Fairmondo UK Privacy Notice 2018
This privacy notice describes how we acquire, store, process and dispose of personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).
Who are Fairmondo UK?
Fairmondo UK Ltd is a Cooperative Society registered with the Financial Conduct Authority. We are a member owned business building ethical online marketplaces and trade.
In the legitimate pursuit of our business objectives Fairmondo UK as a ‘data controller’ acquires, stores, processes and disposes of personal information about you. This notice does not form part of any contract with you.
It is important that you read this notice, together with any other privacy notice and our Data Protection Policy which we may provide on specific occasions when we are collecting or processing personal information about you, so you are aware of how and why we are using such information.
What kind of personal information do we collect and use?
We will ask you to supply only relevant personal information to enable us to provide the specific service requested, this may include (but not exclusively):
- Contact details including email address, phone number and social media username.
- Date of birth – where we need to conduct money laundering checks.
- Organisation – any organisation that we know you are affiliated to.
- Job title.
- Details of how you have used Fairmondo UK products, services and events attended and how you have interacted with our email and web content and any feedback collected.
- Bank details used to enter into/renew membership of Fairmondo UK and purchase products/services.
- When registering for events we ask for dietary requirements and requirements around access (e.g. disabilities).
- Where a client has asked us to incorporate an entity on their behalf we collect information necessary to process the incorporation which includes a person’s National Insurance number, mother’s maiden name, town of birth and ‘names previously known by’.
- Information you have requested on services and products.
We will not ordinarily request sensitive personal information.
When is your personal information collected?
We will ask you for personal data when:
- You apply for membership;
- Register to use one of the products or services we provide;
- Become an employee of the cooperative;
How will personal information be collected?
Information will be collected:
- using online forms
- paper forms
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform a contract we have entered into with you, for example, Contacting you with regard to your membership of Fairmondo UK, its operations, events and governance or, When you have purchased a product or service from Fairmondo UK.
- Where we need to comply with a legal obligation, for example, where we need to conduct money laundering checks or, to comply with our rules and corporate legislation.
- 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, for example, to communicate with you to fulfil our objectives unless you have specifically informed that you do not wish to receive such communications from us.
- Where you have freely given, specific, informed and unambiguous consent to the processing of your personal information for one or more specific purposes, for example, contacting you with regard to your membership of Fairmondo UK, its operations, events and governance; when you have purchased a product or service from Fairmondo UK; where you have subscribed to a mailing list to keep informed about our work.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests), for example, where we are asked by legitimate external agencies and authorities to share this information.
- Where it is needed in the public interest or for official purposes, for example, where we are asked by legitimate external agencies and authorities to share this information.
What happens if I do not provide personal information?
If you fail to provide certain information when requested, we may not be able to fulfil our contract with you.
Change of purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Will we share your data?
We will not ordinarily share your data with third parties and where there is a legitimate and specific reason for sharing we will inform you and require your consent.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to fulfil a contract for goods or services with you, to administer our membership relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities. The following activities are carried out by third-party service providers:
- Provision of IT services
- Formation of companies
- Compliance with ‘anti’-money laundering legislation
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with third parties?
We may share your personal information with third parties, for example in the context of where we have a legitimate business relationship with a contractor to deliver services on our behalf or to perform a contract, and to comply with ‘anti’-money laundering legislation. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We will transfer the personal information we collect about you to the USA outside the EU for processing and storage. There is an adequacy decision by the European Commission in respect of the USA. This means that the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information. To ensure your personal information receives an adequate level of protection we have put in place the following appropriate measure to ensure your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection. Organisations processing data in the USA are certified under the Privacy Shield Framework. Further information about protective measures can be requested from Fairmondo UK’s Named Director.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Fairmondo UK.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from Fairmondo UK. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purpose
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Named Director at Fairmondo UK in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Fairmondo UK, through the Named Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Our Named Director oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Named Director. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact email@example.com