1. About this Policy
This Privacy Policy explains how Proximity News Network Ltd collects, uses, stores and shares personal information, and how it uses cookies and similar technologies.
It applies to:
- the Proximity News Network website;
- all regional, local, industry and specialist publication websites owned, controlled or operated by Proximity News Network Ltd;
- our newsletters;
- contact, correction, complaint and advertising forms;
- voluntary gifts and other payment facilities;
- our social-media and business communications; and
- other services that link to this Policy.
Together, these are referred to as the “Services”. Websites covered by this Policy are referred to as the “Websites”.
A current list of publications is available on our Our Brands page.
2. Who is responsible for your information
The controller responsible for personal information covered by this Privacy Policy is:
Proximity News Network Ltd.
Privacy and data-protection enquiries may be submitted through our Contact page or sent by email to contact@proximitynewsnetwork.com
Individual Network publications are normally brands operated by Proximity News Network Ltd rather than separate legal entities or data controllers.
3. Information we may collect
Depending on how you interact with us, we may collect the following information.
Information you provide
This may include:
- your name;
- email address;
- telephone number;
- organisation, role or professional details;
- postal or billing address;
- newsletter and marketing preferences;
- messages and documents submitted through contact forms;
- correction or complaint information;
- advertising enquiries and campaign information;
- story suggestions, press releases and editorial submissions;
- photographs, recordings or other submitted media;
- payment and transaction information;
- correspondence with us; and
- any other information you choose to provide.
Please do not provide sensitive personal information unless it is necessary for your enquiry or editorial submission.
Technical and usage information
When you use our Services, we or our service providers may collect:
- IP address;
- browser and device type;
- operating system;
- approximate geographic location derived from an IP address;
- referring website or campaign;
- pages and articles viewed;
- date, time and duration of visits;
- navigation, interaction and scroll information;
- error, diagnostic and security logs;
- consent and cookie preferences; and
- identifiers used for security, analytics or service operation.
The extent of this collection depends on your choices and the technologies enabled on the relevant Website.
Payment information
Where you make a gift or other payment, a payment provider may collect your card or bank details directly.
We may receive limited information such as your name, email address, transaction reference, payment amount, payment status and the final digits or type of payment method.
We do not normally receive or store complete payment-card details.
Editorial information
For journalistic purposes, we may collect or use information relating to:
- individuals mentioned in public records, announcements or news sources;
- representatives of companies, public bodies and other organisations;
- witnesses, sources and contributors;
- allegations, legal proceedings and public-interest matters;
- photographs, recordings and published statements;
- professional or public activity; and
- information supplied by press offices, agencies or other sources.
Editorial information may include sensitive or criminal-offence information where its use is lawful, necessary and justified for journalistic purposes.
4. Where information comes from
We may obtain information:
- directly from you;
- automatically from your device;
- from public records and official publications;
- from organisations, employers, press offices and representatives;
- from news agencies and licensed content providers;
- from social-media or other publicly accessible sources;
- from event organisers, contributors and correspondents;
- from business partners and service providers;
- from payment providers; or
- from other lawful journalistic sources.
We assess the reliability and appropriateness of information according to its intended use.
5. How and why we use information
We use personal information for the following purposes.
Operating and securing our Services
We may use information to:
- deliver pages and content;
- maintain website functionality;
- detect misuse, fraud or security threats;
- investigate errors;
- maintain backups and logs; and
- protect our systems and users.
Our lawful bases may include legitimate interests, compliance with legal obligations and, where applicable, performance of a contract.
Responding to enquiries
We use contact information to respond to:
- general enquiries;
- editorial correspondence;
- correction requests;
- complaints;
- privacy and copyright requests;
- advertising enquiries; and
- other communications.
Our lawful bases may include legitimate interests, taking steps at your request before entering a contract, performance of a contract and compliance with legal obligations.
Newsletters and direct marketing
We may use your contact details to send newsletters or other direct marketing where:
- you have consented;
- another lawful route is available under applicable electronic-marketing rules; or
- the communication is not direct marketing.
You may unsubscribe at any time. Withdrawing consent will not affect processing that occurred before withdrawal.
We may keep limited suppression information after an unsubscribe request so that we can respect your preference.
