Privacy notices

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Version number: WS2.5

ICAEW is the controller for the Personal Data collected from speakers at ICAEW events unless this is stated otherwise. ICAEW is registered with the Information Commissioner’s Office (ICO) with registration number (Z5765897). In this privacy notice, references to ‘we’, ‘us’ or ‘our’ mean ICAEW. You can contact ICAEW in a number of ways as follows:

• Email: dataprotection@icaew.com
• Post: The Data Protection Office, ICAEW, Metropolitan House, 321 Avebury Boulevard, Milton Keynes, MK9 2FZ UK
• Telephone: +44 (0)1908 248 250

Personal Data is any information which directly or indirectly identifies an individual, for example, your name, email address, member/student number.

Special categories of Personal Data are a set of Personal Data that we are required to look after even more carefully. Subject to the relevant data protection law, special categories of Personal Data may 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.

Where we collect information, we are doing so in order to offer you better services, both on the website and in the rest of our operations.

Identity Data	Name
Contact Data	Email address
Activity Data	Information of your ‘read, edit and download’ activity of documents shared with you.
Member/Student Data	Your member/student number
Web Chat Data	Any personal data provided by yourself to us via webchat
Chat Bot Data (MiaPlus)	Any personal data provided by yourself to us via the Chatbot
Website Data	Information collected during your use of our website.
Survey/Questionnaire Responses	Information provided by you in response to ICAEW Surveys and Questionnaires

We do not collect any financial information on this website. If you make a debit or credit card payment online for example, to pay subscriptions or fees, to join a Faculty or Community, or to purchase any of our services or products, you will be taken to a secure payment service provider who will take your payment on our behalf and return you to this website when your order has been completed.

We collect your personal data for the following purposes:

Purpose and/or activity	Type of Data	Legal basis for processing (subject to the relevant data protection law)
Conducting Research	Identity Data Contact Data Survey/Questionnaire Responses	Consent: Where you have consented to take part in our research activities. Legitimate Interests: in our legitimate interests to understand more about our users and how better to serve our users.
Building a profile of how you use our website and its facilities	Identity Data Website Data	Legitimate Interest - to improve our website and interactions.
Serving you with targeted and retargeted advertisements	Cookie Data	Consent: Where you have consented to the use of cookies to provide you with targeted and retargeted advertisements
Sending you Emails	Identity Data Contact Data	Consent - where you have consented to receiving the communications. Legitimate Interest: where ICAEW has a legitimate business interest to send you service/research emails
Collecting Management Information on Our Email Campaigns	Contact Data	Legitimate Interest - to improve content and services
Communicating with you via webchat and the chatbot and responding to your queries	Identity Data Contact Data Member Data Web Chat Data Chat Bot Data	Legitimate Interest – to provide easily accessible means of  communication and support.
Audit related activities to ensure ICAEW understands it business practices	A Sample of all Personal Data	Legitimate Interests: where we have a legitimate interest in auditing our internal processes and procedures to ensure that we are complying with applicable laws and internal and  managing risk appropriately.
Anonymisation of personal data for the onward activities of Management Information and Business Intelligence	All Personal Data	Legitimate Interest of the ICAEW for business improvement and intelligence purposes.
Monitoring of One Drive Downloads and activity for IT Security purposes	Identity Data Contact Data Activity Data	Legitimate Interest: in ICAEWs legitimate interest interests to ensure the safe sharing and transfer of data.
Performing system testing in order to enhance and improve our products and services	Identity Data Contact Data Education Data Career Data	Legitimate interest: In our legitimate interest to review and improve our services provided to you.
Facilitation of Courses you have signed up to	Identity Data Contact Data Career Data Activity Data	Performance of a contract.

You can delete or change your email address at any time or unsubscribe to particular types of email. You can do this by logging into your preference centre profile, or by clicking on the links provided in any of our emails.

If you have a web chat conversation, we will record a copy of that conversation which will be stored with the membership number/student number/other identification ID you used to log in to this website.

We keep Personal Data that we obtain about you for no longer than is necessary for the purposes for which it is processed, except as otherwise required or permitted by law. How long we keep your Personal Data will depend on the nature of the Personal Data concerned and the purposes for which it is processed.

ICAEW may share your Personal Data with third-party processors who provide services to the organisation where we have a legal obligation, contract or other legitimate interest to do so, subject to the relevant data protection law. These services include, but are not limited to;

• Email campaign service providers
• Insights and analytics service providers
• Webchat service providers
• We also occasionally work with external organisations to carry out market research about ICAEW on our behalf. We may share your email address with these organisations so that they can contact you directly and carry out this research independently from ICAEW. We only use organisations that adhere to the Market Research Society code of practice.

