Data Protection and Confidentiality

Data Protection

Paul Kingsley Ltd will never knowingly retain client data that contains ‘personal information’ as defined within the Data Protection Act 1998

  • Clients providing data containing personal information for the purpose of analysis should understand that Paul Kingsley Ltd would be acting solely in the capacity of ‘data processor’ under the instructions of the client and would always seek:
  • firstly to undertake data analysis within the client’s secure system wherever possible
  • if unavoidably required to take personal information off site for analysis, to download only to a password-protected computer or memory device, taking suitable physical security precautions, and then only with the permission of the client’s data controller
  • to maintain proportionate security precautions with all computing and storage media holding personal information (e.g. maintain physical security, password protection, up-to-date firewall and anti-virus software)
  • to permanently delete all personal information at the earliest opportunity
  • never to disclose personal information to a third party.

Paul Kingsley Ltd has not registered a data controller as under no circumstances does it intend to hold personal data of its own accord.

Confidentiality and Intellectual Property

Paul Kingsley Ltd will always seek to protect the client’s confidential information and intellectual property in a reasonable and appropriate manner in accordance with good professional practice and not disclose it to any third party.

What constitutes ‘confidential information’ depends on a test of reasonableness and would, for example, exclude information that has been fairly obtained from public sources independently of the client.

‘Intellectual property’ includes ideas, market research, strategies and documentation previously owned by or developed for the client. In order to continue adding value for present and future clients, Paul Kingsley Ltd may from time to time further use, develop or adapt ideas, market research, strategies and documentation previously developed for another client. Use will be on an anonymous and unattributable basis.

If the client makes a specific and reasonable request for exclusivity on a certain piece of intellectual property, Paul Kingsley Ltd will always respect this, together with any applicable copyright restrictions.