Highland News and Media Ltd (we, us, our) is committed to protecting the personal information you entrust us with and respecting your privacy. We make every effort to ensure that your information is processed lawfully and carefully. This privacy notice describes how we collect and use personal information about you in accordance with data protection law, including the General Data Protection Regulation (GDPR) and the Data Protection Act (DPA) 2018.
- Inverness Courier
- John O Groat Journal
- Northern Scot
- Banffshire Journal
- Ellon Advertiser
- North Star
- Caithness Courier
- Forres Gazette
- Huntly Express
- Executive Magazine
- Highland News
- RossShire Journal
- Banffshire Herald
- Turiff Advertiser
- What’s On North
- The Northern Times
- Strathspey and Badenoch Herald
- Banffshire Advertiser
- Inverurie Advertiser
This includes the following websites
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Please note that there may be other privacy policies that apply to certain services we provide. Please read these when you register or subscribe for these services.
If you have any queries about this notice or would like to make requests to exercise your rights, please email firstname.lastname@example.org.
Who we are
Highland News and Media Publishing Ltd is a multimedia company producing high quality media products that help make local communities better places to live and work. Registered in England. Company No. 1232559
Our head office address is Chilworth Point, 1 Chilworth Road, Southampton, United Kingdom, SO16 7JQ
Highland News and Media Ltd is registered with the Information Commissioner’s Office (ICO) as a "data controller". Registration number ZA646410.
To find out more about Highland News and Media Ltd, please visit www.hnmedia.co.uk
The information we collect from you
We may collect and process information about you (the “data subject”) for either personal or professional reasons, depending upon the circumstances in which they are collected, which will be made clear to you at the time of collection.
We may collect and process the following information about you:
- information that you provide in person (including at events) or by post, phone or electronically – including by email, forms on our websites or via SMS
- information provided at the time of registering to use one of our websites, to use one of our professional services (e.g. advertising), subscribing to newsletters, entering competitions, posting material, raising general enquiries or requesting further services;
- certain information when you report a problem with our websites or regarding the services provided by us;
- details of any correspondence in the event that you contact us;
- survey information, which is used for research purposes, although you do not have to participate in them; and/or
- details of your visits to our websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
We may ask you to provide personal information either as a private individual or as the representative of a company, business or organisation; including non-profit clubs, charities and societies.
Some or all of the following personal information may be collected, but only where absolutely necessary.
- Company you are employed with and/or otherwise are representing if your dealings with us (if applicable/relevant)
- Professional Title, Role and/or Responsibilities (if applicable/relevant)
- Home or Business Address and/or Postcode
- Personal and/or Professional Email (Landline and/or Mobile)
- Personal and/or Professional Telephone (Landline and/or Mobile)
- Age / Date of Birth
- Social media profiles (if applicable)
- Marketing preferences
Trust and transparency is important to us
Our websites use advertising and analytics technologies (including cookies from your device). We work with selected marketing partners who use these technologies to collect data about your browsing activity on our sites, as well as other third-party web sites and apps that partner with them. Our marketing partners use this data to serve you with relevant interest-based advertising and for analytics purposes, and may additionally share this data with their service providers for those same purposes.
When you first visit one of our sites, you will be presented with a pop-up window which allows you to view the technologies we use. By continuing to use our sites, including clicking off or closing this pop-up, you consent to the use of advertising and analytics technologies (including cookies) on our sites and other sites that work with our marketing partners. If you wish to decline, click on the MORE OPTIONS link and switch off the purposes you do not wish to be enabled. Additionally, if you wish to change your preferences on subsequent visits, you may do so at any time by clicking on the Privacy button at the bottom of the screen.
Where We Store Your Personal Data
Whilst we have implemented certain technical and organisational measures to protect personal information submitted via our websites from unauthorised or unlawful processing and against accidental loss or destruction or damage, unfortunately the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. You must not share your password with anyone.
How long we keep your Personal Information
When we obtain your personal data our policy is to keep it only for as long as is necessary for the purpose for which it was collected. However, it may be necessary to retain the information for a longer time, which we will detail here.
If your data has been submitted via post for a competition entry, your information will be destroyed no more than one month following the closing date of the competition. However, it may be necessary to make a digital copy in some instances. (For example, to record the identity of a winner.)
If your data is submitted to us electronically (online or via SMS) in order to make contact with us, including taking part in a competition, your data will be held for a maximum of 5 years. In order to satisfy the requirements of the competition and so that an accurate record of your dealings with us is accessible should any queries arise within that period.
When you contact us via SMS we request you provide a limited amount of personal information (name, postcode and, in some instances, postal address) so that we may identify you. If you are under 16 you must also provide your date of birth in the format DD/MM/YYYY.
When you place an advertisement with us you are subject to our “Conditions of Acceptance of Advertisements” [click here to view] and as a customer your data will be retained for upwards of 5 years to enable us to comply with our legal and contractual obligations and maintain a complete record of your transactions with us.
Legal bases for processing data and how we use it
We will only process your personal data where at least one of the six lawful bases for processing are applicable. These grounds are Consent, Contract, Legal obligation, Vital interests, Public task and Legitimate Interests Information you provide.
This information may be used…
- to take specific steps before entering into a contract with you based on legitimate interests, such as:
- providing you electronically with information that you request from us, or
- creating a record/account on one of our database systems;
- to carry out our obligations arising from any contract entered into between us;
- to provide customer care and support on the grounds of legitimate interests
- to provide you with information about products and/or services we offer where a) we have your explicit consent, or b) where you are a customer who was given an opportunity to opt-out of receiving such information at the time your data was recorded;
- to notify you about changes to our websites and/or services on the basis of our shared legitimate interests;
- to ensure that content from our websites is presented in the most effective manner for you and for your computer (or device)on the basis of legitimate interests; and /or
- for internal record keeping on the basis of our shared legitimate interests;
- to comply with legal obligations.
