Tim Cobb Consulting
Tim Cobb Consulting is a philanthropy, communications, marketing and alumni relations consultancy business. The business is a sole tradership.
Tim Cobb Consulting (TCC) and processing data
TCC processes personal data which relates to its (i.e. my) clients’ alumni, donors and other supporters and potential donors and supporters. TCC also processes data about people who work for clients and potential clients as well as others with whom TCC has or had a business connection.
The legal status of data given to TCC by a client is controlled by a contract between TCC and the client. This determines how personal data passed to TCC by the client may be used. TCC will only use this data in the way in which the client has requested. In that respect, TCC acts as a Data Processor as defined in the Data Protection Act 1998, and from May 25 2018, the GDPR. Ultimate control of the personal data remains with the client.
Sometimes work conducted by TCC requires the collection of additional data from people who I meet in the course of a contract with a client. In that respect, TCC acts as both Data Processor and Data Controller.
TCC also acts as a Data Controller in respect of data it holds on people who work for its clients and potential clients, as well as others with whom TCC has a business connection.
When TCC processes data as a Data Controller I rely on three grounds for lawful processing.
- For the purpose of administering contracts with clients, to the extent that I process personal data I do so because it is necessary for the administration of a Contract.
- For marketing and other promotional activity, I process data because it is in the Legitimate Interest of TCC unless the law requires me to obtain your Consent; in which case I will only process data with your consent.
- When carrying out client activity normal practise is to seek Consent to process data, for example, to make interview notes if conducting a feasibility study. In some cases, and especially before meeting someone I am, or may be, seeking to interview, I will process data because it is in my Legitimate Interest to do so in order properly to advise my client.
Please see “your rights” below for details of what Legitimate Interest and Consent mean in this context, and your rights associated with either of terms.
Data held by TCC is kept securely. In particular, portable devices (e.g. smartphone/tablet/laptop) are password and fingerprint protected. My tablet and phone are both capable of being erased remotely should they be lost or stolen.
What data does TCC process?
In carrying out my work as a consultant as described previously, TCC holds data, whether as a Data Processor or Controller, which helps me to understand a person and their relationship with the organisation they support or may support.
This information may include:
• Basic personal details, including name and age;
• Contact details;
• Nature of the relationship with the client, including information about past giving to the client and hoped for future giving;
• Financial, business, family and networking information since this often has a material impact on the way in which the person pursues their philanthropic interests;
• Educational information and affiliations to organisations which are in the public domain;
• Notes of meetings, correspondence and conversations which TCC may have with the data subject.
In carrying administrative and marketing work for TCC, information I hold includes:
• Employment and contact information;
• Communications preferences.
What does TCC do with the data?
In general terms, TCC uses data to provide both general and specific advice to clients on the planning and implementation of fundraising, alumni and supporter relations activities. This may include statistical analysis of data provided to or obtained by TCC.
If I am carrying out interviews with donors and potential donors and supporters, I ask a person’s permission to take and to keep notes of our conversation(s) and correspondence. I ask the person to tell me what I may disclose to the client and what I may not. I may securely retain the notes following the close of a particular contract with the client as these are useful to the client should they choose to work with TCC again. It is also important for me to know with whom I have met in order that I can properly respect the relationship between a particular individual and the client(s) with whom that person interacts.
In pursuit of the business interests of TCC I use personal data to manage the contractual relationship with clients and to send news of interest about TCC and its services and about broader areas of interest to clients. This may be done by post, telephone or email.
Those who provide TCC with email addresses via the TCC website will be sent e-news information from time to time. If you wish to be removed from receiving emails please send a request to firstname.lastname@example.org or write to me at the address below.
To whom does TCC disclose information?
- In its capacity as a Data Processor TCC will never disclose any personal data to a third party unless the client to whom the data belongs requests or permits TCC to do so in writing.
- In its capacity as a Data Controller TCC does not pass control of personal data to any other organisation except with the consent of the individual data subject, unless required to do so by law.
TCC may use email or cloud-based data storage services based outside the European Economic Area. In such circumstances TCC will always ensure that adequate protection is in place such that data is secure. Data will always be transferred to, and stored by, such services in an encrypted form.
How long does TCC retain information?
- In its capacity as a Data Processor TCC keeps information for so long as the contract with a client requires.
- In its capacity as a Data Controller TCC keeps information for as long as is necessary to carry out my work as a consultant (as previously described). In respect of interview notes I and the data subjects often find it very helpful if we have a record of discussions that took place between us even many years earlier. If a donor wishes me to remove this information I will of course comply with that request, simply contact me by mail, phone or email.
- For administering my business, I retain personal data while clients are working with TCC and for a reasonable time and until such a time as repeat business seems unlikely. A data subject may ask to be removed from the TCC database or from the receipt of communications at any time, by mail, phone or email.
You have a number of rights in respect of your data:
• If TCC is processing data with your consent then you have the right to withdraw that consent without prejudice.
• If TCC is processing data because it is in the Legitimate Interest of TCC to do so then you have the right to require us to stop such processing.
• You have the right to request a copy of any data TCC holds about you.
• You have the right to complain about the way in which TCC processes your data, by writing to the address below.
• You also have the right to complain to the Information Commissioner about the way in which TCC has processed data. Contact details are at www.informationcommissioner.org.uk
Tim Cobb Consulting
41 St Judes Avenue
NOTTINGHAM NG3 5FG
Tel: +44(0)7787 505630