Information for our clients

As a services provider for public relations and marketing services there are many interactions between the client, TEAM LEWIS, and other third parties and members of the public. Interactions may occur that may result in the processing of personal information:

between TEAM LEWIS and the client – for example, our daily interactions between our account servicing team and our client contact, or our interactions between our finance staff and the client’s finance contacts.
between TEAM LEWIS and a third party – this could be one of our contractors, suppliers, a journalist, an influencer. It would be a member of the public, for example, if we ask for an opinion about a client’s product.
between the client and the third party – TEAM LEWIS may facilitate the interaction between the Client and the supplier, journalist, influencer or member of the public as stated above.

In our interactions with clients, TEAM LEWIS can be qualified as a “data processor” of content generated, requested or published, where we are following client instructions, using client provided materials, and otherwise on the client’s behalf. The client would still be in control of how the data is collected, used and processed. In such cases, the client would be the “data controller”.

There are however also situations where TEAM LEWIS may be a “data controller”, where TEAM LEWIS determines the purposes and means of processing personal data. For example: our media contacts or our staff profiles. In cases where such data is passed on to the client, then the client will act as the “data processor”.

TEAM LEWIS as a data controller – Media Contacts and Staff

We are constantly reviewing whether TEAM LEWIS has a lawful basis for processing data in our business.

Of particular interest to our clients is our media contacts, which is central to many services we provide. Our media contacts are built through a combination of our long term suppliers (whom other leading members in our industry also engage with), as well as our long term relationships with the many media titles that we work with in each market.

The details we hold for media are primarily public domain information, being name, title, organisation, business social media handles and business contact details. In some cases we also hold information which are not publicly available, for example, their contact preferences, their personal contact information, or information not available on their websites and obtained privately.

TEAM LEWIS will ensure that it has a lawful basis for using media contact details to provide services for our Clients. Whilst it is not common for media contact details to be passed on to the Client, TEAM LEWIS notes that it may not have a lawful basis to pass on those contact details to the Client directly, and will advise the Client if this is the case.

In all other circumstances, TEAM LEWIS should be deemed as a data processor.

Special Category Data
It is not in the nature of the TEAM LEWIS business to be processing any such data in our Client work. TEAM LEWIS staff have been trained regarding the definition of special category data, to avoid contact with such data in our work, and how to respond when coming across such data inadvertently.

Our policy on processing data in client work
When working with TEAM LEWIS and as set out under our standard terms of business, you will, unless otherwise agreed, follow this protocol:

TEAM LEWIS agrees to act as a data controller with respect to Media Contacts and our staff profiles only
Client will ensure that, where it is acting as the data controller, that any data provided to TEAM LEWIS will be compliant with applicable Data Privacy Laws
Written agreement will be required before TEAM LEWIS agrees to act as a data controller with our clients for any other purpose
Written agreement will be required before TEAM LEWIS will act as either a data controller or processor for any special category data for any client.

TEAM LEWIS and security of personal data
As part of our compliance process, TEAM LEWIS:

Has implemented technical and organizational measures to ensure personal data is protected
Shall provide timely data-breach notifications as per internal policy
Shall transfer personal data outside the EU only if there is a lawful transfer mechanism in place with the organization receiving the data.

Client Contracts and International Transfer of Data
Our contract template contains the relevant personal data provisions and can be supplemented with a separate stand-alone Data Processing Agreement as required by the client or in the event TEAM LEWIS transfers data internationally.

How we’ll use information regarding our clients
We frequently contact our clients and the relevant members of their PR team or senior leadership in which case we will be processing personal data in doing so. The main purposes are as follows:

to provide any products and services you’ve requested
to carry out your instructions
to contact you regarding the administration of our client agency relationship, including contracting, fee payment, finance processes
to inform you about and offer you new products, services, tools that the TEAM LEWIS group and our third party partners offer
to inform you regarding events, thought leadership, newsletters, blogposts and other materials produced or organised by TEAM LEWIS group from time to time
to improve our products and services.

We’ll only use your information where we’re allowed to by law. For example, carrying out an agreement or contract we have with you, fulfilling a legal obligation, where we have a legitimate business interest or where you agree to it.

Transferring your information overseas
Information provided by our clients may be transferred and stored in countries outside the European Economic Area, including some that may not have laws that provide the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection, in compliance with the conditions for transfer set out in EU Data Privacy Law.

Rights
Under the applicable Data Privacy Laws and regulations, relevant individuals have a number of rights relating to their own information. This includes seeing what TEAM LEWIS holds and to object to or restrict processing of it. Further details are set out in the Privacy Centre.

Back to TEAM LEWIS Privacy Centre