Data Processing Notice

This notice explains how Signal Intelligence processes personal data in the course of delivering its services. It supplements our Privacy Policy and is intended for clients, prospective clients, and individuals whose data may be processed as part of a portfolio assessment.

Data controller

Signal Intelligence, London, United Kingdom.
Contact: contact@signalintelligence.consulting

Categories of data processed

In delivering creator portfolio due diligence, TRACE assessments, and monitoring services, Signal Intelligence processes the following categories of data:

• Client contact data: names, job titles, work email addresses, and company information provided by clients or prospective clients.
• Portfolio submission data: creator handles, platform identifiers, and any additional information submitted by clients as part of an audit or assessment request.
• Publicly available creator data: social media content, follower and engagement data, news and media coverage, regulatory and legal records, business registration data, and other open-source information relating to creators and public figures who are the subject of assessments.
• Monitoring data: ongoing public-source intelligence gathered as part of TRACK monitoring or REACT Priority Watch engagements.

Purposes and lawful basis

• Service delivery: Processing is necessary for the performance of a contract with our clients. Lawful basis: contract.
• Portfolio assessment: Processing publicly available creator data to produce risk assessments is carried out on the basis of our and our clients' legitimate interests in identifying and managing brand risk. Lawful basis: legitimate interests.
• Communications: Responding to enquiries and delivering The Signal newsletter. Lawful basis: legitimate interests (professional contacts) and consent (newsletter subscribers).

Data sources

Creator data processed in assessments is sourced exclusively from publicly available sources, including social media platforms, news and media archives, regulatory bodies, Companies House and equivalent registers, court records, and open-source intelligence tools.

Data sharing

Assessment outputs are shared with the client who commissioned the work. We do not share personal data with third parties except as required to deliver our services (see our Privacy Policy for details of sub-processors) or where required by law.

Retention periods

• Client contact data: 6 years from the end of the client relationship
• Assessment and monitoring outputs: duration of the engagement plus 6 years
• Portfolio submission data: duration of the engagement plus 12 months
• Newsletter subscriber data: until unsubscribe

Data subject rights

Individuals whose data is processed as part of an assessment may exercise their rights under UK GDPR. To do so, contact: contact@signalintelligence.consulting

Please note that some data is processed on the basis of legitimate interests. Where an individual objects to such processing, we will consider the objection and respond within one month.

Complaints may be directed to the Information Commissioner's Office at ico.org.uk.

Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include access controls, encrypted communications, and restricted sharing of sensitive data.

Contact

Signal Intelligence · London, United Kingdom
contact@signalintelligence.consulting