The FIA Foundation is a company limited by guarantee registered in England and Wales (No. 4219306) and a registered UK charity (No. 1088670) of 60 Trafalgar Square, London WC2N 5DS.
In some instances (for example for specific campaigns), we may collect further personal information about you. On those occasions we may provide you with a separate privacy notice which will provide you with further details about our use of your personal information in relation to that campaign and which is appropriate in those specific circumstances (where this is legally required). In such instances, that specific privacy notice will apply to the collection of that further personal information.
WHAT TYPE OF PERSONAL INFORMATION DOES THE FIA FOUNDATION COLLECT?
The Site allows you to interact with the FIA Foundation in many ways, such as using the “Subscribe to our mailing list” or providing you with our address so that you can write to us. If you do choose to contact us in any way, and, in doing so, provide us with your personal information, we will collect that information for our own use and for the purposes described in more detail below.
Where you choose to subscribe to receive our newsletters, or otherwise contact us (whether through the Site, or by using the contact information in the Site to do so), we will collect the following personal information from you:
- your full name;
- contact telephone number(s);
- your e-mail address; and
- any other information you choose to share with us.
As part of our follow-up contact with you, depending on the nature of your enquiry, and only where you choose to provide it, we will collect the following additional personal information about you:
- the name and address of the company you work for; and
- details of the sector in which you currently work.
Where you have signed-up or become a member, in addition to the above items of personal data which we will process, we will also collect and process:
- your username; and
The personal information which we collect from you is used to respond to any communication or enquiry which you have sent to us. Alternatively, where you have subscribed to receiving copies of our publications, we will use your personal information to provide that information to you.
The personal information which you provide us is provided on a voluntary basis, and is information which we receive directly from you. Where lawful to do so, we will also collect personal information about you from public sources (such as social media feeds), third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties.
The FIA Foundation will never sell your personal information once it has been collected and is being processed.
- HOW DOES THE FIA FOUNDATION USE INFORMATION ABOUT YOU?
Where the FIA Foundation has collected your personal information through this Site, or as a result of communications with you, that personal information will only be used in accordance with this Policy. In the event that you have provided personal information to us as part of a particular campaign or programme, your personal information will be processed in accordance with this Policy, unless we provided an additional privacy notice to you relevant to that campaign or programme. In which case, that specific campaign or programme privacy notice will apply to our handling your personal information.
In terms of this Site, and our general communications with you, we will use your personal information for the following purposes:
- to respond and/or deal with your request or enquiry;
- to administer the Site;
- for internal record keeping;
- provide you with updates about the sector and reports/articles we may publish from time to time (where you have subscribed to receive such updates only);
- to contact you by e-mail or phone for any of the above reasons;
- to provide you with information at your request;
- where necessary as part of any restructuring of the FIA Foundation;
- for compliance with legal, regulatory and good governance obligations;
- to anonymize your personal information so that we can use it (normally in an aggregated statistical format) for research purposes and analysis and improve Site performance;
- to provide you with updated versions of this privacy notice and/or to confirm that you are still happy to hear from us; and/or
- to provide your personal information to third parties (which is described in more detail below in Section 5).
Data Protection law requires that we have a legal basis for processing your personal information. In this regard, we rely on one or more of the following three lawful basis for processing personal information:
- where it is necessary in our legitimate interests, but only where those legitimate interests are not overridden by your fundamental rights and freedoms – this is used, for example, where we respond to your enquiries, or where we use information obtained from your usage of our Site to improve the Site to your and other users’ benefit, or where we engage with our third party service providers who assist us in our daily work as the FIA Foundation (discussed further below), to manage our membership information and subscriptions, to handle any complaints in relation to the work that we undertake, to maintain accurate records;
- with your consent – this is used where you have subscribed to receive news or publications from us, or have otherwise provided your consent for our processing of your personal information; or
- where it is necessary for compliance with a legal obligation – this will include responding to legal requests from government agencies, the Charity Commission, and other similar organizations which require us, by law, to provide personal information to them, where we are required to disclose information as part of any legal proceedings.
- DOES THE FIA FOUNDATION SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
Your personal information will only be made available for the purposes mentioned above (or as otherwise notified to you from time to time) to staff who properly need to know these details for their functions within the FIA Foundation.
- Your personal information will be made available to third parties (within or outside the FIA Foundation) providing relevant services under contract to us. Our service providers can be divided into the following categories of third parties:
- Professional service providers – this would include our lawyers, accountants, auditors who we may rely on to provide specialist professional advice;
- Back office support – this includes service providers who provide IT services, communications (both electronic – such as Mailchimp and website management companies and non-electronic – such as companies we use to assist with any paper mailing campaign) and support services, such as travel services, insurance brokers and advisers, building management company;
- Monitoring or evaluation of FIA Foundation campaigns/activities to assess their effectiveness and impact, which will often include working with Non-Governmental Organization partners, as well as consultants who are involved in the campaigns. This includes NGO partners and consultants.
- We will disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required by law. Only where necessary, we will disclose personal information to third parties in response to legal process (such as court action), or to enforce our agreements, to protect the rights, property or safety of the FIA Foundation, our employees, agents, and/or Site users; and
- Where you authorize us to do so, we will share your personal information with other Non-Governmental Organizations or other similar organizations who assist or work with the FIA Foundation.
- WILL YOUR PERSONAL INFORMATION BE TRANSFERRED ABROAD?
