The General Data Protection Regulation (GDPR) is a European Union (EU) privacy regulation that was signed into law in April 2016. By May 25th 2018, businesses worldwide need to comply with this regulation.
This document has been produced by Advertising Analytics to help you deliver the undertakings required by GDPR, whilst also being able to work effectively and monitor your advertising performance.
An important aspect of GDPR is obtaining informed consent for the use of certain personal data. This consent should be given freely and specifically.
What personal data does Advertising Analytics process?
Advertising Analytics processes the following four pieces of data that are defined as “Personal”:
All are covered by GDPR.
1) CLI – Caller Line Identity: This is the callers telephone number.
This could be a personal landline, mobile, or a shared business telephone number.
2) IP Address: This is captured whilst using the Vision product.
3) Voice Recordings: If you have call recording enabled on your account, we will record all calls that are delivered via the Advertising Analytics system.
Call recordings are covered under GDPR due your voice being unique, and the fact that personal data can be recorded as part of you and your client’s interactions. You may need to review the types of calls you receive and decide:
- a) If call recording is required.
- b) Whether listening should be limited to authorised personnel within your business only.
- c) Whether you should add / change any announcements at the beginning of the call.
- d) The length of time you should store voice recordings.
4) CLI Data Mapping: Using the presented CLI (landline only), Advertising Analytics can attribute the call to the following information using the callers telephone number. In the example
below, we have used 01908 000000.
Region: Area of the UK that the call originated. 01908 000000 = South East.
ITV Region: The Television region. 01908 000000 = Anglia.
County: The County the call originated. 01908 000000 = Buckinghamshire.
Postcode: The 1st part of the postcode using the full number = MK5 for example.
Town: The Town the call originated from = Milton Keynes.
Exchange: The telephone exchange the call originated from = Milton
Keynes. For mobiles, we can provide the mobile exchange (e.g. Vodafone).
5) Consent to acquire, store and process data
The major change GDPR brings is that the failure to Opt-Out does no longer constitutes consent. Visitors to your website need to Opt In
6) How to make your website compliant?
GDPR Transparency means that businesses need to disclose what personal data is being tracked via the website and it is used. This also includes what is tracked by cookies or Google Analytics. You may wish to add a statement to your website
" Company XXX takes full responsibility for, and ensures, that it will not infringe or breach any applicable law by which it is bound including, but not limited to; UK legislation, including the Data Protection Act 1998 and any OFCOM or FSA regulations and PCI-DSS compliance relating to the use of the services or the recording of telephone calls."
6) As a Processors Advertising Analytics captures Controller incoming calls and records them on a platform for them to use. Each Controller has their own access to the platform which is restricted with a username and password and each username has access controlled depending on their level within the Controller company and it is set by the Controller company.
7) The Data Captured by the Processor is as follows:
- Incoming calls and recordings of the calls from customers identifying their telephone number, this data is used for the Processors .to be able to track the call trends and for their own marketing purposes.
- Each client can chose not to have their call used for this purpose and the call can be deleted from the system at any time or not recorded at all.
This document contains general information in relation to on-barding matters. The information is not advice, and should not be treated as such. The legal information is provided “as is” without any representations or warranties, express or implied. Advertising Analytics Ltd makes no representations or warranties in relation to the legal information. You must not rely on the information set out here as an alternative to legal advice from your lawyer or other professional legal services provider. If you have any specific questions about any legal matter you should consult your attorney or other professional legal services provider.