Your Personal Data may be transferred to other third-party organisations in certain scenarios in accordance with law:

1. If we are discussing a merger or acquisition, Personal Data may be transferred to respective third parties under suitable terms as to confidentiality;
2. If we are reorganised or sold, Personal Data may be transferred to a buyer who can continue to provide services to you;
3. If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority, for example the Police, we may need to share your Personal Data; or
4. If we are investigating or defending any legal claims your Personal Data may be transferred as required in connection with defending such investigations and/or claims.

In some cases, we or our suppliers may need to process Personal Data outside your country, the European Economic Area (EEA) and/or United Kingdom (UK). Where this is the case we will only share the minimal amount of Personal Data necessary for the purpose of processing and, where possible, we will share the Personal Data in an anonymised form.

Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK;
2. where we use certain processors, we may use specific contracts approved by the UK which give Personal Data the same protection it has within the UK. When we rely on this measure we will ensure that the third-party can comply with the provision of such contracts and we have confirmed that the country to which the Personal Data is transferred has adequate data protection laws in place to protect Personal Data.

Please contact us at dataprotection@icaew.com if you would like further information about the specific mechanism used by us when transferring your Personal Data

Like most websites, our server gathers limited information about you during a session, including the IP address and domain name from which you are accessing the server. We use this information to help us improve the content, design and performance of the site.

Our website software can recognise the configuration of the computer and the browser software you are using. This will help us to provide you with an optimised experience.

This site uses Google Analytics, including Google Analytics Demographics and Interests reporting. Should you wish you can opt-out of the Google Analytics advertising features used for demographics and interests reporting using. Google have provided more information and a simple plugin to allow you to do this on any website. For more information on how to opt-out of Google Analytics please visit: Google Analytics Opt-Out.

A cookie is a tiny file that is saved by your browser when you visit a website. It enables certain information about your visit to be stored by the site. We have set out full details about our use of cookies on a separate page, where you can find out which cookies we use, why we use them, and what you need to do if you don’t wish to accept some or all them.  To find out more about how we use cookies on this site please visit: ICAEW Cookie Policy.

Our website and emails may contain links to other websites. We are not responsible for the content or practices of these other sites and we recommend that you check their own privacy policies. 

We have appropriate security measures in place to prevent Personal Data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Under the relevant data protection law, you may have rights including:

1. Your right of access – You have the right to request access to, or ask us for copies of, your Personal Data.
2. Your right to rectification – You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete.
3. Your right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.
4. Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
5. Your right to object to processing – You have the right to object to the processing of your Personal Data in certain circumstances.
6. Your right to data portability – You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.
7. Rights related to automated decision making, including profiling -You have the right to ask for explanations on a decision based on automated processing that may significantly affect you, and the right not to be subjected to a decision based solely on automated processing (including profiling) which may significantly affect you. We do not make any employment decisions, solely using automated decision making technologies.

In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request, subject to the relevant data protection law. If we need to extend the time period for responding to your request, we will let you know within the period. We do not charge a fee for any such requests, unless there are exceptional circumstances.

If you wish to exercise any of your rights, please contact our Data Protection Office via email using dataprotection@icaew.com

If you have any concerns about the Personal Data we use about you, 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, by contacting them at www.ico.org.uk, or the relevant data protection authority of your country as mentioned in the applicable Appendix. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the relevant data protection authority, so please feel free to contact us in the first instance via email using dataprotection@icaew.com.

This Appendix applies to individuals who reside in the People's Republic of China (for the purposes of this privacy notice, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan) (China).

This Appendix supplements the main body of this privacy notice should be read together with the main body. In the event of any conflict or inconsistency between this Appendix and the main body of this privacy notice, this Appendix shall prevail.

Legal basis for processing your Personal Data

We process your Personal Data for the purposes mentioned in the main body of this privacy notice with your consent or as otherwise required or permitted by applicable law (e.g. where the processing is necessary for concluding or performing a contract with you, where the processing is necessary to perform legal obligations, etc.).

Processing of your Personal Data upon the expiry of the relevant retention period

We will irreversibly destroy or anonymize your Personal Data upon the expiry of the relevant retention period in a way that prevents that information from being restored or reconstructed.

