1. Our role and responsibilities
FirstRank aims to process personal data lawfully, fairly, transparently and only for specified purposes. Depending on the service and circumstances, FirstRank may act as a data controller or process information on a client’s documented instructions.
We apply data-minimisation principles and ask clients not to send sensitive files unless they are genuinely required for an agreed assessment or service.
2. Personal data we may process
Information may include contact details, enquiry information, relevant URLs, professional or business details, correspondence and evidence supplied for an agreed service. Reputation and content-removal matters can involve information about other people; it should only be provided where relevant and appropriate.
3. Lawful bases
Depending on the activity, processing may be based on consent, steps taken before entering a contract, performance of a contract, compliance with a legal obligation or legitimate interests. Where legitimate interests are relied upon, we consider necessity, proportionality and the rights of affected individuals.
Special-category or criminal-offence data receives additional care and is processed only where an appropriate condition and purpose apply.
4. Security, access and retention
We use proportionate organisational and technical measures intended to reduce unauthorised access, disclosure, loss or misuse. Access should be limited to people and service providers who need the information for an agreed purpose.
Personal data is retained only for as long as reasonably needed for the relevant enquiry, service, legal obligation or legitimate record-keeping purpose, after which it should be deleted or anonymised where appropriate.
5. Service providers and international transfers
We may use reputable technology, communications, hosting and professional service providers. Where a provider processes personal data for us, we expect appropriate confidentiality, security and data-protection terms.
If personal data is transferred outside the United Kingdom, we seek to use an applicable adequacy decision, contractual safeguards or another lawful transfer mechanism where required.
6. Your data-protection rights
Subject to legal conditions and exemptions, you may have rights to access, correct or erase personal data, restrict or object to processing, receive portable data and withdraw consent where processing relies on consent.
To make a request, email hello@firstrank.co.uk and provide enough information for us to understand and verify the request. We may need to retain limited information where required by law or to establish, exercise or defend legal claims.
7. Questions and complaints
Questions about FirstRank’s use of personal data can be sent to hello@firstrank.co.uk or by post to FirstRank, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
You may also have the right to complain to the UK Information Commissioner’s Office. We encourage you to contact us first so we can try to address the concern promptly.