Privacy Policy

The legal basis

Under the General Data Protection Regulations (GDPR) which came into force on 25th May 2018 in relation to the EU and various other countries, we are obliged to have a legal basis for the processing of personal data, which we do mainly in order to provide information to persons enquiring about joining one of AIN’s networks, or to maintain newsletter subscriptions.

One of the acceptable legal bases for the processing of personal data under the GDPR is “legitimate interests”. The Information Commissioner’s Office of the GDPR has advised that this basis for data processing is likely to be most appropriate where people’s data is used in ways they would reasonably expect and which have a minimal privacy impact (and without overriding the interests, rights or freedoms of the data subject). The Information Commissioner’s Office has also advised that “legitimate interests” may be an acceptable basis for sending emails and text messages and otherwise contacting clients and prospects.

The Commissioner’s Office has suggested a three-part test to satisfy the “legitimate interests” basis:

1. Identify a legitimate interest;
2. Show that the processing is necessary to achieve it – the necessity test (are there alternative ways to achieve the same result?); and
3. Balance it against the individual’s interests, privacy, rights and freedoms.

With these tests in mind, AIN/MMA has reached the following conclusions:

Legitimate Interest: AIN/MMA has a legitimate interest in the growth of its business and fulfilling the broader purpose of providing a useful service to its clients and prospects.

Necessity: AIN/MMA believes that collecting the details persons contacting us, via email and other means of electronic and telephonic communication, social media, social networking sites such as LinkedIn, networking, the exchange of business cards and research within the public domain (company websites, advertisements, publications, brochures, etc.) and storing the same in a secure database is necessary for this purpose, and enables us to provide a more personalised service, and that there are no alternatives to achieve the same ends.

Balance: Looking at the above, AIN/MMA believes that the balance comes down on the side of acceptability of the data processing it undertakes. It also believes that people working in the markets covered by AIN/MMA will expect and accept that their business contact details and other information will be processed by AIN/MMA.