Data Protection Privacy Notice

THE JOHN SPEAK LANGUAGE TRUST

DATA PROTECTION PRIVACY NOTICE

issue date May 2018

The John Speak Language Trust (“Trust”) is part of the West and North Yorkshire Chamber of Commerce and Industry, Registered Charity number 529115, run under the authority of the Trust’s trustees (“Chamber”, “we”, “us”, “our”). The Chamber is registered with the Information Commissioner’s Office (“ICO”) under number

If you have any questions about this privacy notice (“Notice”), please contact us by email at John.Speak@wnychamber.co.uk.

The Chamber will process your and third parties’ personal data, as further explained below, in the course of considering, granting and administering foreign language grants, together with publishing a website on behalf of the Trust, along with other ancillary marketing and business development services solely associated with the Trust (“Services”).

We will let you know, by posting on our website or otherwise, if we make any changes to this Notice from time to time. Your continued receipt of grant funds after notifying such changes will amount to your acknowledgement of the amended Notice.

What is Personal Data?

“Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, dates of birth, educational history, current travel plans, future employment plans, email address, phone number, IP address, location data, photographs, personal facts and opinions of data subjects, cookies and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject or data concerning health.

The Chamber may process personal data and special categories of personal data which you provide in connection with the Services about yourself and other data subjects, e.g. individuals (e.g. referees; friends; colleagues) whose details and data are included in any materials provided by you to the Chamber. The Chamber may obtain information about you and other data subjects from third party service providers, such as due diligence platforms. If you use our online Services, the Chamber may collect information about your devices including clickstream data.

The provision of certain personal data is needed in order for the Chamber to provide the Services. You warrant on a continuous basis that your personal data is accurate, complete and up to date. Failure to comply may result in documents being rejected and foreign language grants being withheld or withdrawn.

In relation to the provision by you of personal data of other data subjects you warrant to the Chamber on a continuous basis that, where applicable, you are authorised to share such personal data with the Chamber in connection with the Services and that wherever another data subject is referred to, you have obtained the explicit and demonstrable consent from all relevant data subjects to the inclusion and use of any personal data concerning them.

How do we use your personal data?

The Chamber will only process personal data in connection with the Services in accordance with applicable law, for the following purposes:

responding to grant applicants’ queries, requests and other communications;
providing the Services, in particular the Trust’s website;
enabling suppliers and service providers to carry out certain functions on behalf of the Chamber in order to provide the Services, including webhosting, data storage, identity verification, technical, logistical or other functions, as applicable;
allowing you to use the “contact us” feature on our website, when you choose to do so;
ensuring the security of the Chamber and preventing or detecting fraud;
administering the Trust and the Chamber, including complaints resolution, troubleshooting of our website, data analysis, testing of new features, research, statistical and survey purposes;
developing and improving our Services;
complying with applicable law, guidelines and regulations or in response to a lawful request from a court or regulatory body; and
marketing and fund-raising activities from alumni of the Trust, as well as from other interested parties.

The legal basis for our processing of personal data for the purposes described above will typically include:

processing that is necessary to administer grant applications made by data subjects and to comply with the legal provisions of any grant awards made, such as processing for the purposes set out in paragraphs (a), (b), (b) and (d);
your consent, such as processing for the purposes set out in paragraph Error! Reference source not found.;
processing necessary for our or a third-party’s legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (e), (f) and (i), which is carried out on the basis of the legitimate interests of the Trust and the Chamber to ensure that the Services are properly provided, the security of the Chamber and its clients and the proper administration of the Trust and the Chamber; and
processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (h), and
any other applicable legal grounds for processing from time to time.

What exactly are cookies?

In order to collect the information including personal data as described in this Notice, we may use cookies and similar technology on our website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the Services offered through our website may not function properly if your cookies are disabled.

Cookies can be first-party or third-party cookies.

First-party cookies – cookies that the website you are visiting places on your device.
Third-party cookies – cookies placed on your device through the website but by third parties, such as Google.

The cookies placed on our website

We use the following cookies on our website:

Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, some or all of the Services you have asked for cannot be provided. They are deleted when you close the browser. These are first-party cookies.
Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first-party cookies.
Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise, where applicable. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.

We may combine information from these types of cookies and technologies with information about you from other sources.

Cookie consent and opting out

We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Services.

Disclosure of personal data

There are circumstances where the Chamber may wish to disclose or is compelled to disclose your personal data to third parties. These scenarios include disclosure to:

our suppliers and service providers to facilitate the provision of the Services, including data storage providers in the UK, translators, IT consultants, webhosting providers, identity verification partners (in order to verify your identity against public databases), consultants, for example, in order to protect the security or integrity of the Trust’s and Chamber’s activities, including our databases and systems and for business continuity reasons;
public authorities (i) where we are required by law to do so or (ii) to carry out acts which may be necessary in connection with the Services, such as contacting the Foreign Office in emergencies;
foreign organisations to carry out acts which may be necessary in connection with the Services, such as foreign Embassies, Consulates and High Commissions; and
any other third party where you have provided your consent.

International transfer of your personal data

We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred to foreign organisations such as foreign Embassies located in the UK or abroad, either if we are required to do so by applicable law, or in any emergency (but not otherwise). Such organisations will process personal data in accordance with the laws to which they are subject and international treaties over which the Chamber has no control.

Retention of personal data

Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law. For example, the Notaries Practice Rules require that that notarial acts in the public form shall be preserved permanently. Records of acts not in public form shall be preserved for a minimum period of 12 years. Please contact us for further details of applicable retention periods. Personal data may for reasons of security and convenience be stored on remote data facilities but in an encrypted form.

Security of personal data

The Chamber will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.

However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot therefore guarantee the security of your information transmitted to us on the web.

Data subject rights

Data subjects have numerous rights in relation to their personal data. For further information about your data protection rights please visit the ICO website at https://ico.org.uk.

Right to make a subject access request (SAR). Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other data subjects. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and payment, where applicable.
Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete personal data.
Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal data carried out by the Chamber on the basis of previous consent. Such withdrawal will not affect the lawfulness of processing based on previous consent.
Right to object to processing, including automated processing and profiling. The Chamber does not make automated decisions. Profiling may be carried out for Chamber administration purposes, such as monitoring trends in user visits of our website. The Chamber may use third party due diligence platforms which provide recommendations about data subjects by automated means. We will comply with any data subject’s objection to processing unless we have a compelling overriding legitimate ground for the processing, the processing is for the establishment, exercise or defence of legal claims or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
Right to erasure. Data subjects may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping some or all of the personal data, such as the Chamber’s accounting and bookkeeping obligations that we have to comply with.
Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as a legal obligation to continue processing your personal data in a certain way.
Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly-used and machine-readable format and have it transferred to another provider of the same or similar services. To the extent such right applies to the Services, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be required for legitimate and lawful purposes.

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View the West & North Yorkshire Chamber Privacy Policy here