Sensitive Personal Data

Sensitive Personal Data is Personal Data that, once leaked or illegally used, may easily cause the personal dignity of a natural person to be infringed or his/her personal or property security to be endangered. It includes data related to biometrics, religious belief, specific identity, medical health, financial account and location tracking, the Personal Data of a minor under the age of 14 (Minor Personal Data), as well as government issued ID information.  The sensitive Personal Data about you we process may include financial information. We only process your sensitive Personal Data where such processing is strictly necessary for the relevant purposes identified in the main body of this privacy notice. Our processing of your sensitive Personal Data will adhere to the safeguards mandated by applicable laws and regulations. However, depending on the specific type of sensitive Personal Data involved, such processing may result in various impacts, including potential harm to your reputation, property, or personal safety in the event of a data breach.

We will not knowingly collect or process Minor Personal Data except with consent of the parent or guardian or as otherwise permitted by law. When we collect or process Minor Personal Data, we will process such data in accordance with the safeguards set out in applicable laws and regulations.

If you are a parent or guardian who believes that we collect or process any Minor Personal Data of your child without your consent or would like to erase, correct, or exercise any other right regarding any Minor Personal Data of your child, or have inquiries or complaints about how we process Minor Personal Data, please contact our Data Protection Office, which is in charge of protection of Minor Personal Data, through the means mentioned in the main body of this privacy notice.

With your express consent where required, we may share your Personal Data with third parties as described in the main body of this privacy notice.

Overseas transfer of your Personal Data

As ICAEW operates globally, with your express consent where required, we may transfer your Personal Data outside of China, including to the UK and other jurisdictions where we, our service providers and other relevant third parties conduct business. In particular, your Personal Data may be transferred to our office in the UK for our storage and processing in accordance with this privacy notice.

Your additional rights

Besides the rights listed in the "Your Rights" section in the main body of the privacy notice, you also have the following rights:

1. Your right to deregister your account – You can request to deregister any account you may have with us. However, if you deregister your account, certain services or processes may be disrupted or become unavailable.
2. Your right to withdraw your consent – You can withdraw your consent to our processing of certain Personal Data about you when we rely on your consent for such processing. Please note that your withdrawal may lead to certain consequences (e.g. disruption or unavailability of certain services or processes) if such processing is strictly necessary for a certain purpose and consent is the only legal basis for our processing.

Inquiries or complaints

If you have any requests to exercise rights, inquiries or concerns about the Personal Data we use about you, please contact us at china@icaew.com. [You also have the right to make a complaint at any time to the Cybersecurity Administration of China (CAC) or its local counterparts.

This Appendix applies to individuals who reside in the Republic of Singapore. It supplements and should be read together with the main section of this privacy notice. In the event of any conflict or inconsistency between this Appendix and the main body of this privacy notice, this Appendix shall prevail.

Consent

We will collect, use or disclose your Personal Data for purposes which you have provided your consent which can be express, deemed or by notification, unless exempted, in accordance with Singapore’s Personal Data Protection Act (2012) and its regulations (PDPA). Where we have collected, used or disclosed your personal data based on consent, you may withdraw consent with reasonable notice, and we will inform you of the likely consequences of the withdrawal. 

Purpose limitation & notification

We will only collect, use or disclose Personal Data for the purposes that a reasonable person would consider appropriate under the given circumstances and for which you have given consent (unless exempted by law). 

Accuracy, access & correction

We will make reasonable effort to ensure that your Personal Data collected is accurate and complete. You have right to access Personal Data which we hold about you, request a copy of that information and details of what we have done with that information (i.e., how long we kept it for and to whom we disclosed it) within a year before your request.

You have a right to request us to correct your Personal Data where it is inaccurate or out of date. We will make the necessary corrections as soon as practicable and send the corrected data to other organisations to which your Personal Data was disclosed pursuant to this privacy notice within a year before the correction was made.

Retention limitation

We will cease retention of your Personal Data or dispose of it in a proper manner if it is no longer necessary for the purpose for which it was collected and we have no other legal ground for processing the data, or if the collection, use or disclosure of your Personal Data was based on consent and the consent has been withdrawn.

Transfer limitation

For international transfers (i.e., a cross-border disclosure) of your Personal Data from Singapore to overseas, we will put in place contractual measures to ensure the overseas recipients process your personal data in accordance with our instructions and have in place technical and organizational measures to protect your personal data with a level of protection comparable to the protection under the PDPA.

Data breach notification

We will notify you of any data breach that is or is likely to be of significant scale, or results in or is likely to result in significant harm to you.

Data portability

Where required by law, at your request, we will transmit your Personal Data that is in our possession or under our control, to another organisation in a commonly used, machine readable format.

Inquiries or complaints

If you have any requests to exercise rights, inquiries or concerns about the Personal Data we use about you, please contact our Data Protection Officer at  dataprotection@icaew.com. If we are unable to help you, you may contact Singapore’s Personal Data Protection Commission (http://www.pdpc.gov.sg).