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Privacy Notice and Privacy Policy for Cogent Perspectives Ltd

Policy last updated 07.03.26

  1. General
 

This Privacy Notice and Privacy Policy relate to the collection, storage, and use of personal data collected/processed by Cogent Perspectives Ltd (hereafter referred to as ‘Cogent Perspectives’ our trading name or “we”, “us” or “our”).

The Privacy Notice is specifically intended to inform users of our practices in relation to personal data/information you may have been provided to us via this website, or through registration forms for events.

The Privacy Policy provides details about the personal data we collect, how we use it, and your rights regarding the personal data we hold about you. We commit to using any personal data you provide to us, or we collect and process on the basis of legitimate interests in the course of our work responsibly and in accordance with all applicable UK laws and data privacy regulation.

Cogent Perspectives is the data controller. Daniel Cremin is the company’s data protection lead and you can contact us via Contact@CogentPerspectives.co.uk if you have any queries about this policy or your personal data.

Under General Data Protection Regulation (GDPR), personal data is defined as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

  1. Our operating approach and principles:
 

In all cases, as we collect personal data, we are careful to balance our legitimate interests and lawful reasons against your interests, rights and freedoms as an individual, including your right to privacy. Our aim is to minimise data processing to what is necessary. We look to ensure that we only use your personal data in a way or for a purpose that you would reasonably expect in accordance with this policy, and that does not unfairly intrude on your privacy.

Cogent Perspectives will only process and/or collect personal data where we have a lawful and valid reason for doing so, such as:

  • The processing and/or collecting is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract.
  • The processing in necessary in order for us to comply with any legal obligations.
  • You have consented to us holding such data for purposes agreed with you; and/or
  • The processing or collection is necessary for the pursuit of our legitimate interests as a business.
 

Our operating principles are set out below.  

  • Data will be collected for a specific purpose, and the processing is lawful, fair and transparent.                  
  • When you contact us using our website contact form or sign up to our mailing list you are consenting to our privacy policy. You have the right to withdraw consent by contacting Contact@CogentPerspectives.co.uk or using appropriate functionality such as the unsubscribe option on a newsletter or marketing email.
  • We will take steps to periodically ensure we have your continued consent to contact you if you are on our mailing list.                                                      
  • We seek to be transparent about what kind of personal data we collect and what such data is being used for.                                                               
  • Personal data may be processed and disclosed in the context of the work we undertake for clients in a responsible manner, but we will not sell your personal data to a third party entity such as a marketing firm.                                                                                                                  
  • We use third parties to support us in providing our services and to help provide, run and manage internal IT systems such as the website and our mailing list – some personal data may be processed by them in the course of our communications with you (e.g. our email service provider and our mailing list service provider).                                    
  • We use cookies on our website for basic website use tracking and analytical purposes, but you have the option to go ‘cookieless’ on our website. See the Cookies Policy further below for more information.                                                                  
  • Data is not kept for longer than necessary and we will periodically review the data we hold, at least once on an annual basis, to ensure this.                
  • The data we collect and process is kept safe and secure, and we will notify data subjects if there is any data breach.                                             
  • Where we are collecting and processing information that is classified as special category data under the UK GDPR legislation, we will do so in accordance with the law, undertaking a legitimate interest assessment to ensure the data being collected complies with the lawful reasons of substantial public interest (Article 9, 2 (G)) and/or consent (Article 9, 2,(A)) and is in line with our legitimate interests as a business (Article 6, 1 (F)).                                                                                                                              
  • We will never collect, process or disclose information covered by special category data provisions if not strictly necessary to our work and in line with the lawful reasons set out above.
  • We will seek to be transparent and fair with stakeholders where they contact us in relation to their personal data and to exercise their rights, aiming to respond in a timely manner to correspondence.
  • If you ask us to stop processing data about you in the context of our work or to correct / amend or delete data we have published, we will give this serious and fair consideration, balancing your rights with our legitimate interests.
  • We will comply with lawful requests from UK law enforcement and regulatory authorities including where there is a legal requirement to disclose personal data.
 