Individuals within the European Economic Area (“EEA”) should be aware that your personal information will be transferred outside of the EEA to locations which may not have equivalent protection for personal information to that within the EEA. Where this happens, the FIA Foundation take steps to protect your personal information. As such, where we are asked to allow data to be transferred outside of the EEA, for instance where one of our service providers (such as our IT service provider) hosts our data outside the EEA, we will ask for information about the safeguards in place regarding the systems where your personal information will be stored and ensure that appropriate mechanisms are in place to protect your personal information during and after the transfer, such as standard contractual clauses. We will not transfer personal data until appropriate checks have been made.
Additionally, whenever we engage new service providers, we will carry out due diligence to find out from the outset whether the nature of their operations requires the transfer of personal information outside the EEA and, if so, based on what mechanism. If satisfactory data protection measures are not in place, we will not provide them with any personal information until such time as they are.
At present, the FIA Foundation does not transfer any personal information outside the EEA.
If you have any questions about the international transfer of personal information, please contact us using the contact information provided below.
- WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND PERSONAL INFORMATION?
You have the right to request access to the personal information that we hold about you. In order for us to comply with such a request, we may require you to prove your identity before we are able to commence with any work associated with such a request, both for your security and to ensure our own compliance with data protection laws.
As well as the right to access the personal information that the FIA Foundation holds about you, you have a number of other rights in respect of your personal information under the data protection laws. These may include (as relevant):
- the right to rectification, including to require us to correct inaccurate personal information;
- the right to request restriction of processing concerning you or to object to processing of your personal information;
- the right to request the erasure of your personal information where it is no longer necessary for us to retain it;
- the right to data portability including to obtain personal information in a commonly used machine-readable format in certain circumstances such as where our processing of it is based on a consent;
- the right to object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual (however, please note, we don’t undertake such activities at the FIA Foundation at present); and
- the right to withdraw your consent to any processing for which you have previously given that consent.
Please be aware that some of these rights will only become relevant when changes to the data protection laws come into force on 25 May 2018.
If you wish to exercise any of the above rights, or if you would like to contact the FIA Foundation in respect of its data processing activities, please contact FIA Foundation at either 60 Trafalgar Square, London WC2N 5DS or via email@example.com.
- HOW LONG WILL FIA FOUNDATION KEEP YOUR PERSONAL INFORMATION
Your personal data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Policy and to allow us to comply with our legal requirements. The criteria which we use to determine personal information retention periods include:
- Member personal information: where you are, and continue to be a member of the FIA Foundation, we will keep your details on record for so long as you remain a member. If you would like to cease to be a member, please email Jane Pearce at firstname.lastname@example.org. Following which, we will retain the personal information relevant to your account for a reasonable period (up to three months), after which it will be deleted;
- Subscription to receive publications/information: where you have subscribed to receive information/publications from us, we will retain your personal information until you choose and inform us that you no longer wish to hear from us. Once you have advised us that you no longer wish to receive publications/information from us, we will remove your name from our subscription list as soon as possible, and in any event within 28 days;
- Your enquiries: where you have contacted the FIA Foundation we may retain your personal data for a reasonable period (up to three months) after we have dealt with your enquiry, unless you subscribe to receive information and/or publications from us; and
- Retention in accordance with legal and regulatory requirements: where necessary to comply with our legal or regulatory obligations, we may need to retain your personal information for longer than the periods set out above. Where this is the case, we will only retain that personal information for as long as necessary to comply with such legal or regulatory compliance purposes.
If you have any further questions regarding our holding of your personal information, please contact us using the contact information provided in Section 7 above.
- COOKIES AND WEBSITE USAGE INFORMATION
When you visit our Site, we will automatically collect certain standard internet and website log information and details of patterns about how you use the Site. The information we collect is:
- your Internet service provider;
- your operating system;
- your browser type and domain name;
- your access times on our Site;
- the website that referred you to us; and
- web pages you request.
While some of the above listed information is not your personal information, we consider that it is important to let you know about all of the information which we collect and process when you visit our Site. We use this information to better understand and improve how our Site works, to better understand which portions of our Site are the most visited, and how you got to our Site. This information helps us to improve our Site, and your experience whilst visiting it.
- monitor the Site’s performance and ensure that we deliver a fast browsing experience;
- allow you to share content with social networks, express interest in content and connect with your social media networks;
- to allow us to collect anonymous data about Site usage to help us improve the usability, content and user experience of the Site. This includes site analytics cookies such as Google Analytics. We also use Google Analytics to collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the site from and the pages they visited. For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html
For more information on the specific cookies we use on our Site please contact us using the information at Section 10 below and we will provide further information to you.
Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org.) If you do so, some of the features and services of the Site may not function properly. To opt out of being tracked by Google Analytics across all Sites visit http://tools.google.com/dlpage/gaoptout.
- CHANGES TO THIS POLICY
We keep this Policy under regular review. We may change this Policy from time to time in order to reflect changes in the law and/or our privacy practices. The date at the bottom of this Policy will be updated accordingly.
Where required by law, we will notify you of any modified versions of this Policy that affect the way we use or disclose your personal information.
This Policy only extends to your use of the Site and your communication with the FIA Foundation through the contact methods as set out on the Site. As noted above, in some instances we may provide you with additional privacy notices in relation to certain projects and/or campaigns that we may run. In such instances, the terms of those project/campaign specific privacy notices will apply to our processing of your personal information.
- CONTACT/ADDRESS DETAILS
If you have any questions about this Policy, please contact us using the below contact methods:
By e-mail: email@example.com
By writing to us at:
60 Trafalgar Square
15 May 2018