Privacy Policy

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Thomas Murray collects and processes your personal data through your use of this website, including any data you may provide or that may be provided to us through this and other Thomas Murray websites when you sign up to our newsletters or market newsflashes, subscribe to a service, or create a user account, or when your organisation provides us with your details for its business purposes.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Thomas Murray comprises different legal entities, including Thomas Murray Network Management Limited, Thomas Murray Limited, Thomas Murray Technology Limited, Thomas Murray Cyber Limited, Thomas Murray Custodian Monitoring Inc, GTMCOL S.A.S., and Thomas Murray Global Limited.

This privacy notice is issued on behalf of the Thomas Murray group. When we mention “Thomas Murray”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Thomas Murray group that is responsible for processing your personal data.

Thomas Murray Network Management Limited is the controller responsible for this website. Where you purchase, subscribe to, use, or enquire about a product or service provided by another Thomas Murray group company, we will let you know which Thomas Murray group company is the controller for your personal data in relation to that product or service.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice and our handling of personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

CONTACT DETAILS

Our full details are: 
Thomas Murray Network Management Limited 
Data Protection Officer: Andrew Wright
Email address:  dpo@thomasmurray.com
Postal address: Smiths Square, 77-85 Fulham Palace Road, London W6 8JA, UK
Telephone number: +44 (0)20 8057 7100

Data protection complaints

If you are unhappy with how we have handled your personal data, or how we have responded to a request to exercise your data protection rights, you may make a data protection complaint by contacting our Data Protection Officer using the details above.
Please provide enough information for us to understand your complaint and identify the personal data, processing activity, service or communication to which it relates. We may need to ask you for further information to verify your identity or understand your complaint.
We will consider your complaint and respond within a reasonable period. If we are unable to resolve your complaint, or if you remain dissatisfied, you may complain to the ICO.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to consider and respond to your concern before you approach the ICO. Please contact us in the first instance using the details above.

EU representative

We have appointed IT Governance Europe Limited to act as our EU Representative under the EU General Data Protection Regulation (EU GDPR). If you are located in the EU/EEA and wish to exercise your rights under EU GDPR, or have any queries in relation to your rights or privacy matters generally, you may contact our Representative at eurep@itgovernance.eu or post your request or query to:

EU Representative, IT Governance Europe, The Mill, Newtown Link Rd, Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland

When contacting our representative please ensure you include our company name in any correspondence.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 26 August 2026 to update controller/contact details, add complaints handling wording, expand website technology disclosures, update marketing wording to reflect B2B legitimate interests, PECR consent/soft opt-in where required, and preference/opt-out mechanisms, and refresh wording on special category data, live chat transcript retention, international transfers, retention categories, and internal/external third-party recipients.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, and title.
• Contact Data includes department, job title and function, location or business address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Thomas Murray websites.
• Profile Data includes your username and password, application permissions to access data/reports and carry out administrative functions, and individual preferences regarding user interface language, report parameters and email notifications.
• Usage Data includes information about how you use our websites, products and services.
• Marketing and Communications Data includes your preferences for receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not normally collect Special Categories of Personal Data about you through our public website or marketing activities. Special Categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We also do not normally collect information about criminal convictions and offences through our public website or marketing activities.

Please do not provide Special Categories of Personal Data or information about criminal convictions and offences when using our website, forms, live chat, or other general communication channels unless we specifically ask you to do so.

In limited circumstances, certain Thomas Murray services, including cybersecurity advisory, incident response, forensic investigation, expert witness or related professional services, may involve processing Special Categories of Personal Data or criminal offence data. Where this is necessary, we will process such data only where permitted by law and subject to appropriate contractual, security and confidentiality safeguards.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you or your organisation and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our websites;
  • subscribe to our services or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • or give us feedback.

• Automated technologies or interactions. As you interact with our websites, online services, emails, advertisements, forms, landing pages, live chat and other digital communications, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions, interaction with our communications and usage patterns.

