and Complaints Policy
Reviewed: September 2020
BriteVox Limited understands that your privacy is important to you and we are committed to safeguarding the privacy of anyone who provides personal information to us, including the collection and processing of personal data on behalf of our clients and visitors to our website www.britevox.co.uk. This policy sets out how we will treat your personal information.
What Is personal information?
Personal information is any information about you that enables you to be identified. it is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (Data Protection Legislation) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
What information do we collect and how this is used?
Processing of personal data for our clients
BriteVox is engaged by clients to provide customer and supporter acquisition services. In order to do this BriteVox will process data on behalf of its clients, whereby the client is the Data Controller and BriteVox is the Data Processor.
We will ensure we will only share any personal data to third parties which provide services necessary for the processing of the data, and which have been approved by the Data Controller.
We will not sell any personal data or use it for any other purpose than what has been agreed and consented to, and we will only retain this personal data for the period of time agreed between the clients as necessary and for a maximum of 12 months.
Processing of personal data of contractors and subcontractors
In order to conduct its client campaigns, BriteVox will engage marketing companies and their respective personnel and contractors and will vet and approve brand ambassadors to represent its clients. BriteVox and its contracted marketing companies will be joint Data Controllers for this personal information. In addition to this, BriteVox may from time to require additional information in the form of questionnaires from subcontractors to fulfil health and safety requirements.
We will be required to share vetting information and when relevant information from questionnaires with clients or suppliers of BriteVox based in the UK as part of the vetting process and campaign management and will limit this to what is required.
This personal data will be retained for a maximum period of 6 years.
Personal data from website users
We will acquire information about your computer and your visits to our website (information such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation)
We will use your information to
- administer the website;
- improve your browsing experience by personalising the website;
- enable your use of the services available on the website;
- provide third parties with statistical information about our users – but this information will not be used to identify any individual user
Please note our website may contain links to other websites, and we have no control over how your data is collected, stored, or used by other websites. We advise you to check the privacy policies of any such websites before providing any data to them.
Personal information if you contact us directly:
We will receive information that you choose to provide to us if you contact us with an enquiry (information such as your name, email address, contact number, address or employer).
This information will be used to deal with the enquiries and /or complaints made to us, or to provide information to you which you have requested. We may be required to share this information with clients or suppliers of BriteVox based in the UK, if you are contacting us in relation to a product or service offering you have taken up with them via us, or if their actions have caused you to contact us.
If any of your personal information and data as above is required by our clients or suppliers as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
In some limited circumstances, we may be legally required to share certain personal information, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
Personal data will not be retained for any longer than is necessary and any emails containing personal information will be deleted after 6 years after the subject matter of your email has been resolved.
What are your rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data.
- The right to access the personal data we hold about you.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- The right to restrict or prevent the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us at firstname.lastname@example.org.
Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) www.ico.org.uk
If you have any cause for complaint about our use of your personal information, you have the right to complain to the Information Commissioner’s Office (ICO).
How and where do we store your personal data?
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will only store your personal data in the UK on our protected systems. This means that it will be fully protected under the Data Protection Legislation.
We will limit access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
Please note that data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
How can you access your personal data?
If you want to know what personal information and data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email email@example.com or to our postal address (see Contact Us section below).
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may use both “session” cookies and “persistent” cookies on the website.
We will use the session cookies to keep track of you whilst you navigate the website. We will use the persistent cookies to enable our website to recognise you when you visit.
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
For data protection queries: please contact us at:
Email address: firstname.lastname@example.org
Postal Address: BriteVox Limited, Britevox House, Queensway Business Park, Queensway, Telford, Shropshire, England, TF1 7UL
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
BriteVox Whistleblowing Policy
Last updated: November 2020
BriteVox is committed to protecting its employees, contractors, suppliers, clients and members of the public at all times. BriteVox seeks to provide the highest standards of service and working practice, adhering to all legal and regulatory requirements, and encourages feedback on improvements that we may be able to make to those services and day-to-day practices.
There may, however, be times, when an individual becomes aware of an issue at BriteVox, which they wish to disclose in the public interest, but have concerns about confidentiality or sensitivity of the issue. Individuals have the legal right to report complaints about specific issues without fear that they will be treated unfairly or suffer repercussions.
This policy outlines BriteVox’s process for reporting concerns and what to expect.
What is whistleblowing?
Whistleblowing is the raising of a concern by a worker about wrongdoing, risk or malpractice, which affects others, with someone in authority, either internally at the company in question, or externally (e.g. regulators, the police or media).
Whistleblowing does not apply to concerns about how you exclusively are being treated (for example your rights under your working or trading contract).
Examples of concerns or complaints which fall under this policy are:
- A criminal offence, for example fraud, has been, is being, or is likely to be committed
- A concern about the health and safety of an individual
- A miscarriage of justice has occurred, is occurring or is likely to occur
- Dishonest work practices
- Breaches of regulations, for example, the Data Protection Act, sector regulations such as the Fundraising Regulator’s Code of Practice or Ofgem regulations or any other relevant regulation
- Concerns about discriminatory practices
- Environmental risk or damage
- Someone else covering up a wrongdoing
Please write to email@example.com to report your concern to a senior manager usually the Director of Operations. Please include relevant background to the issue, relevant dates and your reasons for your concerns.
BriteVox will take any reported concern seriously and will conduct an initial assessment to ascertain if further investigation is required. You will be advised within 10 working days if the investigation is to be progressed and BriteVox may contact you for further information to enable a full investigation.
BriteVox will report back to you on the outcome of the investigation once it has been completed.
BriteVox will deal with all concerns confidentially and sensitively. If requested, and where possible anonymity of the complainant can be provided, although this may mean that the complaint cannot be fully investigated.
BriteVox UK Complaints Policy
BriteVox UK is committed to providing the highest levels of service and welcomes feedback from any individual or organisation. This feedback is invaluable in helping us to continuously evaluate, learn and improve our service and we take any complaints or concerns very seriously.
We aim to make it as easy as possible to raise any concerns or complaint that you have with us. Our complaint procedure is intended to ensure that all complaints are handled fairly, promptly and, wherever possible, resolved to the complainant’s satisfaction.
What is a complaint?
BriteVox UK understands a complaint to be any expression of dissatisfaction by anyone, whether an individual or an organisation.
BriteVox’s policy is that its complaints procedure:
- is easy to access, clear and easy to understand
- ensures all complaints are listened to properly, acknowledged and acted upon fairly and promptly
- is properly implemented
- is investigated, resolved and responded to within a stated period of time
- takes appropriate action, if a complaint is upheld
- Is implemented in line with The Data Protection Act 2018
How to report a complaint
You can submit your complaint in writing using the below contact details:
By Post to the Complaints Officer
Queensway Business Park, Queensway
Telford TF1 7UL
By Email: firstname.lastname@example.org
Please ensure your complaint includes as much of the following information as possible:
- The date and location where the complaint arose
- The detail of your complaint
- The names of anyone involved
- Your contact details
Our complaint procedure
- Complaints will be handled by our Complaints Team
- We will acknowledge your complaint within 2 working days of receipt, by email
- We will aim to resolve any complaint within 10 working days of receipt
- If the complaint cannot be resolved by the Complaints Team within 10 working days, it will be escalated to the Head of Operations, who will investigate and attempt to resolve the issue within a further 10 working days
- If, on the completion of BriteVox’s investigation, the complaint is still not resolved to your satisfaction, you can also complain to the relevant industry regulator:
Fundraising – Fundraising Regulator
Energy – Ofgem
This policy will be reviewed and updated regularly. The last update was on 27 July 2020.