Privacy Policy

Earendel Associates Ltd (Earendel) is committed to safeguarding the privacy of its correspondents and contacts. This notice sets out Earendel’s policy and practice as regards personal data.

  • The information Earendel processes will usually be limited to name, email address and phone number, and relevant career notes where appropriate. Earendel will also hold notes relating to interactions with contacts, or to commercial arrangements with them.

  • This personal information usually comes to us by introduction, research usually conducted from open source / public domain, or by individuals’ contact with us.

  • Earendel exists to generate analysis of, and advice concerning, global change and security issues. In doing so, Earendel maintains and develops a network of professional contacts, to enable the generation and processing of this analysis and advice; and identifies and engages potential readers of or customers for the product.

    Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

    • Consent: where Earendel is in established correspondence with a contact, it will seek their clear consent to process their personal data

    • Contract: where Earendel is in a contractual relationship with an individual or with an organisation represented by them, Earendel will process data necessary to perform that contract

    • Legitimate interest: where Earendel is processing data with a view to identifying clients or partners, Earendel will hold minimal identifying detail necessary to inform decisions, as a legitimate commercial interest causing minimal risk to the individual’s interests, rights and freedoms.

  • Earendel may use data collected to inform decisions regarding potential clients, advisers or partners; or to enable the conduct of established relationships and signed contracts.

  • Earendel will make every effort to store contact details securely, on their externally managed and secured IT system.

    Stored data is reviewed regularly and only retained where an ongoing use is determined.

    Earendel keeps the above listed types of identifiable data until the subject makes it clear to us that they no longer wish us to hold their information. We will then erase the information by erasing from across all our commercial systems. Information on how to do this is listed below.  

  • Earendel may disclose information in special cases where it has reason to believe that disclosing such information;

    • is reasonably necessary in order to comply with the Law; or

    • will protect the rights, property or safety of Earendel, its employees, clients or partners, or its contacts.

    In the case of information being provided by telephone or other verbal meas, we will check the caller’s identity to ensure they are entitled to receive the information . If the identity cannot be verified satisfactorily, we will ask the caller to put the request in writing.

  • Users have rights to access data subjects held about them by the Data Controller (Earendel). Individuals can find out what personal information Earendel holds on them by making a ‘subject access request’ free of charge. 

    Earendel will respond to such requests within one calendar month, subject to the availability of its data systems. Individuals making requests will receive the following information sets where appropriate:

    • List/description of the user’s data

    • Explanations to why we hold this data and what this is being used for

    • Who the data has/may be disclosed to and why they may have access

    • Provide a copy of information in an easy-to-read format (data portability)

  • Under data protection law, you have rights including:

    • Your right of access - You have the right to ask us for copies of your personal information.

    • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

    • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

    • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

    • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

    • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

    You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact Earendel by email at: office@earendelassociates.com if you wish to make a request.

  • If you have any concerns about our use of your personal information, you can make a complaint to us via the following email address: office@earendelassociates.com.

    You can also complain to the ICO if you are unhappy with how we have used your data:

    Information Commissioner’s Office

    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

    Helpline number: 0303 123 1113

    ICO website: https://www.ico.org.uk