interaction between Steven Hunt – Alesco Development and its suppliers and customers.

1.2. Business development and marketing data processing (Data Controller)

Steven Hunt – Alesco Development processes supplier and customer data for legitimate and common business purposes, including communications and marketing, processing certain ‘low risk’ personal data to gather market intelligence, promote products and services, communicate with and tailor offers to individual customers and contacts.

Specific examples are:

  1. Discretionary service interactions - customers are identified in order for them to receive communications relating to service developments and product notifications relating to Steven Hunt – Alesco Development products
  2. Direct marketing – of the same, or similar, or related products and services
  3. Targeted marketing of Steven Hunt – Alesco Development products and services to appropriate businesses
  4. Analysis and profiling for business intelligence - the responses to a marketing campaign; what are the most effective marketing channels and messages; etc.
  5. Ad performance and conversion tracking after a click
  6. Audience measurement – measuring audiovisual audiences for specific markets
  7. B2B marketing, workshop and event planning, and interaction

Steven Hunt – Alesco Development may obtain an individual’s information by various means. In some cases the data may be captured via the Steven Hunt – Alesco Development website or during networking events, workshops, exhibitions, or business intelligence gathering exercises.

Steven Hunt – Alesco Development does look to secure its hard earned reputation throughout any marketing campaign - consequently it is very careful to consider the relevance of its products and services to a data subject. All marketing subject data will be contained within the master database, Steven Hunt – Alesco Development will categorise the origins of the data in a number of lists.

The lists contained within the master database could be:

  1. Website enquiry data
  2. Website sign up to our news data
  3. Telephone or email enquiry data or
  4. Manually inputted data

The argument here is that any business or individual that has used Steven Hunt – Alesco Development’s services, has shown interest in our services or would naturally benefit from the services of Steven Hunt – Alesco Development, is of a ‘Legitimate Interest’ to Steven Hunt – Alesco Development. As such, but in compliance with the data protection and privacy structure provided by the GDPR,  Steven Hunt – Alesco Development has a compelling and reasonable right to record their data in order to promote its services.​ The data processed is not considered to be sensitive according to the guidelines of ‘Special Category Data’ and the contact would fully expect a B2B Steven Hunt – Alesco Development to process their data, in order to provide information and suggest opportunities for the marketing of their business. Due to the nature of Steven Hunt – Alesco Development’s services and products, and due to the non-sensitive nature of the B2B data collected by Steven Hunt – Alesco Development for marketing purposes, there is a minimal risk of offense to, or harm to a data subject as a consequence of their data being used for marketing the Steven Hunt – Alesco Development’s services.

In order that Steven Hunt – Alesco Development fulfils a cost effective marketing strategy, email marketing will be the preferred approach - making use of Steven Hunt – Alesco Development in-house mailer facility. Any data processed will not be sensitive, and as such will not require special protection under the GDPR.

2. The rights of the individual whose data is processed

2.1. Minimal intrusion

Following any email marketing correspondence, the data subject will be encouraged to view the Steven Hunt – Alesco Development’s Privacy Policy, where they will be able to see the legal basis on which Steven Hunt – Alesco Development relies on for gathering data. In the event that an individual feels that their data is unconnected to the business that they represent or that they do not expect their information to be used for purposes connected to the products or services of Steven Hunt – Alesco Development, they will be able to manage their subscription via the Steven Hunt – Alesco Development website Subscriptions page (accessible via the unsubscribe link on an email or via the Steven Hunt – Alesco Development Privacy Policy page).

The Subscriptions page is intended to provide a minimal intrusion experience for the data subject. Should the data subject wish to see their data stored in the Steven Hunt – Alesco Development master database, they will receive a link to their own Subscription web page, from which they will be able to unsubscribe from a mailing list or update their data. In the event that an individual would like to exercise their right to erasure, they can email This email address is being protected from spambots. You need JavaScript enabled to view it. to have it erased.

2.2. Sharing data

Steven Hunt – Alesco Development will not share its database with any other business. Steven Hunt – Alesco Development may need to make use of third party data processors in order to fulfil its marketing challenge; on these occasions, a contract will be in place between Steven Hunt – Alesco Development (the data controller) and the third party data processor - only GDPR compliant third party data processors will be used to provide these services. The contract, which is a requirement of GDPR will ensure that both parties understand their responsibilities and liabilities.

Data may need to be shared with the authorities such as the ICO during an IT or Cyber security investigation. This may be required under the GDPR following a breach of security. Another example of data sharing may be if the authorities need to investigate a subscribers details during an anti-fraud or criminal investigation.

2.3. Security measures and online safeguards

This section will focus on the security measures that Steven Hunt – Alesco Development has in place for the hosting and administration of its own website. The website is a Content Management Systems and as such is able to collect  and organise data into lists (these lists identify the origin of the data, so, subject data from an enquiry via the website, subject data from a ‘Latest News’ signup form via the website, manually entered data, etc.). The data is contained in a main database, which is hosted online. The website is hosted by a GDPR compliant hosting services provider on a Virtual Private Server (VPS) and benefits from a rigorous maintenance regime for optimal site security.

3. Summary of Steven Hunt – Alesco Development’s reliance on the ‘Legitimate Interest’ legal basis

Steven Hunt – Alesco Development takes its reputation in the business community very seriously. Almost without exception, enquiries to Steven Hunt – Alesco Development  (through various channels) are from individuals and businesses, or from individuals who are exploring a new business project. Steven Hunt – Alesco Development gathers an enquirer’s data as a means to engagement and dialogue, but also to help develop exposure. Any preliminary data captured or recorded is kept to a minimum, ie. name, email and telephone number, this information is not sensitive and is necessary to conduct business. Following their initial enquiry, the data subject is likely to receive further communication via email, relating to services that Steven Hunt – Alesco Development offers. The assumption here is that the data subject is requires services that are offered by Steven Hunt – Alesco Development and their business is likely to benefit from exposure to them - consequently, the data subject is very likely to be interested in the content of the marketing and would reasonably expect that their data will be used for relevant marketing purposes. This is also the case with data that is gathered through business intelligence and networking. Steven Hunt – Alesco Development pany does make it very easy for a data subject to manage their data via a Data Management web page and any inconvenience felt by the data subject following a marketing communication (email) is easily avoided in the future simply by following the unsubscribe link.

Occasionally an enquiry will be made which contains a personal email address - Steven Hunt – Alesco Development takes the view that a data subject that uses a personal email address for business purposes does so, accepting that their email address is in the business domain. Once again, if the data subject does feel that Steven Hunt – Alesco Development’s use of their data is intrusive, it is very easy for the data subject to unsubscribe from Steven Hunt – Alesco Development’s marketing.

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