Purple Demand generates sales-qualified appointments, discovers new leads, and nurtures long-term prospects. As a leading provider of lead generation services, we are committed to compliance with the General Data Protection Regulation (GDPR).
The purpose of this statement is to provide information regarding how and why Purple Demand process and store data, as well as providing the appropriate contact information should you wish to exercise any of your personal data processing rights under GDPR such as the right to object, the right to restrict processing etc. (Explained fully here on the ICO website).
Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed as follows:
- Consent – the individual has given clear consent for you to process their personal data for a specific purpose
- Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
- Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)
- Vital Interests – the processing is necessary to protect someone’s life
- Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
- Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful bases for processing personal data can be found at www.ico.org.uk
Purple Demand Client Contracts
Purple Demand has assessed all six grounds for lawful processing of personal data and has selected ‘contract’ as the most suitable lawful ground for the processing of data for the purposes of delivering our programmes and fulfilling our contractual obligations throughout those programmes to our clients, and for and communicating with our clients leading up to the programme, for the duration of the programme and afterwards.
Purple Demand collects necessary data for contractual reasons when delivering programmes.
Purple Demand Promotion and Inbound Enquiries
When you send Purple Demand an enquiry or booking form via our website or by email or letter you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Purple Demand services and news that we feel may be of interest to you, it is deemed that as you have visited the Purple Demand website and provided us with your contact information that you are legitimately interested in our services and related information. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.
How we procure Data for the purposes of marketing Purple Demand services:
We procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’
- You have requested information from Purple Demand on a previous occasion
- Someone has sent us your e-mail address requesting information about our services be sent to you
- You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
- We have previously met at an event and your business card or contact details were handed to us willingly
- You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
- You have previously connected with a member of our team via LinkedIn regarding our company and / or our services
- A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in Purple Demand services, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product
PURPLE DEMAND – Lead Generation Service
Purple Demand processes information in 2 ways. The first is for the purposes of promoting itself (please see section above) and the second is for the purposes of promoting the products and services of its clients.
For the purposes of promoting the services of Purple Demand’s clients:
As an organisation that works, on behalf of our clients, solely with other businesses (i.e. not directly with the general public), Purple Demand has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of communicating our marketing and sales messages to the target organisations we wish to work.
Purple Demand’s clients provide data for a specific ‘Campaign’, we then collect, process and store data relating to businesses and decision makers on behalf of our clients, until ‘Campaign’ completion. We believe that the individuals that we process the data of, are likely to have an interest in the service/product pertaining to this ‘Campaign’. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical segmentation includes those at ‘B’ and ‘C’ level within B2B organisations across most Industry Sectors (tailored to suit the product/service of our client’s ‘Campaign’) including IT Directors and Managers and Finance Directors and Managers although this list is not exhaustive and other variables may apply.
We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, direct dial contact numbers, mobile numbers, business postal address and occasionally social profiles (e.g. LinkedIn). Other business-related data may also be processed including business name, job function, and turnover, however we will never collect further personal data such as those classed under ‘special category personal data’.
The data collected will be used to communicate marketing and sales messages relating to Purple Demand’s client’s services/products, based upon the job function held by the data subject. Purple Demand specifically only contacts those we believe are likely to be interested in Purple Demand’s client’s services and based upon their job function within that organisation. Messages from Purple Demand are typically delivered via telephone, or via email. These contacts have the right to object from any method of correspondence at any time, by informing the telephone operator, using the unsubscribe button on an email, or by contacting us via any of the methods below.
How our clients Procure Data
We procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’
For the purposes of conducting ‘Campaign’ on behalf of our clients:
- Data has been purchased by a registered third-party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer (Due diligence checks around GDPR compliance will have been conducted accordingly)
- Data has been supplied from our clients’ CRM systems, based upon their typical target customer profiles and these are checked against a Legitimate Interest Assessment – see below.
- A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in services of Purple Demand’s client, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product
Legitimate Interest Assessment (LIA)
Where Purple Demand’s client has supplied data from their internal systems, Purple Demand will request that an Legitimate Interest Assessment (LIA) is carried out by the client, as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding the ‘Campaign’ and that in no way would a data subject be caused harm by our correspondence. Based upon the segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Purple Demand in a sales capacity, could be legitimately interested in Purple Demand’s client’s ‘Campaign’. It is also deemed that sales is necessary in the context of promoting Purple Demand’s clients ‘Campaign’ to professionals in business in order to increase awareness of our clients products and services in the marketplace.
Per the ICO guidance, Purple Demand can confirm that we have working with our clients to show:
- We have checked that legitimate interests is the most appropriate basis
- We understand our responsibility to protect the individual’s interests
- We have conducted a legitimate interest assessment (LIA) and kept a record of it, to ensure that we can justify our decision
- We have identified the relevant legitimate interests
- We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
- We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
- We only use individuals’ data in ways they would reasonably expect
- We are not using people’s data in ways they would find intrusive or which could cause them harm
- We do not process the data of children
- We have considered safeguards to reduce the impact where possible
- We will always ensure there is an opt-out / ability to object
- Our LIA did not identify a significant privacy impact, and therefore we do not require a ‘Data Protection Impact Assessment’ – DPIA
- We keep our LIA under review every six months, and will repeat it if circumstances change
- We include information about our legitimate interests in our privacy notice
Purple Demand has an in-house data team, who are responsible for ensuring the validity and quality of the data contained within the Purple Demand system. Any records found to be out of date are updated or deleted on a regular basis by the Data Team.
UK Data Storage
The data held within the Purple Demand’s CRM system is processed and stored within a secure environment, provided by our suppliers.
Right to Object / or Restrict Processing
In all communication with contacts, we will give you the right to object from receiving further correspondence from Purple Demand’s clients. The request will be viewed within the boundaries of the particular Client that Purple Demand is calling on behalf of. On any emails you receive from Purple Demand, on behalf of our clients, there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you receive a telephone call from us, on behalf of our clients, you have the right to request not to receive any further calls. Purple Demand has a companywide CRM system, your request to object will be logged within our CRM system to ensure that you do not receive further communication from Purple Demand on behalf of the subject client. Our client will also receive the details of your request, so that they can update their own CRM system.
Request for Deletion
It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from the Purple Demand CRM system and this will also be passed onto our clients. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from Purple Demand client’s products/services. If you do not wish for us to contact you again with our client’s sales and marketing messages, we would recommend you use the right to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days.
This privacy statement was last reviewed and updated on the 20th October 2022. Policies are periodically reviewed to ensure compliance with the current compliance environment.
For questions relating to this policy please contact us.
Contacting Purple Demand Regarding Your Data Processing Rights Under GDPR
Should you wish to object to receiving communication from Purple Demand, or exercise any of your other rights under GDPR you can do so in a variety of ways:
- Please click the ‘unsubscribe’ link at the bottom of any email
- If you have received a call, please tell the representative that you do not wish to receive any further communication
- Please call 0203 701 1229 and ask to speak with Purple Demand Marketing
- You can also make your request by emailing email@example.com
- Or by writing to: Purple Demand, 1st Floor, 5 Theale Lakes Business Park, Moulden Way, Sulhamstead, RG7 4GB.