Glocal Media is a translation, subtitling and voiceover company based in London, Manchester and Dartford.
We work in over 200 languages in broadcast, DVD, Web or written text. We have a wealth of experience in all sectors and you can rely on our honest assessment and guidance to help you achieve exactly what you need. Offering a full range of services – with an established network of translators & subtitlers and a constant investment in the latest technologies.
This document considers the data being collected and processed by the sales team conducting inbound & outbound business development activity in London. Other areas of the business will have their own documentation. As GDPR regulations become mandatory and evolve the Glocal Media sales team will do everything to comply in order to help protect data subjects. As a result this document and our processes will evolve over time which will lead to updates to our systems and how we collect and process data.
The Glocal Media sales team consider they do not collect sensitive data and only collect data necessary to ascertain if well considered organisations and so data subjects will benefit from the integrated marketing services offered.
What data do we collect
Name of stakeholders (data subjects) in marketing / decision making roles, along with the company switchboard telephone number and where possible direct dials (landline & mobile) of data subjects involved in the profiling, qualification, discovery and where legitimate market opportunities appear from sales information.
Sometimes during early conversations prospective customers may send commercially sensitive information and Glocal Media staff have to sign Non-Disclosure Agreements.
Email addresses are also collected but presently Glocal Media team do not collect social media posts, location IP addresses or cookies. Glocal Media will follow and connect with businesses on social media platforms.
As part of the initial profiling of businesses Glocal Media may research and retain information about businesses to ensure only those approached on a legitimate interest are contacted.
Glocal Media sales team do send bulk emails to prospective prospects via ALF data which is GDPR compliant and Campaign Monitor which gives an opt out option for GDPR.
Purchased data is only acquired from GDPR compliant sources i.e.) ALF. A statement of their GDPR compliance will kept on file by Glocal Media and this data will only be processed lawfully. i.e.) to express a legitimate interest.
Where do we store the data
The Glocal Media sales team only collect data which enables them to select suitable businesses during profiling and enable a suitable dialogue to build to understand and confirm if stakeholders (data subjects) within these businesses are responsive to the legitimate interest expressed.
Glocal Media related emails are stored securely on the Glocal Media email system where any prospective client related emails with attachments are also retained. Prospective clients may also pass high density documents via secure cloud sharing systems such as DropBox etc. Such documents are deleted / stored as appropriate.
Documents are stored on the Glocal Media secure server.
Ongoing dialogue with prospective clients is retained on the secure ACT system.
How do we protect and document the data we have?
All systems above are password protected and access is strictly limited to data processors that need access. Data is not sensitive and if data were ever to become sensitive special measures would be put in place to harden security.
Data maybe processed on company and personal IT but this is protected with these machines software & operating systems being kept fully up to date and suitable virus protections being installed and kept current.
How long do we plan to keep the data for?
Data will be kept for as long is reasonable to enter into a discovery dialogue with a prospective client unless they wish to be removed / forgotten by Glocal Media.
As is standard policy if any prospective client that Glocal Media expresses a legitimate interest in request to no further contact their data is deleted and the name of the business retained on ACT CRM as a NO GO record along with reasons.
Do we have a function/ reason for every piece of data we collect?
Yes and we only collect relevant and necessary data to help profile, discover and express a legitimate interest.
What is the process if someone asks to be removed from our records?
Glocal Media outbound sales team comprises of Steve Clayton, Tina Griffin & Sophie Young. If someone asks to be removed from our records the person being notified will permanently delete all records with the exception of the business name (which is not personal data) Glocal Media outbound sales is recorded by individual business name basis so all contact with that business would be suppressed.
Glocal Media inbound sales enquiries are where a prospective client has requested information about Glocal Media services. Such enquiries often result in them becoming a Glocal Media customer but if the enquirer does not wish to proceed after receiving information or undergoing a marketing review / audit the business name is recorded and notes attached to ensure any further contact is secure & appropriate.
Statement on Glocal Media data processing
Glocal media only process personal data on a lawful basis. Glocal Media sales team only process data on carefully profiled and selected businesses and the only personal data involved are the contact details of relevant stakeholders within the business where we express a legitimate interest. i.e.) marketing manager / co-ordinator, managing / marketing director etc.
There are six available lawful bases for processing. No single basis is ’better’ or more important than the others – which basis is most appropriate to use will depend on your purpose and relationship with the individual.
The lawful basis for your processing can also affect which rights are available to individuals. For example, some rights will not apply:
Glocal Media sales team will process data using consent when a prospective client has expressed a direct interest in receiving information and engaging in sales dialogue.
Glocal Media sales team will also process data using legitimate interest as part of the agency’s business development / growth plans
Although Glocal Media do receive inbound enquiries, client referrals and recommendations we are often unable to reach businesses which will benefit greatly from our skills and experience. Glocal Media will always take steps to promote the agency via social media but it is also acceptable protocol for marketing agencies to reach out and offer to conduct marketing reviews / audits and join rosters. Most proactive agencies do this in responsible manner and Glocal Media have always followed the data processing protocols espoused by GDPR. As Glocal Media is best suited to serve large regional & national businesses it is often very difficult to reach them via networking and social media. Where Glocal Media have specialist sector / industry insight or skills which will benefit prospective clients we will use outbound sales methodology to reach prospective clients.
Glocal Media will therefore need to process data on a Legitimate Interest basis in addition to consent. Below follows the Legitimate Interest Necessity & Balancing tests for prospective client data on a global basis.
Glocal Media privacy notice will include the lawful basis for processing as well as the purposes of the processing within the footer of outbound communications.
Glocal Media rarely process special category data but if they did it would be done on a consent basis and special measures adopted. i.e.) Local council work.
