Who we are
Communisis Data Intelligence (CDI) is part of the Communisis Group. For further information on the Communisis Group, please click here to see the relevant privacy notice.
CDI work with a variety of organisations to assist them in their marketing campaigns and help them communicate with their customers more effectively. Our main goal is to ensure that the data we process is accurate and up to date, and that you receive direct marketing relevant to you. We regularly update our database to make sure it is accurate. This not only helps us to meet the accuracy principle of the UK General Data Protection Regulation (UK GDPR), but it also ensures that you don’t receive material that is not of interest to you.
Organisations use our database to assist them in their own marketing campaigns, which may be directed towards new or existing customers. Our database may hold information that they may not have access to, such as if you’ve changed address recently.
If you have any questions about how we use your personal data, you can contact us here:
Communisis Data Intelligence
What personal data do we process about you?
- Contact details – Your name, address, email (this could also apply to ‘Director’ details, which are publicly available via Companies House).
- Household/demographic details – Your D.O.B, marital status, number and age of children, homeowner status, car owner status, pet owner status.
- Occupational & financial details – Your salary, occupation, credit card owner.
- Insurance details – Details about any home, motor, travel, or pet insurance. This includes information such as the month of renewal.
- Preferences – Details about your travel and reading habits. This includes information such as which national newspaper you may read, and which destinations in the world you may be likely to travel to. We also process preference data such as shopping habits and likelihood of donating to charity.
- Profiling – Creating pools of potential interested customers based on shared characteristics. We only do this when requested by one of our clients. The purpose of profiling is so that our clients can communicate with you more efficiently. More information on profiling is explained below.
We don’t process or store any special category data. This is information relating to your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, sex life and sexual orientation.
How do we obtain your personal data?
We obtain most personal data from one of our trusted third-party marketing vendors. We don’t obtain it directly from you. We conduct thorough checks on our suppliers to ensure that they have obtained the data appropriately and that individuals are informed about how and why their personal data may be used.
In most cases, this data will have been originally collected directly from you through surveys or competition sites and then ultimately passed on to one of our suppliers. We then obtain your personal data from our suppliers. We have reviewed the ‘supply chain’ of this data to ensure that fairness and transparency are present throughout and we continue to do so.
We may also obtain your personal data from the following sources:
- Royal Mail ‘Postcode Address File’. This is only used for checking the accuracy of an address.
- The Software Bureau. This company supplies ‘SwiftCleanse’ which can check for deceased, ‘goneaways’, home movers for new addresses.
- Companies House ‘Director’ register. This is publicly available and contains the address details of company directors (where they have opted-in to the register).
What is profiling?
There are many different uses for profiling, however it’s important to note that in the context of our business we only use profiling to increase the accuracy of our clients’ marketing campaigns. Profiling simply means looking at a key characteristic, and using this to find people who are likely to share this characteristic.
For example, a client may ask us to find people within a certain age bracket who share similar reading habits. Profiling allows our clients to reach the people who are most likely to be interested in their service or product and reduces the chance of people receiving marketing communications that have no relevance to them.
Here’s some additional information on profiling:
- We only use profiling to help our clients reach people likely to be interested in their service/product. We do not carry out any ‘ad-hoc’ profiling, or any profiling for our own use. We only carry out profiling when requested to do so by a client.
- Profiling involves understanding what characteristics make a ‘typical’ customer for our client, and then using the data on our systems to find potential matches.
- We don’t take any decision in respect of this data; we simply provide it to our clients.
- Alongside profiling we may undertake modelling to further aid our clients in reaching potential customers through their marketing activity. For example: models to predict the likelihood someone will be interested in our clients’ products/services through to segmentation models that can be used for tailoring communications. When these activities are required the analysis and modelling is performed using pseudonymised data.
- Segmentation involves aggregating groups of individuals/households together based on similar characteristics in order for our clients to tailor their marketing activity accordingly to those segments.
Any messages relating to these segments will be sent by our clients.
It is possible that some of the data we receive from our third-party suppliers may have already been profiled to some extent.
How do we keep your personal data accurate?
We take our data protection responsibilities seriously, which is why we purge and refresh our database every month. This deletes and cleans all of the data out of our system every month, and then replaces it with a fresh import. This allows any changes in the data (such as a person moving home) to be picked up as soon as possible.
We also use suppression files, such as the Mail Preference Service, to ensure the data has the most up-to-date contact permissions attached to it.
We do these to meet the accuracy principle of the UK GDPR.
Who do we share your personal data with?
We mainly share your data with our client base, and only when they request it. We have a range of clients in the following sectors:
- Leisure and tourism
We also may conduct a ‘health check’ report on behalf of a Communisis UK client. When agreed by the client, Communisis UK share the client’s file with us so that we can match it against our own database. We produce a report that highlights how accurate the client’s data file is and share this with them. We don’t share any personal data as part of this report.
Should the client wish to update their records we would then share this output with the client that flags deceased and home movers. This allows the client to understand if their current data is accurate.
How contact is made
We only process and store personal data for the purposes of direct marketing. We provide accurate address details to our clients; we don’t send any direct marketing for our own purposes.
There may be occasions however where Communisis UK carries out both the printing and sending of postal marketing messages, however this is always at the request of a client. In these situations, Communisis UK is a data processor acting on behalf of their client, the data controller.
What’s our lawful basis under the UK GDPR?
We process your personal data for the purposes of direct marketing under the basis of ‘legitimate interest’ (UK GDPR Article 6 (1) (f)).
We use this basis where our use of your personal data doesn’t override your rights and freedoms, and where we believe you would have a reasonable expectation that your data would be used in this way. We also consider the interests of our clients in their marketing activities reaching the relevant audience.
Is my personal data transferred overseas?
No, all personal data is processed within the UK.
What rights do I have over the use of my personal data?
You have the following rights in relation to the processing of your personal data:
- To be informed of how and why we process your personal data. This privacy notice covers our core processing activities.
- Ask that we amend any inaccurate (or incomplete) data about you.
- Object to certain uses of your personal data.
- Ask that we temporarily restrict the processing of your personal data. We would generally apply this when we need to investigate further.
- Ask that we provide you a copy of your personal data.
- Ask that we erase or delete certain personal data.
- Withdraw any consent that you have given us (please note that as we don’t collect personal data from you directly, this is unlikely to apply to us. In these circumstances, we would recommend contacting the coupon/competition site where you originally provided your details).
- Ask that we provide a copy of your personal data in common machine-readable format (such as CSV).
Please note that we don’t conduct any ‘automated decision making’ as defined by the UK GDPR, so rights in relation to this type of processing wouldn’t apply.
How to complain
If you have any questions or concerns about how your personal data is being processed, please contact firstname.lastname@example.org.
If you are not satisfied with the response we give you, you have the right to make a complaint to the Information Commissioner’s Office, the UK regulator. Further details can be found here: https://ico.org.uk/