GDPR policy

Last Modified: January 12, 2021

Data Processing

Data processing refers to any set of operations performed on personal data or on sets of personal data. Within the range of services Commetric delivers to the Communications sector this can include the creation of media lists of influential media outlets, journalists and social media influencers relevant to a client.

Article 6.1 of the GDPR framework requires that an organization must establish the appropriate legal basis for processing customer data and controlling personal data.

According to the Information Commissioner’s Office (ICO) “legitimate interests” provides the most flexible lawful basis for processing personal data. Specifically, it is most appropriate where individual’s data is used in ways they would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing.

Reliance on legitimate interests requires a review of the “reasonable expectations” of the individuals based on their relationship with the controller and whether the individual could “reasonably expect at that time and in the context of the collection of the personal data that processing for that purpose may take place

On this basis, we believe that journalists, social media and political influencers who are actively engaging within discourse and debate within a specific profession would reasonably expect their details to be used by communications professionals for the purposes of building mutually beneficial relationships and increasing their own visibility.

What personal information we collect?

We will collect personal data relating to individual social media users who have made mentions on those platforms which can include:

  • Name
  • Social Media handle
  • Affiliation as provided by user in social media profile
  • Profile picture
  • Number of social media followers
  • The country of residence defined by author
  • Publicly available content published by that Author

We obtain the information we hold about you from publicly available sources where you have posted content, including your publicly available social media profiles on Facebook, and Twitter. For our research purposes we use data from social media platforms and aggregators, using up-to-date personal data as provided by users in their social media profiles at the time of our research

What we don’t do:

  • We never collect sensitive personal information including but not limited to: healthcare status, religious beliefs, sexual orientation, financial status, personal relationships or family status.
  • We do not knowingly work with personal data of minors.
  • We do not combine data sources and keep our research to one social platform at a time. If we identify a relevant expert influencer in one social media, we would not be looking to supplement their profile with information available elsewhere.

Subject Access Request (SAR)

Under GDPR, individuals will have rights including the right to be informed; access their personal data; rectify inaccuracies or omissions; request deletion or removal of data once it is no longer required; restrict the processing of their data; and object to the use of their data. If at any time you want to see or amend your influencer data, please email us at and we will process your request within 3 working days.

For further information on your rights under the data protection laws please do see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

How we share your personal data and who we share it with

We may share your personal data with our customers. We may also transfer your personal data outside of the European Economic Area (EEA), but only when specific contracts approved by the European Commission have been put in place in order to protect your personal data.
Our customers are typically communications and marketing departments within businesses or other institutions, or PR agencies. Our customers come from all business sectors.

How long will we use your personal data?

We will keep your personal data only for as long as is necessary for the purposes set out in this privacy notice and to fulfil our legal obligations.

If you have any questions about this Privacy Policy or want to report a potential data breach, please reach out to our Data Protection Officer at