GDPR (General Data Protection Regulation) applies from May 25, 2018. The Munro Agency is committed to having had introduced all appropriate and necessary changes in the app, on the website, and on the blog by that time. Here’s what The Munro Agency will do to comply with the regulation, and what The Munro Agency users need to know about GDPR.
The Munro Agency sets out to meet all the GDPR requirements that relate to protecting the privacy concerns of our app users, website and blog visitors, as well as email lists subscribers.
Here’s what we are going to do before the regulation becomes binding:
The Munro Agency is defined as:
1) data administrator in relation to The Munro Agency users and email lists subscribers;
2) data processor and data sub-processor in relation to the data owners whose personal data is uploaded to third party systems offered by The Munro Agency and used in emails sent from third party systems and by its users.
It means that as a company, we oversee a couple of matters:
The Munro Agency undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed sub-processors that will or may have access to or process Service Data. please find a list of all suppliers we have checked in our GDPR Supplier Check.
The General Data Protection Act (GDPR) is being introduced by the European Union to regulate how personal data can be processed. It’s intended to reinforce data protection of the people who live in the EU.
EU data protection rules haven’t been updated for over two decades. There are at least two reasons why the EU legislative branch decided to improve the existing data protection regulations.
GDPR is supposed to protect natural persons and their rights. It does not protect businesses, entities or organisations, and processing of their data.
It protects processing personal data, such as name, age, address, phone number, but also indirect identifications that influence their identity including physiological, mental, physical, genetic, economic, cultural and social identity. Basically, any information based on which one can identify the individual.
‘Processing’ relates to personal data “collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction,” as in Article 4 (2) of the regulation.
To safely and legally process personal data in the light of GDPR, you should abide by several principles. Those are lawfulness, fairness, transparency, adequacy, relevance, limitedness, accuracy, storage limitation, integrity, and confidentiality.
Below you will read about how The Munro Agency abides by those principles and what actions you should, or shouldn’t, take to use The Munro Agency in accordance with GDPR.
As data administrator, you should make sure your actions are transparent and the purpose of processing data is legitimate. It means you should be always able to prove that you had legitimate reasons to process personal data of EU citizens. You also need to be able to describe the whole process of obtaining the personal data you use.
As a data processor, The Munro Agency processes only the data necessary in relation to the purposes for which it is processed. We do not collect or process any sensitive data such as gender, race, ethnic background, political views, etc.
The Munro Agency processes its users’ data as long as they have a The Munro Agency account (either trial account or a premium account), or until they express their wish for their personal data to be removed from our user base.
Munro Agency users can also request deletion of their data by contacting the support team at support[at]munro.agency
If, at The Munro Agency, we decide to contact an EU citizen, who has not been a Munro Agency user or email list subscriber, we will do so only if we have a clear reason to claim that this is a contact relevant to our business purposes, and that at the same time, this contact could be beneficial to the contacted person.
If a person asks us to stop contacting them, The Munro Agency we will always respect that request and stop further contact immediately.
As data administrator, you can process personal data of EU citizens who have granted you permission to process their data by subscribing to one of your mailing lists. GDPR does not forbid cold emailing though, as long as you follow the data processing rules described in the regulation.
If you decide to contact a person who has not subscribed for email correspondence, and has not been in any business relationship with you before (cold email), you should have a clear reason to claim that this will be a contact relevant to your business purposes, and that at the same time this contact could be beneficial to the contacted person. If you place an offer in your cold email, the offer should be logically connected to the specifics of your prospect’s business.
You are required to inform your cold email recipient that you’re processing their data and how you process it. The email should also contain a clear and easily available information about how your prospect can request change or removal of their personal data.
You are obliged to immediately stop contacting prospects who expressed their wish not to be contacted again. If a prospect of yours demands that their data gets removed from your contact lists, you are obliged to remove it (in accordance with the ‘right to be forgotten’.)
You should process only the personal data that are necessary in relation to the purposes for which you process it. That means you should remove from your contact base all the personal data that are irrelevant to your email campaign, or be able to justify why a specific type of data is necessary for the goal you are trying to accomplish.
The Munro Agency will keep every user’s personal data no longer than it’s necessary for the purposes for which the personal data are processed. At the same time, each data owner can request an exact time limit of their data processing.
As data administrator, you need to make sure you don’t keep personal data of your prospects longer than it’s necessary for the purposes for which the personal data are processed.
In case of cold email campaigns, you shouldn’t process a non-responsive prospect’s data longer than it may be assumed to be necessary, namely one month after you tried to contact the person for the first time. That means you should always keep your prospect base updated.