Privacy policy
GDPR policy — data privacy notice
This document provides details of International Correspondents in Education or ICE's GDPR data privacy policy.
It is a 'live' document and will be updated as new information becomes available.
The purpose of this policy is to explain to you how we control, process, handle and protect your personal information, including your rights under current laws and regulations.
Business overview
ICE is a small company with three main areas of business:
journalism and all forms of writing, usually in English
editing, especially of non-native English
translating.
ICE is a Spanish company, registered in Barcelona. ICE will be what is known as the controller of the personal data you provide to us.
What data do we collect?
Client information: contact names, job titles, addresses, email, contact number, web addresses, billing information
Contributors to writing, editing and translating projects: names, job titles, education & work history, qualifications & skills, addresses, email, contact number, web addresses, bank details for payments
We do not collect sensitive personal data (health, sexual orientation, dates of birth etc).
How do we collect data?
We collect data in the following ways:
data is supplied by data subjects interested in an assignment
through email contact and on-line agency contacts (e.g. LinkedIn etc)
business to business contact scenarios (conferences, trade fairs, meetings etc)
introductions and recommendations.
Why do we collect your data and what do we do with it?
We collect and use data for normal business activities:
to complete our projects and comply with contractual obligations
to research stories for journalism assignments
through documents and content supplied to us as part of our work (i.e. texts for translating and editing, background material for research and writing assignments)
to put together teams of freelance professionals for assignments or public tenders
to market our services to new and existing clients
to invoice our clients, pay our suppliers and complete our annual accounts.
We do not sell or trade data, neither do we make automated decisions or do profiling based on the data we hold.
We will share data if required to do so by law (i.e. by the police or as part of a legal process) or as part of our regular accounting activities (i.e. invoicing and payments).
We will only pass data on to third parties for the purpose of securing assignments, contracts or for other business proposals if we have the written permission of the data supplier.
We do not share data with any countries outside of the EU.
What are our legal bases for processing data?
Under GDPR, we control and / or process any personal information about you using the following lawful bases:
Lawful basis: contract
The reason we use this basis: processing is necessary to fulfil a contract that the data subject has asked for such as providing a service or processing an invoice.
Data retention period: We shall continue to process your information until the contract between us ends or is terminated under any contract terms. In order to comply with ICE's legal obligations, we will keep accounting information including invoices for five years.
Sharing your information: We only share your personal information with our accountants for the purpose of preparing company accounts and satisfying our tax obligations.
Lawful basis: legitimate interest
The reason we use this basis: processing is necessary for the purposes of the legitimate interests of the data controller, these interests are generally aligned with those of the data subject.
Data retention period: One year for data which is less relevant to our business (CVs supplied by professionals not relevant to our services, quotes which are not accepted by clients). Five years starting from the date of the last assignment or business proposal for data such as CVs which are more relevant to our business interests. All email correspondence is kept for five years.
Sharing your information: We occasionally share your personal information with third parties. These may include partner organisations for the purpose of preparing a business proposal, potential clients when pitching for work or competing for a contract. We only do this with the written consent of the data subject.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We will stop processing your personal information if the lawful basis used is no longer relevant.
How do we store data?
Our email contact lists are stored in our webmail system hosted by Heart Internet, our data is backed up by idrive's cloud-based system. We are confident both are fully GDPR-compliant. All our computers and devices are password protected with antivirus software installed.
Your right to access your data
You may contact ICE at any time to request a copy, rectification or erasure of your personal data. We will take action without undue delay and in any event within one month of receipt of the request.
Your right to lodge a complaint
Should you have any concerns about how we process your personal data, please contact Rebecca Warden via rwarden@ice-online.net. You also have the right to lodge a complaint with the supervisory authority in Spain (www.aepd.es) or in the country where you live.