  We may collect this personal data by using cookies and similar storage and access technologies, including tags, pixels, scripts, local storage, server logs and similar technologies. These technologies may be provided by us or by service providers acting on our behalf, including website hosting, analytics, customer relationship management, marketing automation, live chat, advertising and security providers.

  We currently use technologies including Google Analytics 4, Google Tag Manager, Google Ads and remarketing tags, HubSpot functionality, and cookie consent management tools. Our website currently uses a Drupal cookie consent plugin provided by OneTrust. Following migration of our public website to HubSpot, we expect to use HubSpot’s cookie banner and consent management tools.

  Please see the Cookies and similar technologies section of this Privacy Policy and our cookie preference tools for further details on the technologies we use and how you can manage your choices.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Identity and Contact Data from your employer or contracting organisation or one of its agents or counterparties where we act as a data processor on behalf of a client or respondent acting as data controller, for example to create user accounts in a Thomas Murray website or application
  • Technical Data from the following parties:
    1. Technical Data, Usage Data and Marketing and Communications Data from analytics, marketing automation, advertising, customer relationship management, live chat, website hosting, security, search information and consent management providers, including providers such as Google, HubSpot, OneTrust and Microsoft, which may be based inside or outside the UK and EEA.
    2. Identity Data, Contact Data, Profile Data, Usage Data and Marketing and Communications Data from forms, landing pages, live chat, email campaigns, customer relationship management systems, marketing automation tools and web applications.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as WorldPay based inside the UK or EU.
  • Identity and Contact Data when you register for a user account in one of our web applications.
  • Identity and Contact Data from data brokers or aggregators such as LinkedIn based outside the UK and EU.

  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK.

     

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or with your employing or contracting organisation.
• Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than where you have opted in to marketing use e.g. for direct email newsletters or web advertising purposes. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

You may receive marketing communications from us if you have requested information from us, purchased services from us, subscribed to our publications, attended or registered for an event, provided your business contact details to us, or otherwise engaged with us or our services, and you have not opted out of receiving that marketing.

For business-to-business marketing to corporate subscribers, we generally rely on our legitimate interests in developing our products and services and growing our business. Where the Privacy and Electronic Communications Regulations require consent or allow reliance on the soft opt-in, we will process your marketing preferences accordingly.

Every marketing email we send includes a means to unsubscribe or customise your marketing preferences. You may also contact us at any time to ask us to stop sending marketing communications.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Thomas Murray group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions by you or your organisation.

Cookies and similar technologies

Our websites and online services use cookies and similar technologies. These may include cookies, tags, pixels, scripts, local storage, server logs and other technologies that store information on, or access information from, your device.

We use these technologies for purposes including operating our website, remembering your preferences, maintaining security, understanding how visitors use our website, improving our website and services, supporting live chat and forms, managing marketing communications, measuring campaign performance and, where enabled, delivering or measuring advertising.
Some technologies are necessary for our website or services to work properly. Others, such as analytics, marketing or advertising technologies, may require your consent. Where consent is required, we will ask for your consent through our cookie banner or preference management tool. You can withdraw or change your consent at any time using the cookie preference tools made available on our website.

We currently use technologies including Google Analytics 4, Google Tag Manager, Google Ads and remarketing tags, HubSpot functionality, and cookie consent management tools. Our website currently uses a Drupal cookie consent plugin provided by OneTrust. Following migration of our public website to HubSpot, we expect to use HubSpot’s cookie banner and consent management tools.

If you disable or refuse some cookies or similar technologies, some parts of our website or online services may become inaccessible or may not function properly.

Please refer to our cookie policy or cookie preference tool for further details on the specific technologies we use, their providers, purposes and duration.

Live chat and AI-assisted chat

Our website may provide live chat, chatbot or similar online communication functionality. This may be provided through HubSpot or other service providers acting on our behalf.