Information collected about you.
This information may be used…
- to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes on the basis of legitimate interests;
- as part of our efforts to keep our websites safe and secure on the basis of legitimate interests; and/or
- to make suggestions and recommendations to you and other users of our websites about services that may interest you or them only where we have consent;
- to comply with legal obligations.
Information received from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.This information may be combined with information you give to us and information collected about you. This information, and the combined information, may be used for the purposes set out above and below (depending on the types of information received).
Your information may be shared with selected third parties, including:
- our analytics and search engine providers who assist in the improvement and optimisation of our websites; and/or
- our business partners or suppliers, for the performance of any contract entered into with you and in order to provide you with our products and/or services.
Your personal information may be disclosed to other third parties:
- in the event that we sell or buy any business or assets, in which case your personal data may be disclosed to the prospective buyer or seller of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our users may be one of the transferred assets;
We may use your email address to make contact with you. In some instances this will be based on legitimate interests, but in most cases this will only be done where we have your explicit consent.
1. Service notices
We (the “data controller”) send a variety of email newsletters to those data subjects who have given us permission to do so. These include, but are not limited to, summaries of newly added website content. We use internal systems as well as third party service providers to achieve this as below: The Rocket Science Group (trading as MailChimp) who act as a “data processor" and process and store personal data. In order to subscribe to these services, an individual has to submit their email address. This data is, where applicable, shared with / processed by one or both of these service provider/s to deliver the service/s on our behalf. Opening and click behaviours are recorded using industry standard technologies to help us monitor and improve our newsletters. Data is stored on the service provider's secure server/s. Our service providers are not permitted to use the data for their own purposes nor to sell or distribute it on to any other individual, organization or business under any circumstances. Recipients can unsubscribe from newsletters individually at any time by clicking on the 'Unsubscribe' link. Please note this is an automated service. Should any errors occur in submitting an unsubscription request, please use email email@example.com for assistance.
If you have voluntarily given your consent to receive marketing communications, these will come only from us and, if you agree, from any named third party you have agreed to have your data shared with. Our marketing emails include details of promotions, products and services, including competitions and opportunities to take part in surveys. We may also share details of advertising opportunities. We use a third party service provider The Rocket Science Group (trading as MailChimp) as “data processor" to send a variety of marketing emails. The information provided will be kept no longer than 5 years from the last recorded opening and only used to contact you in accordance with your established preferences. You can change your preferences or unsubscribe at any time. Opening and click behaviours are recorded using industry standard technologies to help us monitor and improve our communications. Data is stored on the service provider's secure server. Our service provider is not permitted to use the data for their own purposes nor to sell or distribute it on to any other individual, organization or business under any circumstances. Recipients can unsubscribe from email marketing at any time by clicking on the 'Unsubscribe' link. Please note this is an automated service. Should any errors occur in submitting an unsubscription request, please use email firstname.lastname@example.org for assistance.
We do not collect or use children's data for any advertising or marketing purposes, but we undertake limited processing of personal information about children under the age of 16. Purposes for which data is collected include prize draw competitions in which children may enter themselves, picture voting competitions ("Cute Kids" competitions) and the publishing of drawings by children and/or class photographs in agreement with the schools. Data used for the "Cute Kids" features is collected and shared with us by The Photography Company, who gain consent from parents/guardians to disclose this information to us for this purpose only. Data submitted by those under 16 for competitions is retained for no longer than is necessary. (i.e. until a winner has been identified and informed) Where pictures of, or by, children are published alongside personal information, it is done so with the explicit consent of parents/guardians and/or the school each individual attends.
You have the right...
- to be informed (to have the reasons behind the collection and use of your personal information clearly explained);
- of access (to be provided, within one month of making a verbal or written request, a copy of any data about you that we retain – this is also known as a “subject access request”) at no charge;
- to rectification (correction of your personal data when incorrect or out of date etc. within one month of receipt of a verbal or written request);
- to erasure (deletion of your personal data within one month of making a verbal or written request in instances where such a request does not conflict with other legal bases for its retention);
- to restrict processing in certain circumstances (to be carried out within one month of your making a verbal or written request);
- to data portability (to receive a copy of the data you've provided to us, in a structured, commonly used and machine readable format, either to yourself or directly to another data controller.);
- to object to your personal data being processed (and to get a response within one month of your verbal or written request being received).
You also have rights in relation to automated decision making and profiling. We will only carry out this type of processing where the decision is:
- necessary for the entry into or performance of a contract; or
- authorised by Union or Member state law applicable to us; or
- based on your explicit consent.
Concerns and complaints
If you have a question, query or concern about how we use your personal data, please contact us at email@example.com and we will do our best to respond within 72 hours. If you feel that your data, or a request related to your data, has not been handled correctly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can contact them by calling 0303 123 1113 or going to www.ico.org.uk/concerns
The information on this site is intended to be useful and informative for customers of and investors in Highland News and Media Ltd and its subsidiaries. Highland News and Media Ltd will use reasonable care to ensure that information is accurate at the time it is added on the site. Please note, however, that Highland News and Media Ltd cannot guarantee the information is accurate and it shall not be liable for any losses or damage that anyone may suffer as a result of relying on this information. The information may be changed by Highland News and Media Ltd at any time. Please also note that the contents of this web-site do not constitute an invitation to invest in shares of Highland News and Media Ltd. Highland News and Media Ltd assumes no responsibility for the contents of any other websites to which the Highland News and Media Ltd website has links. The copyright in this web-site belongs to Highland News and Media Ltd. All other intellectual property rights are reserved.