GDPR Data and Information Policy
We are extremely transparent about how we hold and use data.
The information we hold is:
- Information enabling us to run their marketing campaign. Including names, phone numbers, email addresses, business address (or home address if working from home)
- Website logins (where supplied)
- Social media logins (where supplied)
- Domain and hosting logins (where supplied)
- Advertising account logins (where supplied)
- Analytics logins (where supplied)
All of this information is gathered from the client in a Kickstart Questionnaire sent to them at the start of the campaign. It is hosted inside various spreadsheets in Google Drive, which the staff working on the campaign have access to.
Elements are also kept inside Infusionsoft (our CRM), Xero (our accounting software), Teamwork (our Project Management software), and Slack (our chat software). Their data processing terms and conditions are available on their websites.
Leads and Contacts
If you request a marketing review from us, sign up for free book updates, register to ‘join the dojo’ and receive our marketing training, or enquire about using our services, we will retain some or all of the following data:
- Address (if purchased)
- Email address
- Phone number (if provided)
- Declared business information, including target turnover
This information is collected through:
- Our website:
- The free marketing review questionnaire asks visitors for the information necessary for us to carry out the review
- Book update forms allow people to sign up with their name and email address to receive future book updates
- Join the Dojo allows people to sign up for our email list to receive tips and advice
Lead information is shared between staff members responsible for sales, marketing, and accounting.
We always make clear on email capture forms that the data we collect will be used for follow up marketing (“Join the dojo”). On Kickstart Questionnaires and other forms, we specify how the data submitted will be used.
On all forms, we make it clear that consent can be withdrawn at any time by contacting us.
The basis for processing client data is Contract. The basis for processing lead/contact data is Consent and/or Legitimate Interest.
Data and Privacy Notice
We store the data you submit to us in our email marketing software so that we can send you relevant information and training to help you with your marketing.
You can remove your consent to receive this information at any time by clicking the link at the bottom of the email. If you would like to be ‘forgotten’ and have your data erased, simply reply to any email from us requesting this and we will handle this for you within 3 working days.
Exposure Ninja only collects and stores information from clients necessary for us to carry out the marketing work that we are required to carry out. This information is available to the team working on the campaign and other staff in the company who might need it for the purposes of accounting, administration or helping with the marketing work.
We also collect and store information from contacts and leads in order to provide relevant marketing training, advice, and sales recommendations. This information is available to staff across the company.
The information we store about each client or contact is available to that client or contact on request, and we will delete any data when requested by them.
All client or contact information is held only in the designated cloud software applications (Google Drive, Infusionsoft, Gmail, Slack, Skype, 8×8, Teamwork, Teamwork Desk). Information and data should never be stored locally on staff computers in documents not controlled by these cloud apps, and the Ninjas receive training on the importance of not storing data locally.
Risks and Impact Assessment
- Risk: Staff computer or account hacked, and contact information accessed
- Impact: client data leaked and shared online. Potentially websites hacked and personal data leaked.
- Mitigation: where possible, data is stored in cloud services like Google Drive which have login protection and two-step verification when accessed from new locations or IP addresses. Staff required to change all passwords every 3 months.
- Risk: Staff member leaves and takes personal data with them
- Impact: client data leaked and shared online. Potentially websites hacked and personal data sold
- Mitigation: offboarding process which quickly removes access once staff member is terminated.
All staff are trained on the following:
- Password and account security
- Data handling (including data storage methods and types of data to never store)
- Device security
A data breach can be something which leads to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
If any staff members notice that this has happened they are required to immediately notify their manager. Following notification of a breach, we will:
- Assess the impact of the breach
- Notify the relevant parties immediately
- Investigate the cause of the breach
- Rectify any security vulnerabilities or processes to minimise the chance of this happening again
Right of Access
If an individual requests access to their personal data, this request is to be immediately passed to the Data Protection Officer (Tim) who will:
- Confirm the data being processed
- Provide full access to their data stored in our various softwares, via email.
We will respond to all such requests within 1 month.
Individuals have the right to be forgotten and can request that their data is erased. We will erase all records held for that individual/company including:
- CRM records
- Campaign documents and files
- Slack channel
Data Processor Contracts
We have written contracts with our data processors governing the processing of personal data.
Data Protection Impact Assessments
We conduct DPIAs whenever we add a new piece of software to our workflow which will store or process personal data. These have a description of the processing operations and the purposes, and assessment of the necessity, risks, and details of the controls put in place to reduce these risks.
Information Security Policy
Every staff member is required to adhere to this policy and to abide by our data guidelines:
- Personal data must not be stored on your personal devices
- Passwords must be changed on the three-monthly cycle and at any other time when management requests
- No data should be collected and retained other than what is necessary to carry out the work that has been requested of us
- Any requests for access to data, requests to be forgotten, reports of a breach, or any other matter relating to management of or access to personal data should be immediately passed to Tim Cameron-Kitchen at firstname.lastname@example.org.