If you use live chat or chatbot functionality, we may collect and retain your name, business contact details, organisation, technical information, chat transcript, enquiry details and any other information you choose to provide during the conversation. We may use this information to respond to your enquiry, provide support, follow up with you, manage our relationship with you, improve our services and maintain records of communications.

Some chat functionality may use AI-assisted features to help respond to enquiries, route messages or support our staff. You should not submit Special Categories of Personal Data, criminal offence data, confidential information or sensitive business information through live chat unless we specifically ask you to do so and appropriate arrangements have been put in place.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Thomas Murray group and with service providers, professional advisers, clients and other third parties where this is necessary for the purposes described in this privacy notice. This may involve transferring your personal data outside the UK and the European Economic Area (EEA).

Some Thomas Murray personnel may access limited business contact, account, support, service or communication data from countries outside the UK and EEA, including where this is necessary to provide our services, support users, administer web application accounts, send service-related communications or manage client relationships.

Whenever we transfer personal data outside the UK or EEA, we ensure that a similar degree of protection is afforded to it by using one or more of the following safeguards where required:

• transferring personal data to countries, territories or organisations that are covered by UK adequacy regulations or, where EU GDPR applies, by an adequacy decision of the European Commission;
• using standard data protection clauses or other appropriate transfer mechanisms recognised under UK GDPR or EU GDPR, such as the UK International Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses, or EU standard contractual clauses;
• relying on other legally permitted safeguards, certifications, approved frameworks or derogations where applicable.

Where we act as a processor on behalf of a client organisation acting as controller, we may transfer personal data to that client organisation or process personal data in accordance with that client’s instructions. In such cases, please refer to the relevant controller’s privacy notice for further details where applicable.

You may contact us if you would like further information about the safeguards used for a particular transfer.
 

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data only for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying legal, regulatory, accounting, reporting, contractual, audit, security or legitimate business requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, whether we can achieve those purposes through other means, applicable legal requirements, and whether the data may be needed to establish, exercise or defend legal claims.

In general:

• customer contract, billing, transaction and core relationship records may be retained for up to seven years after the relevant customer relationship, contract or record ceases to be active, unless a longer period is required or permitted by law;
• web application account records may be retained for the duration of the account and then for such further period as is necessary for contractual, audit, security, legal or service management purposes;
• marketing and prospect records are retained while they remain current or while we continue to have a legitimate business reason to maintain the relationship or contact record, and are reviewed periodically;
• where you opt out of marketing, we may retain limited suppression information for as long as necessary to ensure that your marketing preferences are respected;
• live chat, enquiry and support records are retained for as long as reasonably necessary to respond to the enquiry, manage the relationship, provide services, maintain business records, investigate issues, or establish, exercise or defend legal claims;
• website analytics, cookie, tag, advertising and similar technology data are retained according to the settings and retention periods applied in the relevant website, analytics, advertising, consent management or marketing platform.

In some circumstances you can ask us to delete your data: see  Request erasure below for further information.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you. We may use anonymised information indefinitely without further notice to you.
 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

INTERNAL THIRD PARTIES

Other companies in the Thomas Murray group acting as controllers, joint controllers or processors, as applicable, and personnel located in the UK and other countries who provide client services, cybersecurity advisory services, technology services, IT and system administration services, customer support, marketing, finance, administration, service delivery and leadership reporting.

EXTERNAL THIRD PARTIES

• Service providers acting as processors who provide IT, hosting, customer relationship management, marketing automation, analytics, advertising, website, live chat, payment, communication, support, security, administration and system services.
• Professional advisers acting as processors, controllers or joint controllers, including lawyers, bankers, auditors, accountants and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators, public authorities, courts, law enforcement agencies and other authorities acting as controllers, processors or joint controllers where they require reporting or disclosure of processing activities or personal data in certain circumstances.
• Clients, suppliers, agents, counterparties and other business contacts where this is necessary for the purposes described in this privacy notice.
   

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.