Nicola Smith Communications Ltd – Privacy Policy

When we collect and process personal data, we do so only in the pursuit of and in accordance with the real and present legitimate interests of the business and taking into consideration the fundamental rights and freedoms of the relevant data subjects.

The data is held indefinitely unless and until:

  • The data subject ceases to be professionally active for a significant period
  • The data subject request the removal of his or her personal data from the database.

We only use individual’s data in ways they would reasonably expect and which have minimal privacy impact. We do not use personal data in ways that the individuals concerned would find intrusive or which could cause harm, but in a way that people expect us to use their data.

This data processing is entirely necessary as without it, Nicola Smith Communications could not function as a communications consultancy.

Personal Information Held

Client contacts:

We store contact names, postal addresses, invoicing details, email addresses and telephone numbers for the purposes of carrying out our communications work for and on behalf of our clients and for invoicing for that work. No access is given to any third parties whatsoever.

Clients’ clients and business partners:

We occasionally hold names, email addresses and phone numbers for our clients’ clients and business partners in order to work with them on PR, marketing and communications work. No access is given to any third parties whatsoever.

Journalists and media contacts:

We store contact names, email addresses and phone numbers for relevant media contacts for the purposes of sending information about our clients or for placing advertisements. This data is held in our bespoke database. No access is given to any third parties to this data.

Every press release mailing is to a carefully-selected bespoke list to ensure relevance and that there is legitimate business interest. An unsubscribe function is included in all press release mailings and if requested, the contact details are immediately removed from the database. All contacts have the right to erasure.

Supplier details:

We store contact names, email addresses and phone numbers for any suppliers we have worked with to be able to provide orders and briefs to them. This information is not shared with any third parties.

Client-owned data:

As part of the communications service provided to clients, we are often granted access to client websites in order to create, monitor and update the content. This access to client Content Management Systems means that we also have access to any information gathered by their websites eg job applications or requests for information. Such information is stored safely, checked for accuracy and may be forwarded to the client organisation for action. It will not be used for any other purpose.

Supporting client organisations with their communications and marketing means that we may be granted access to their database(s), working as an extension of their team. Such data will only be used in accordance with the clients’ individual data policies for the specific purposes outlined. In the event of the client relationship coming to an end, all data will be returned to the client and deleted from our files.

Personal photographs and film:

Photography and film are significant elements of our communications work for clients, and many of the photographs and film clips are of individuals, be that employees of a client organisation,  customers or service-users eg residents or volunteers.

Whenever photography or films are commissioned, each participant is required to complete a Photographic and Filming Consent Form. This explains the variety of ways in which the photographs or film could be used, and grants consent for the client organisation, and therefore also Nicola Smith Communications working as an extension of the organisation, to use these materials in promotional work. These forms are held by the client organisation, not by us.

This consent can be rescinded by the subject, in writing at any time. In such cases, we will no longer use the image(s) in question, and they will be deleted from our files. In the case of images used online, these will be removed as soon as possible, and within a month at the most. Images used in printed literature may take longer to remove, but this will be discussed with the subject.

In the event of us no longer working with a client organisation, we will stop using any of their photographs and all images will be returned to the client and/or deleted from our files.


We try to use all commercially acceptable means to protect the personal data we hold, including password-protection on all computers and tablets, security code-protected mobile phones, the use of fire-walls and anti-virus software.

We do not log personal information using cookies, and bank details for suppliers are not electronically filed as we do not take credit or debit card payments.

We maintain data security by protecting the confidentiality, integrity and availability of personal data defined as follows:

  • Confidentiality means that only people who are authorised to use the data can access it
  • Integrity means that personal data should be accurate and suitable for the purpose which it is proposed
  • Availability means that authorised users (Nicola Smith) should be able to access the data if they need it for authorised purposes.

GDPR Data Breaches

Data breaches would be detected, reported and investigated by our GDPR Data Protection Officer, Nicola Smith, who has responsibility for data protection compliance and requests.

Subject Access Requests

Data subjects should make a formal request for information we hold about them. If an individual asks what information we hold about them, we will notify them that we will respond within one month. We will send them details of all personal data we hold on them.

We will inform them about:

  • The source from which we obtained their personal data
  • The purpose(s) for which we intend to process that data
  • The types of third parties, if any, with whom we will share or to which we will disclose that personal data
  • That the data subjects can limit or prevent our use and disclosure of their personal data.

Right to Erasure

Any requests to provide information on the data held or to remove contact details from our records will be carried out as soon as practically possible. This is typically within 48 hours and within a maximum of 30 days. We will confirm to them that we have done so.

Website Privacy Policy

You can access our home page and browse our website without disclosing your personal data. It is available purely for browsing or if someone wishes to contact us via email.


This is the Nicola Smith Communications Limited website (‘website’), which is owned and operated by Nicola Smith Communications Limited (or referred to as ‘we’ or ‘us’ or ‘our’).

Nicola Smith Communications is a limited company, registered in England company number 9159189. Registered office: Alliott Wingham Ltd, Kintyre House, 70 High Street, Fareham, Hampshire PO16 7BB.

Please address all correspondence regarding this privacy statement to [email protected]

Who may process data

Nicola Smith Communications does not collect any personal data about you on this website, apart from information which you volunteer (for example by emailing us). Any information which you provide in this way is used only in line with the purpose for which you provided it.

Non-Personal Information

Technical details in connection with visits to this website are logged by our internet service provider for statistical purposes. Unless provided to us, no information is collected that could be used by us to identify website visitors. The technical information will be used only for statistical and other administrative purposes. Technical details, which we cannot associate with any identifiable individual, do not constitute ‘personal data’ for the purposes of GDPR.


Unless we are obliged by law to disclose your personal or other information, it will not be used for any other purposes and shall not be disclosed to any other third parties.


We may send a small file to your computer when you visit our website. This will enable us to identify your computer, track your behaviour on our website and to identify your particular areas of interest so as to enhance your future visits to this website.

We may use cookies to collect and store personal data and we link information stored by cookies with personal data you supply to us. Save for the use of cookies, we do not automatically log data or collect data apart from for information you specifically provide to us. You can set your computer browser to reject cookies but this may preclude your use of certain parts of this website.


If you have any enquiries or concerns about our privacy policy, please email [email protected]