  1. Why we collect personal data
 
  • To correspond with you when you contact us to enquire about our services or for any other matter by using our contact form or email address.         
  • To send you information or marketing material in relation to our services or events, where you have given us permission to do so.
  • To distribute newsletters, event information, or briefings or to you where you have given us permission.
  • To communicate with you in the context of our work and to manage our relationship with you – a reason covered under our legitimate interests as a business.
  • To undertake our work for clients in line with our legitimate interests as a business. This may include helping them to understand and engage with key political, public policy, regulatory, and technology issues and the key decision makers and stakeholders related to such issues.                                                                                    
  1. What information do we collect?
 

Personal data is information that identifies you as an individual.

Categories of personal data we collect includes:

  • Contact information (name, physical address, telephone number, email address that you provide through the contact form on our website or in other forms of correspondence such as emails, letters or when you register for events we organise.
  • Information about your affiliations (e.g. your role and organisation).
  • Registration details for events and recordings of events organised by Cogent Perspectives where you were either an invited speaker or an audience participant. In all cases, it is a stated condition of registration for participation in our events that you agree to Cogent Perspective’s right to record and publish or disseminate a video of the event and/or audio transcript or summary.
  • Information for invoicing, hiring and human resources purposes (e.g. financial account information, employment and education history, work eligibility status, date of birth).
  • Any additional information you submit when contacting us that identifies you. .                                                                                                                           
  • Personal data and Special Category personal data about you we may collect and process as a relevant stakeholder in the context of the legitimate interests of our business from publicly available sources / third parties (e.g. Hansard, newspaper articles, and public social media sources such as YouTube, X and BlueSky). In the case of Special Category data, this may include, for example, political opinions, religious/philosophical beliefs, trade union membership, nationality, and race/ethnic origin.
 

In the course of our activities as a business, providing analysis and advice, facilitating engagement, and organising events we may process data on:

  • Business-to-Business Contacts.
  • Clients (and individuals associated with clients).
  • Suppliers.
  • Staff of our company.
  • Persons who supply us with their information.
  • Members of Parliament; Peers in the House of Lords; Members of the UK devolved legislatures; Elected Representatives in Local Government; Members of the European Commission, Council and Parliament; Other overseas elected representatives.
  • UK Civil Servants and officials in public bodies.
  • Journalists, researchers, and political and social affairs commentators.
  • Other relevant stakeholders to our clients engaged in influencing public policy and political debate in the UK – for example people working for or affiliated with industry bodies/trade associations, think tanks, national academies, institutes, and campaigning organisations.
 
  1. Security and Data Retention
 

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it.

We commit to only retain personal data for as long as it is necessary and will periodically review to ensure it is up to date and take steps to securely delete/erase the personal data we no longer need.

  1. Your Rights and options to Complain
 

Where we hold personal data about you, you have the following rights:

  • To ask us to provide you, or a third party with your express consent, with copies of personal information we hold about you at any time, and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law.
  • To request erasure, anonymisation or blocking of your personal information that is processed in breach of the law;]
  • To object on legitimate grounds to the processing of your personal information and request that we desist in doing so. Where we may not be able to stop using your personal information, if that is the case, we will let you know why.
  • To withdraw consent – when personal data is processed on the basis of consent, an individual may withdraw consent at any time (this may apply to processing of special categories of personal information where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership).
  • In the event that you no longer want to receive mailing list materials such as newsletters, briefings or event information from us, please use the unsubscribe option (which is in our marketing e-mails to you), or contact our Company’s data protection lead via Contact@CogentPerspectives.co.uk.
  • To exercise such rights (bar withdrawing from marketing emails – as described above) and if you have any questions about how we collect, store and use Personal Data, then please contact us using the details as set out in the “Data Controller contact information” section below.
  • In the unlikely event that you feel that you need to complain about our use of your personal data, and we have not been able to resolve this internally, you have a right to complain to the Information Commissioner’s Office. Their details are shown below:
 

         Information Commissioner’s Office
         Wycliffe House
         Water Lane
         Wilmslow
         Cheshire
         SK9 5AF                                                                                                                                 
         Website: www.ico.org.uk. E-Mail: casework@ico.org.uk. Telephone: 0303 123 1113.

Cookies Policy for Cogent Perspectives Ltd

Policy last updated 07.03.26

Our website uses traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

You can choose to accept or decline cookies when prompted on our website. Some web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

We do not use cookie technology to collect personal information about you to sell or transfer to third parties for the purposes of contacting you or targeting you with information or products.

If you have any queries about this policy or the use of cookies, please email us on Contact@CogentPerspectives.co.uk.