Version 2.00. This policy was last updated on January 29th 2021.
- About this policy
- Who we are
- The personal data we collect about you
- How we use your personal data
- Who we share your personal data with
- Where you personal data are stored
- How we keep your personal data secure
- How long we keep your personal data for
- Your rights
1. About this policy
This policy explains how we collect and process personal data from and about the following groups of individuals:
- Individuals working for our customers and suppliers
- Individuals who contribute content to us such as news stories and other media
- Visitors to our website
Our objective is to ensure that you are never surprised by how your personal data has been used by us. You are therefore encouraged to read this policy. There may be other notices that apply to specific services we provide, which you should also read at the relevant time.
As our business and this website develops, we may need to update this policy. If we intend to make any important changes that affect your rights and interests, we will make sure we bring this to your attention and explain what this means for you beforehand.
If you have any questions in relation to this policy or wish to exercise any of Your rights under data protection law, you should contact our Data Protection Officer Jody Knowles by email at firstname.lastname@example.org
2. Who we are
Jam Press Limited (trading as Jam Press) is a limited company registered in England and Wales under the company number 10564468
3. The personal data we collect about you
Personal data means any data that identifies or can be used to identify a person. It does not include data where the identity has been removed (anonymous data).
The types of personal data that we may collect from or about you will depend on which group you fall into and may include:
Individuals working for our customers and suppliers and agents
- your name(s) and contact details
- your job title or role and the department/division/publication you work for
- any correspondence we have with you in relation to our contractual relationship
Individuals who contribute content to us such as news stories and other media
- your name(s) and contact details
- your bank account number and sort code or other bank account details, if we make any payment to you for a story or any other media
- your login details if you have an account for Jam Press archive (our content submission platform)
- any correspondence we have with you in relation to the content submitted by you
- biographical and other information about you and your image, where any content submitted by you relates to or includes you
Visitors to our website
- your name(s) and contact details when you contact our news desk, picture desk or our office
- any correspondence we have with you
4. How we use your personal data
We will only use your personal data when the law allows us to. We will generally rely on one of three legal grounds for using your personal data:
- where we need to perform the contract we are about to enter into or have entered into with you
- where necessary for our legitimate interests or those of a third party, provided those interests do not override your fundamental rights and interests
- where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal ground for using your personal data, except in relation to sending you marketing by email or text message. You have the right to withdraw your consent to marketing at any time either by contacting us, clicking the unsubscribe link in an email or replying to a text message with the required words notified to you in each text message.
Specifically, we will use your personal data as follows:
- contact details:to respond to your enquiry, contact you in relation to a story or media that you have contributed or administer our contract with you (as appropriate)
- bank account details:to make any payment that we have agreed to make to you
- correspondence:to communicate with you in relation to your enquiry, story or contract
- biographical information and images:to investigate, author and publish journalistic, artistic and/or literary works (subject to the exemptions noted below)
Data protection law strives to achieve a balance between individuals’ right to privacy and freedom of expression. Although we are required to preserve the confidentiality and security of personal data provided to or obtained by us, the Data Protection Act 2018 includes important exemptions from a number of data protection obligations, including the obligation to provide individuals with information about how we process their personal data, for the purposes of journalism, artistic and literary purposes.
In order to rely on the exemption, we must show that we processed your personal data (or that of a third party, where relevant) with a view to publication that we reasonably believe to be in the public interest and that complying with various obligations under data protection law would be incompatible with processing personal data for journalistic purposes.
Jam Press honours the Independent Press Standard Organisation Editors’ Code of Practice, even though it is not a member of IPSO.
6. Who we share your personal data with
We will share your personal data with appropriate members of staff within our organisation.
We also share your personal data with:
- where you are an agent or work for one of our customers or suppliers, other businesses within Jam Press, including Jam Prime
- service providers including our hosting provider and email marketing platform
- HM Revenue & Customs, the tax authority in the UK who require reporting of our processing activities in certain circumstances
- any third parties to whom we may choose to sell, transfer or merge parts of our business or assets or third parties we may seek to acquire or merge with (if any change happens to our business, the new owners may use your personal data in the same way as set out in this policy)
7. Where your personal data are stored
We do not transfer your personal data outside of the European Economic Area.
8. How we keep your personal data secure
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those within our organisation that have a need to access it. They will only process your personal data on our instructions and they are required to keep your personal data confidential.
Please note that any correspondence with us by email or telephone is not encrypted. If you have any particular concerns regarding the security of your correspondence with us, please let us know.
9. How long we keep your personal data for
We will only keep your personal data for as long as necessary in connection with the purposes we collected it for and to comply with any legal, accounting or reporting requirements. To determine how long we keep your personal data for, we consider the amount, nature and sensitivity of the personal data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.
Any email correspondence that we have had with you will be stored on our email servers, archived and then deleted in accordance with our back-up and retention policies.
If we have paid you anything, we will retain details of the transaction for a period of six years from the date of the transaction order for tax purposes.
We will retain personal data relating to email marketing data until you unsubscribe or your email address has become permanently unavailable. Once you have unsubscribed, we will keep a record of your choice indefinitely to ensure that you do not receive any further emails from us.
We may retain any data that does not identify you indefinitely.
We use various cookies on the Jam Press website
Cookies help our websites serve you a consistent and efficient experience, as well as perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as social media sharing buttons (“third party cookies”).
If you disable cookies, please be aware that some of the features of our service may not function correctly.
Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).
Types of cookie we use
The table below explains the types of cookies we use on our websites and why we use them. These vary across our suite of websites. For more information on specific site cookies, please contact us.
Description of the cookies on Jam Press website
Essential – Essential for website to perform its basic functions. These include those required to allow registered users to authenticate and perform account related functions.
Functionality – Used to store preferences set by users such as account name, language, and location.
Security – Used to help identify and prevent potential security risks (i.e. security and anti-spam software or plugins).
Analytics – Tools such as Google Analytics collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use this detail to understand how users interact with our sites.
Third Party / Embedded Content – We use a number of third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
11. Your rights
Subject to the exemptions noted above, you have a number of rights in relation to the personal data we hold about you:
Access: You have the right to request access to and be provided with a copy of the personal data held about you together with certain information about the processing of such personal data to check that are holding it lawfully
- Correction: You have the right to ask us to correct any inaccurate or incomplete personal data held about you
- Deletion: You have the right to ask us to delete or remove any personal data held about you where there is no good reason for us to continue holding it or where you have exercised your right to object
- Restriction: You have the right to ask us to restrict how we hold your personal data, for example, to confirm its accuracy or our reasons for holding it
- Objection: You have the right to object to our holding of any personal data about you which is based on our legitimate interests or those of a third party based on your particular circumstances. You also have the right to object to our holding your personal data for direct marketing purposes
- Portability: You have the right to receive or request that we transfer a copy of the personal data we hold about you in an electronic format where the basis of our holding such information is your consent or the performance of a contract and the information is processed by automated means
- Complaints: You have the right to complain to the Information Commissioner’s Office (ICO) or any other EU supervisory authority in relation to how we collect and use your personal data
You will not have to pay any fee to exercise any of the above rights though we may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, we will let you know.
To protect the confidentiality of your personal data we will ask you to verify your identity before fulfilling any request in relation to your personal data.