Glocal Media do not process criminal conviction data or data about offences.
Legitimate Interest Assessment (LIA)
1. Identifiy a Legitimate Interest
Glocal Media are a localisation production company offering translation, subtitling and voiceover services.
The purpose of processing personal data is to be able to communicate with stakeholders (data subjects) who hold marketing related decision making roles in well profiled businesses. Such communications have historically led to the agency being placed on marketing agency rosters or asked to carry out marketing reviews / audits to assist with marketing objectives. Glocal Media only ever take on clients where there is a clear opportunity to use our skills and experience to the benefit of clients and this approach has led to significant growth for many of our clients.
Reasons why and how data is acquired & processed and clearly articulated and communicated to the individual(s)
While only one Legitimate Interest needs to be identified, all relevant interests will be considered.
Glocal Media LIA only covers relevant processing and the disclosure of the personal data. Any other agency departments or Third Parties will conduct their own LIA for their own processing purposes.
2. Carry out a Necessity Test
Glocal Media data controllers consider the processing of Personal Data done with Legitimate Interest in mind is “necessary” for the pursuit of its commercial or business objectives whilst serving and protecting only carefully profiled and selected businesses to engage with professionally. Glocal Media do not engage in bulk indiscriminate communications.
The adjective “necessary” is not synonymous with “indispensable” but neither is it as wide as “ordinary”, “useful”, “reasonable” or “desirable”.
Is there another way of achieving the identified interest?
Although social media and advertising can be used to achieve the identified interest it cannot be relied on. If it could then Legitimate Interest would not be a processing basis for Glocal media or any other commercial organisation engaged in consultative selling for the benefit of prospective clients.
Although social media & advertising may present another way it would require disproportionate effort, so we are able to determine that the processing is still necessary;
As there are multiple ways of achieving the objective, a Data Protection Impact Assessment (DPIA) should be used to identify the least intrusive processing activity; or
If the processing is not necessary then Legitimate Interests cannot be relied on as a Lawful Basis for that processing activity.
3. Carry out a Balancing Test
A Controller can only rely on a genuine Legitimate Interest where the rights and freedoms of the individual whose Personal Data will be processed have been evaluated, and these interests do not override the Controllers’ Legitimate Interest.
The balancing test must always be conducted fairly. The Controller should not attempt to make the assessment unfair or biased, and must always give due regard and weighting to the rights and freedoms of individuals.
There are several factors to consider when making a decision regarding whether an individual’s rights would override a Controller’s Legitimate Interest.
- the nature of the interests;
- the impact of processing;
- any safeguards which are or could be put in place.
The nature of the interests includes:
The reasonable expectations of the individual
Marketing professionals in commercial organisations would and should expect the processing to take place. The impact on the individual is likely to have already been considered by them and accepted. They will be able to unsubscribe at any time.
The type of data involved is described elsewhere in this document and does not fall into any special category.
Consideration in a balancing test
Q. Is it also in the interests of the individual?
A. YES – Glocal Media can help businesses and agencies with their localisation needs.
Q. If there may be harm as a result of the processing, is it unwarranted?
A. THERE IS NO HARM
The Impact of processing includes:
Q. Any positive or negative impacts on the individual, any bias or prejudice to the Controller, Third Party or to society of not conducting the processing.
A. AS THE UK ENTERS BREXIT AND CONTINUES TO FACE ECONOMIC GROWTH CHALLENGES MARKETING WILL REMAIN AN EXTREMELY IMPORTANT BUSINESS MANAGEMENT FUNCTION. IT IS CRITICAL BUSINESSES BRANDS COMMUNICATE THEIR MESSAGES AS EFFECTIVELY AS POSSIBLE AND DIGITAL MARKETING CHANNELS ARE FULLY HARNESSED. THIS WILL BE TO THE BENEFIT OF UK AND OVERSEAS / EXPORT MARKETS.
The Controller needs to carefully consider the likelihood of impact on the individual and the severity of that impact. Is it justified? A much more compelling justification will be required if there is the likelihood of unwarranted harm occurring.
GLOCAL MEDIA OUTBOUND ONLY MAKE HIGHLY PROFESSIONAL APPROACHES ONTO KEY ACCOUNT TYPE BUSINESSES WHO MAY BENEFIT GREATLY FROM SUCH CONTACT. IMPACT ON ANY STAKEHOLDERS / DATA SUBJECTS / INDIVIDUALS IS ALWAYS MINIMISED AND ONGOING COMMUNICATIONS ONLY EVER MAINTAINED WHEN PROSPECTIVE CLIENTS ARE IN AGREEMENT.
Q. The status of the individual.
A. COMMERCIAL MANAGERS AND PRODUCTION MANAGERS IN MARKETING RELATED FUNCTIONS.
Q.The status of the Controller.
A. GLOCAL MEDIA LOCALISATION SERVICES
Q. The ways in which data are processed.
A. THE PROCESSING INVOLVES PROFILING BUT NO PUBLICATION OR DISCLOSURE TO LARGE NUMBERS OF PEOPLE.
Q. Is the processing on a large scale?
A. THE PROCESSING IS NOT LARGE SCALE.
Data processing checklist
Glocal Media sales team have reviewed the purposes of our inbound and outbound sales processing activities and selected the lawful basis for each activity.
Glocal Media have checked that processing is necessary, and are satisfied there is no other reasonable way to achieve the purpose.
Glocal Media have documented our decision on which lawful basis applies to help us demonstrate compliance.
Glocal Media do not process special category or criminal offence data.
As GDPR regulations become mandatory and evolve the Glocal Media sales team will do everything to comply in order to help protect data subjects. As a result this document and our processes will evolve over time which will lead to updates to our systems and how we collect and process data.