This document sets out the way that MM Group will operate in business. This is a document which establishes the way in which we will trade both to meet the requirements of legislation and regulatory bodies and also the way we wish to operate as an ethical business.
What we do as a business
- We always put our customer first – we value our customer relationships and will strive in all we do to put them at the centre of how we operate.
- We respect the privacy of the data subjects whose data we have been trusted with – where
we broker data or leads we understand that these represent individuals who have trusted us to protect their privacy.
- We will work in a way which is honest and fair – we will work in a way which is honest, open and fair.
- We will take responsibility for our actions – we will take steps to ensure that our own organisation and those who work with us work to follow our values.
We Will Respect Privacy
When we are working with personal data, whether this is as part of our lead generation or direct marketing activities or part of digital systems we will remember that this data is to be protected. We will ensure that we maintain the highest standards of privacy and correctness in what we do to prevent undue distress.
- We will never send unsolicited emails or text messages or instigate unsolicited telephone calls – all data will be fully opt-in and we will be clear in the reasons why we are collecting the data and how we will be using it.
- We will maintain an internal suppression file – we will ensure that, if an individual has requested that we do not sent them further contact this happens. We will ensure that data we supply is cleansed against this file in addition to external lists.
- We will ensure that data we use is cleansed – lists will be checked against TPS, MPS, CTPS, FPS and other relevant lists) to ensure individuals who have requested no contacts are respected. In addition we will ensure that, where we are informed of deceased individuals we will remove their data from any lists.
- We will not allow antisocial calling or texting – We will respect people we call or text and will not do so at antisocial hours.
- We will act lawfully in all we do – we will ensure we follow all relevant legislation such as the GDPR. We will ensure that we do not send communications which would be in breach of legislation.
We Will be Honest And Fair
We will strive to achieve the highest levels of integrity in our business and aim to be completely transparent, honest and fair in what we do.
- We will not exploit a customers lack of knowledge or experience – honest business means that we will not look to ‘con’ a customer through their lack of knowledge.
- We will ensure that we identify who is carrying out direct marketing – we will ensure that individuals are aware who is contacting them. In addition we will ensure caller line identification is showing for telephone campaigns and there is a clear address for opting out for email and postal campaigns.
- Where we use surveys to provide data we will be clear what the data is to be used for – we will not misrepresent surveys as research if data is to be used for direct marketing purposes, instead we will be clear as to what the data will be used for and gain a positive ‘opt-in’ from the data subject.
We Will Respect The Privacy of Data Subjects
We understand that individuals who opt-in to allow us to use their data do so for specific reasons and have the right to be protected against misuse. We will work in a way which protects the data we have been trusted with.
- We will only collect the data we need for the required purpose – we will ensure that we only collect the data we need for the purpose it has been collected for. We will not request additional data.
- We will ensure the personal data we use is up to date – we will not hold data for longer than necessary.
- We will process data in accordance with the rights of the customer – we know that customers have rights which we will respect at all times.
- We will ensure we have suitable technical and organisational measures to ensure data is processed lawfully – we have a Chief Data Officer who is responsible for ensuring we are processing data lawfully, they will review and update process and procedures as required.
- We will ensure that any data transferred outside of the EEA is adequately protected – if we share data outside of Europe we will ensure that has any additional protection which may be required.
- We will maintain a contract with clients who use our data – to ensure that others who use data we supply are contractually obliged to do so according to our values.
We Will Take Responsibility For Our Actions
We will act in a way that is lawful and meets our objectives as a company. We will ensure that we always take full responsibility for our actions and those who work on our behalf.
- We will strive to act fairly and decently at all times – we will fulfill our contractual obligations and look to act fairly in everything we do.
- We are responsible for the actions of the people who work for us – we will take responsibilities for the actions of our staff, agents and contractors when they are working for us.
- We will require those who work with us to abide to our values – we will require organisations who work with us to abide to our values.
- We will ensure we maintain records to show we comply with legislation and regulatory codes – we will look to ensure we can show how we comply with our trade and regulatory bodies and the law
- We will work in a way which is better for the environment – we will employ our environmental policy to ensure we are doing all we can for the planet.
We will act in an ethical way in all we do
As a responsible organisation we want to do the best we can to be an ethical organisation, naturally we comply with all of the relevant regulations associated with data protection and direct marketing, however we also have established a voluntary code to ensure that, the business we conduct, is always ethical, professional and second to none.
- We will remain professional in all we do, therefore there are certain products which we will not support. – As an ethical organisation we will not work with organisations who are offering products which do not meet our ethical model for example online gambling, smoking or vaping, subprime loans and others.
- We feel that we should not be associated with campaigns which could be seen as a nuisance or that could upset the target audience. – We will ensure that the campaigns we manage or support are run in such a way that they are seen to be positive and useful as opposed to being a nuisance.
- We will not target the elderly – We do all we can to exclude individuals over the age of 75.
- We will review how we communicate with individuals. – We review content before it is used for a campaign. We look to ensure that the messages which are delivered are accurate and professional.