Privacy Statement

Orbit Business Development is a business consultancy firm that works with clients in a business to business environment by delivering programmes for strategic alignment, leadership, sales productivity and culture & brand realisation.

As a leading provider of people and business consultancy, we are committed to compliance with the General Data Protection Regulation (GDPR).

The purpose of this statement is to provide information regarding how and why Orbit Business Development Limited, process and store data, as well as providing the appropriate contact information should you wish to exercise any of your personal data processing rights under GDPR such as the right to object, the right to restrict processing etc. (Explained fully here on the ICO website).

Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed as follows:

  • Consent – the individual has given clear consent for you to process their personal data for a specific purpose
  • Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
  • Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)
  • Vital Interests – the processing is necessary to protect someone’s life
  • Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
  • Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful bases for processing personal data can be found at www.ico.org.uk

Orbit Client Contracts

Orbit has assessed all six grounds for lawful processing of personal data and has selected ‘contract’ as the most suitable lawful ground for the processing of data for the purposes of delivering our programmes and fulfilling our contractual obligations throughout those programmes to our clients, and for and communicating with our clients leading up to the programme, for the duration of the programme and afterwards.

Orbit collects necessary data for contractual reasons when delivering programmes. This may include personality profiling information that we process for people development purposes agreed up front in writing with our clients, as part of our programme contract.

Orbit Sales & Marketing

As an organisation that works solely with other businesses (i.e. not directly with the general public) Orbit has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of communicating our marketing and sales messages to the target organisations we wish to work with (including former clients).

Orbit collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in Orbit services. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical segmentation includes those at ‘C’ level within B2B organisations in the IT, financial, commercial and public sectors, including CEO, Managing Directors and Sales Directors, although this list is not exhaustive and other variables may apply.

We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, social profiles (e.g. LinkedIn). Other business related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘special category personal data’.

The data collected will be used to communicate marketing and sales messages relating to Orbit’s services, based upon the job function held by the data subject. Orbit specifically only sends messages to those we believe are likely to be interested in Orbit services based upon the organisation they are employed by and based upon their job function within that organisation. Messages from Orbit could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.

When you send Orbit an enquiry or booking form via our website or by email or letter you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Orbit services and news that we feel may be of interest to you, it is deemed that as you have visited the Orbit website and provided us with your contact information that you are legitimately interested in our services and related information. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.

How we Procure Data

We procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:

  • You have requested information from Orbit on a previous occasion
  • Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you
  • You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
  • We have previously met at an event and your business card or contact details were handed to us willingly
  • You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
  • You have previously connected with a member of our team via the LinkedIn regarding our company and / or our services
  • A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in Orbit services, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product
  • Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly)

Legitimate Interest Assessment (LIA)

Orbit has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Orbit and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Orbit in a direct marketing or sales capacity, could be legitimately interested in Orbit programmes and related services. It is also deemed that direct marketing and sales is necessary in the context of promoting Orbit to professionals in business in order to increase awareness of our services in the marketplace.

Per the ICO guidance, Orbit can confirm:

  • We have checked that legitimate interests is the most appropriate basis
  • We understand our responsibility to protect the individual’s interests
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
  • We have identified the relevant legitimate interests
  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
  • We only use individuals’ data in ways they would reasonably expect
  • We are not using people’s data in ways they would find intrusive or which could cause them harm
  • We do not process the data of children
  • We have considered safeguards to reduce the impact where possible
  • We will always ensure there is an opt-out / ability to object
  • Our LIA did not identify a significant privacy impact, and therefore we do not require a ‘Data Protection Impact Assessment’ - DPIA
  • We keep our LIA under review every six months, and will repeat it if circumstances change
  • We include information about our legitimate interests in our privacy notice

Orbit has an in-house marketing team, who are responsible for ensuring the validity and quality of the data contained within the Orbit system. All Orbit staff have access to the CRM system and any records found to be out of date are updated or deleted on a regular basis.

UK Data Storage

The data held within the Orbit CRM system is processed and stored in the UK within a secure environment.

Request to Object / or Restrict Processing

In all correspondence with you we will give you the right to object from receiving further correspondence from Orbit. On any emails you receive from Orbit there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you receive a telephone call from us, you have the right to request not to receive any further calls. Orbit has a companywide CRM system, your request to object will be logged within our CRM system to ensure that you do not receive further communication.

Request for Deletion

It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from the Orbit CRM system. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from Orbit services. If you do not wish for us to contact you again with our sales and marketing messages, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.

The option however is yours, and in either case we will process your request within 30 days.

Last Reviewed

This privacy statement was last reviewed and updated on the 11 May 2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.

For questions relating to this policy please contact us.

Contacting Orbit Regarding Your Data Processing Rights Under GDPR

Should you wish to object to receiving communication from Orbit, or exercise any of your other rights under GDPR you can do so in a variety of ways:

  • Please click the ‘unsubscribe’ link at the bottom of any email
  • If you have received a call, please tell the representative that you do not wish to receive any further communication
  • Please call 07967 454075 and ask to speak with Orbit Marketing
  • You can also make your request by emailing gdpr@orbitbusinessdevelopment.com
  • Or by writing to: CEO, Orbit Business Development, 18 Melton Road, North Ferriby, East Yorkshire, HU14 3ET