Payments and accounting
We may use payment and transaction information to:
- process and confirm payments;
- respond to payment queries;
- prevent fraud;
- maintain financial records; and
- comply with tax, accounting and legal duties.
Our lawful bases may include performance of a contract, legitimate interests and legal obligations.
Analytics and improvement
We may use information to understand:
- audience levels;
- article performance;
- general reader journeys;
- website speed and reliability;
- device and browser compatibility;
- aggregate geographic distribution; and
- how our Services can be improved.
Where consent is legally required, analytics technologies will not be activated until consent has been provided.
Where we rely on an applicable statistical-purpose exception, use will be limited to aggregate service-improvement statistics. Individual-level information will not be retained longer than necessary to create those statistics, and users will be given a simple and free method of objecting.
Analytics used for advertising, individual profiling, cross-site tracking, session replay, visitor recordings or persistent individual monitoring will require consent where required by law.
Further information about our use of cookies and analytics is provided below.
Advertising and commercial relationships
We may use business contact information to:
- respond to advertising enquiries;
- prepare proposals;
- manage campaigns;
- communicate with clients, agencies and suppliers;
- perform contracts;
- invoice and receive payment; and
- maintain business records.
Our lawful bases may include legitimate interests, taking steps before entering a contract, performance of a contract and legal obligations.
Establishing and protecting legal rights
We may process information to:
- investigate suspected wrongdoing;
- respond to legal demands;
- enforce agreements;
- establish, exercise or defend legal claims;
- obtain professional advice; and
- comply with court orders or regulatory requirements.
Our lawful bases may include legitimate interests and legal obligations.
6. Journalism and freedom of expression
Proximity News Network is a news publisher. Some personal information is used for journalistic purposes with a view to publishing journalistic material.
Where the legal conditions are met, provisions of data-protection law may be restricted by the journalistic exemption. This exemption is intended to balance privacy rights with freedom of expression and information.
We will only rely on it where we reasonably believe that:
- the information is being used for journalism;
- the activity is carried out with a view to publication;
- publication is in the public interest; and
- complying with the particular data-protection requirement would be incompatible with the journalistic purpose.
The exemption is assessed in relation to the particular information and activity. It is not treated as a blanket exemption from data-protection law.
Certain rights may therefore be limited where applying them would improperly interfere with journalism, source protection, pre-publication work, archives or freedom of expression.
We will consider requests individually and explain a refusal where legally appropriate.
Publishers must generally comply with data-protection law and may use the journalism exemption only where its specific criteria are met and can be justified. Security and accountability requirements continue to apply.
7. Our lawful bases
Depending on the circumstances, we may rely on:
- consent, where you have made a genuine choice;
- contract, where processing is necessary to perform an agreement or take requested pre-contract steps;
- legal obligation, where the law requires processing;
- legitimate interests, where processing is necessary for our or another person’s legitimate interests and those interests are not overridden by your rights;
- the journalism exemption and applicable conditions for sensitive information where the statutory requirements are met.
Where we rely on legitimate interests, those interests may include:
- publishing and distributing journalism;
- operating a news network;
- improving our Services;
- maintaining security;
- responding to correspondence;
- managing business relationships; and
- protecting legal rights.
8. Sensitive and criminal-offence information
We do not ordinarily ask readers to provide special-category information.
However, such information may arise in:
- editorial submissions;
- complaints;
- reports involving health, politics, religion or other sensitive matters;
- public-interest journalism;
- legal proceedings; or
- information made public by the person concerned.
Where required, we will identify an additional legal condition for using special-category or criminal-offence information or consider whether the journalism exemption applies.
12. Consent, choices and objections
When you first visit a Website, you may be shown a control that allows you to:
- accept optional cookies;
- reject optional cookies; or
- manage categories individually.
Rejecting optional cookies will not prevent access to ordinary news content, although some non-essential features may be unavailable.
Where we rely on consent, you may withdraw it at any time through [Cookie Settings].
Where we rely on an applicable statistical-purpose, preference or appearance exception, you may object free of charge through [Cookie Settings or analytics objection link].
It should be as easy to reject or withdraw consent as it is to provide it.
Non-essential cookies will not be activated before a valid choice has been made where consent is required.
Withdrawing consent or objecting does not automatically delete cookies already stored on your device. You may remove them through your browser settings.
We may keep a record of your consent or objection for an appropriate period so that we can respect your choice and demonstrate compliance.
