CPI’s policy on privacy and use of personal data
2. Collection of personal data including email addresses
We may collect personal data about you in a variety of ways, including:
- When you engage with us or access or subscribe to any of CPI’s services;
- When you access this website, including if you make an enquiry or sign up to receive our newsletter;
- When you engage with us as a potential customer or supplier or use any of the services offered by our organisation;
- When you attend a seminar or other event provided by us or in which we are involved;
- When you share your details with our staff, or connect with CPI or our staff on any social media platform; and
- From third parties and public sources.
We may collect, use, store and transfer different kinds of personal data about you, including:
- Your name, title, date of birth and gender;
- Your contact details including postal / billing addresses, email addresses and telephone numbers;
- Details of services we have provided to you or which you have supplied to us;
- Details of your employer or the organisation you work for and other employment information;
- Technical data such as internet protocol (IP) addresses;
- Marketing and communications data, including your preferences in receiving marketing from us; and
- Visual images recorded on CCTV at any of our premises.
We also collect traffic data and site statistics about the use of our site (for example page hits) but are not readily able to identify individuals from this information.
We only collect special categories of personal data about you in very specific circumstances, such as where we are required to do so in connection with any funding which may be used to benefit you or your organisation (this may include details about your race or ethnic origin and information about your health and/or any disability). We do not routinely collect information about criminal convictions and offences.
If you do not provide information requested by us from time to time, we may not be able to provide services to you or otherwise fulfil the purpose for which we have requested the information.
3. Use of personal data
We will only use your personal data where the law allows us to do so. CPI and its group companies, employees, agents, consultants and subcontractors may use your personal data and disclose it on a confidential basis to third parties for the following purposes:
- To send you publications, news and/or information about our people, products and services or events;
- To provide services to you or the organisation you work for;
- For disclosure to third parties working for us or you on the same matter;
- To send you regular updates on issues we think will be of interest to you or matters which we are working on for or with you or your organisation;
- For the purpose of employment, partnership or other engagement;
- In connection with any tender or other service commissioning by CPI or its group companies;
- To provide you with access to information and materials;
- To administer this website and monitor and audit usage;
- To help us improve our website, services and communications to you;
- To issue invoices and reminder notices, to raise queries in relation to invoicing and other matters, and to manage accounts, records and collection of payments and debts;
- For the prevention or detection of crime;
- To ensure the safety and security of our people and premises (where we may also use CCTV and record access to our buildings) which may include disclosure to relevant third parties;
- To process your requests of, and applications to, us;
- To verify eligibility for project funding;
- For disclosures to our funders and auditors and otherwise demonstrating the impact of our organisation’s receipt of public funding;
- For disclosures to or our own legal and other professional advisors and insurers;
- For advertising, marketing and public relations, including sending you direct marketing communications as well as market research;
- Where we or any of the CPI Group are the subject of a merger and/or acquisition;
- As otherwise required by law or where we are permitted by law to do so;
- Where you have given written consent to such use or disclosure; and
- For any other purpose for which this information was provided to us or for any purpose related or ancillary to any of the above.
We consider that the processing of personal data as described above is necessary for the legitimate interests of CPI. In deciding this:
- We understand our responsibility to protect your individual interests;
- We only use your personal data in ways you would reasonably expect (described above);
- We are not using personal data in ways you would find intrusive, or which could cause you harm; and
- We have considered safeguards to reduce the impact where possible.
We will also process your personal data where it is necessary in order to perform a contract we are about to enter into or have entered into with you, or where we need to do so in order to comply with a legal or regulatory obligation.
You may at any time request that we stop processing your personal data for direct marketing purposes by emailing us as set out further below.
4. Disclosure of your personal data
We may share your personal data within the CPI Group or trust companies and may share your personal data with third parties where we reasonably consider that it is in our legitimate interests to do so and your interests, rights and freedoms do not override our legitimate interests. We will not sell, resell, lease or license your personal data to any third parties.
We may share, transfer or disclose your personal data to comply with a legal requirement, for the administration of justice, to protect your vital interests, to protect the security or integrity of our databases or our website, to take precautions against legal liability, or in the event of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event.
We may share, transfer or disclose your personal data to a potential or actual successor to us.
In each case we require the relevant third party to take adequate precautions to protect your personal data and to comply with applicable law though we cannot control the use of your personal data by third parties.
Please be aware that we may transfer your personal data to countries outside the European Economic Area (EEA) where the level of protection may not be as comprehensive as it is within the EEA. We have procedures in place to ensure that your personal data is adequately protected.
5. Data Security and Retention
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. Please note that our systems are not completely secure and, though we do our best to protect data, the transmission of data to us is done at your own risk.
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.
We will only retain your personal data 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.
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.
6. Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including 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; © 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please put your request in writing to: Marketing Team, Centre for Process Innovation Limited, Wilton Centre, Wilton, Redcar TS10 4RF or by following the steps set out below.
You will not normally 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.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office; the UK supervisory authority for data protection issues. We would, however, appreciate the opportunity to deal with your concerns and therefore request that you please contact us in the first instance. Further information about data protection issues and your rights as a data subject can be found at www.ico.org.uk.
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