This page sets out important information about The Morning Paper newsletter and your privacy: the data that is collected, where it is processed, and purposes for which it is used.
Who runs The Morning Paper mailing list?
Informally, that would be me, Adrian Colyer. From a legal perspective, I operate through a UK registered company, ‘One L and a Y Ltd.’ (because Colyer is spelt with one L and a Y… it seemed a good idea at the time!). Registered company number 8975786. Contact details are at the bottom of every email and at the end of this page. I need a company in order to contract with Mailchimp and send you emails.
I use MailChimp to power the mailing list.
In the terms of the GDPR, One L and a Y Ltd. is the data controller, and MailChimp is the data processor.
Between keeping the company alive and paying the MailChimp bills, it ends up costing several thousands pounds a year to send those free emails!
Explicit consent to receive emails from The Morning Paper
There’s only ever been one way to get onto The Morning Paper newsletter email list, and that’s by explictly completing a double opt-in process. In step one, you completed a form giving your name and email address. The purpose for which that data is collected is stated very clearly on the form:
Sign up for ‘The Morning Paper’ email distribution list and never miss an edition again. I’ll send each day’s paper direct to your inbox as it is published, and of course you can unsubscribe at any time.
After completing the form, you would also have had to click the link in the opt-in confirmation email (this prevents e.g., someone else signing up your email address without your knowledge).
If you’ve made it through the sign-up form and the confirmation link in the email, this constitutes your explicit consent to receive email messages from The Morning Paper. (Which is hopefully what you wanted in the first place!).
Both the sign-up from and the opt-in email are and always have been clearly branded with the MailChimp logo. Going forward I have added explicit wording to make it even clearer that MailChimp is used as a data processor.
If you wish to be unsubscribed from the newsletter and/or have all of your data forgotten, you can request this at any time. See ‘Your data rights and how to exercise them’ below.
What data is collected and where is it processed?
The primary data collected is the name and email address you provided when you subscribed to the email list. In addition to this, by default MailChimp tracks whether you open the emails that are sent to you, and whether you click on any links in those emails. MailChimp does this using Web Beacons, as described in the “Cookies served through the services – User email campaigns” section of the MailChimp Cookie Statement. This data is retained for as long as the mailing list is in operation, and you do not explicitly request it to be deleted.
One L and Y Ltd. has a legitimate interest in knowing whether email list subscribers in aggregate are opening and engaging with the email content, so as to ensure that the content being provided remains of interest to subscribers. MailChimp’s open and link tracking mechanisms enable this legitimate interest.
Through a combination of your previously given explicit consent, and this legitimate interest claim, I will not be asking every member of this list to individually reconfirm they wish to be subscribed. If at any time, or based on the information presented here, you do wish to be unsubscribed, you can unsuscribe at any time and request for all your data to be deleted. See ‘your data rights and how to exercise them’ below.
It is possible in the MailChimp UI to disable open tracking and link tracking, but currently only on an individual email (‘campaign’) basis, and it is tedious in the interface to do this every single time. This process has finally given me the kick I needed to investigate automatic creation of campaigns through the MailChimp API, rather than the web UI, in which case it should be possible to specify no link tracking and no open tracking for every campaign.
I have configured the MailChimp account to opt-out of any use of the data MailChimp holds in MailChimp’s ‘data science projects.’
Your data rights and how to exercise them
An individual’s rights under the GDPR legislation are neatly set-out by the UK Information Commissioner’s Office here. This section explains how these rights apply in the context of The Morning Paper.
The right to be informed
You have a right to be informed about the collection and use of your personal data, including but not limited to, the purposes for which it is kept and with whom it will be shared. This document provides you with this information.
The right of access
You have a right to access your personal data that is being held. In order to receive information about an email address registered on the list, you can send a request to firstname.lastname@example.org from the registered email address for which you wish to view the information. You may also contact MailChimp directly to request access to any information they hold about you.
The right to rectification
You can update the name and email address associated with your The Morning Paper subscription at any time. A link to update your subscription preferences is included at the bottom of every email.
The right to be forgotten (erasure)
You can unsubscribe from The Morning Paper newsletter at any time using the link at the bottom of every email (including this one). When you unsubscribe, your data is retained and your account is marked as ‘unsubscribed.’ You can make a request to The Morning Paper (email@example.com) or directly to MailChimp, to have any data held about you permanently deleted.
The right to restrict processing
Your name and email address is used to send you The Morning Paper newsletter. You may request the restriction of this processing at any time, which is also known as ‘unsubscribing.’ After unsubscribing from the list you will no longer receive any emails from The Morning Paper at the subscription address. A link to unsubscribe is included at the bottom of every email. Alternatively you may contact The Morning Paper directly at firstname.lastname@example.org to request to be unsubscribed.
The right to data portability
You have a right to obtain a copy of the data you have explicitly provided to The Morning Paper to reuse for your own purposes or across different services. If you send me your name and verified subscriber email address, I will happily send you back your name and email address.
The right to object
You have the right to object to processing at any point in time. The same conditions apply as described in ‘the right to restrict processing’ above.
Rights in relation to automated decision making and profiling
The Morning Paper does not carry out any automated decision making or profiling activities.
By email: email@example.com.
One L and a Y Ltd
PO Box 6945
London, England W1A 6US