14. Third-party providers
The providers used by individual Websites may change.
The live cookie inventory will identify the relevant providers and, where appropriate, link to their own privacy information.
Third parties may act as our processors, independent controllers or joint controllers depending on how their technology operates.
We assess these arrangements and configure services in a privacy-conscious manner where reasonably possible.
15. Browser controls
Most browsers allow you to:
- view stored cookies;
- delete cookies;
- block some or all cookies; and
- receive warnings before cookies are stored.
Blocking all cookies may prevent parts of a Website from working correctly.
Browser controls do not necessarily prevent server-side processing or technologies that do not use conventional browser cookies.
17. International transfers
Some service providers may process information outside the United Kingdom.
Where personal information is transferred to a country that does not have an applicable UK adequacy decision, we will use an appropriate safeguard where required, such as approved contractual protections, and assess whether additional measures are necessary.
You may contact us for further information about the safeguards relevant to your information.
18. Retention
We keep personal information only for as long as reasonably necessary for the relevant purpose, including legal, regulatory, accounting, security and journalistic purposes.
Indicative periods include:
- general enquiries: normally up to 24 months after closure;
- advertising and contractual records: normally up to six years after the relationship ends;
- financial and transaction records: for the period required by accounting and tax law;
- newsletter information: until you unsubscribe or the service ends, followed by limited suppression information where necessary;
- unsuccessful job applications, where applicable: normally up to six months;
- routine security and technical logs: normally between 30 days and 12 months, depending on purpose and risk;
- correction and complaint records: normally up to six years after closure where required for accountability or legal claims; and
- editorial records and published news archives: potentially for long periods or indefinitely where retention remains justified for journalism, historical record, source protection, accountability or legal purposes.
Cookie-specific expiry and retention periods are provided in the live cookie inventory.
These periods may be shortened or extended where justified by the circumstances. We periodically review information that is retained.
19. Published archives
News articles form part of a continuing public and historical record.
We do not normally remove accurate archived material solely because it is old, inconvenient or no longer reflects a person’s current circumstances.
We may consider:
- correcting inaccuracies;
- adding an update or clarification;
- reducing unnecessary prominence;
- removing information that no longer serves a legitimate public interest;
- anonymising information in exceptional cases; or
- restricting indexing where justified.
Each request will be assessed against:
- accuracy;
- privacy;
- freedom of expression;
- public interest;
- the nature of the information; and
- the importance of maintaining an accurate archive.
20. Your rights
Depending on the circumstances, you may have the right to:
- receive information about how your personal information is used;
- request access to your personal information;
- ask for inaccurate information to be corrected;
- request erasure;
- request restriction of processing;
- receive certain information in a portable format;
- object to processing based on legitimate interests;
- object to direct marketing;
- withdraw consent; and
- complain to the Information Commissioner’s Office.
These rights are not absolute. They may be restricted where an exemption applies, including where necessary to protect journalism, confidential sources, legal privilege, another person’s rights or legal proceedings.
We may need to verify your identity before acting on a request.
21. Automated decision-making
We do not currently use personal information about readers to make solely automated decisions that produce legal or similarly significant effects.
We may use automation to assist with security, classification, analytics and editorial workflows, but this does not ordinarily amount to legally significant automated decision-making about readers.
22. Children
Our general news Services are not designed specifically for children under 13.
We do not knowingly invite children under 13 to subscribe to direct marketing without appropriate authorisation.
Journalistic content may concern children where publication is lawful, justified and handled with appropriate care.
Editorial use of information about children is assessed separately from information collected through subscriptions or website services.
23. Security
We use proportionate technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
No internet service is completely secure. You should avoid sending highly sensitive or urgent information through an ordinary contact form unless necessary.
24. Changes to this Policy
We may update this Policy to reflect changes in law, technology, suppliers or our Services.
The current version will be displayed on this page with the date of the latest update.
Where appropriate, we may provide additional notice of material changes.
25. Complaints and contact
Please contact us first so that we have an opportunity to address your concern.
Privacy and cookie enquiries, objections and rights requests may be submitted through our Contact page or email contact@proximitynewsnetwork.com.
You may also complain to the Information Commissioner’s Office if you believe your data-protection rights have been infringed.
Information about submitting a complaint is available on the ICO website.