WHAT IS THIS?
1. When you deal with Shoosmiths LLP in connection with your membership or other participation with theJPA.club (JPAC, or the Club), you trust us with your information. We take privacy seriously and we are committed to protecting the data you provide to us.
2. This policy explains when and why we process personal data collected from you or provided to us by third parties, how this data is used, the conditions under which it may be disclosed to others, and how it is kept secure. It also provides you with information regarding various rights you may have in respect of processing of your personal data.
3. This policy may be updated from time to time in accordance with changing privacy and data protection laws, so please re-visit this page occasionally to ensure that you are happy with any changes. If any amendments have an impact on how we process your personal data, the notice will say so.
WHO WE ARE
4. Shoosmiths LLP (we, us or our) is a limited liability partnership with registered company number OC374987 and its registered office is at 100 Avebury Boulevard, Milton Keynes MK9 1FH. Shoosmiths is a controller of personal data registered with the Information Commissioner under registration number Z3279355.
5. As we administer and organise JPAC’s activities, we are a ‘data controller’. This means that we determine why and how the personal data we collect is processed.
HOW WE COLLECT YOUR PERSONAL DATA
6. When we refer to “personal data”, we mean information that could identify you directly, such as your name, or indirectly by a certain characteristic combined with information we already hold about you, or any information we can link to those identifiers relating to you. When we refer to personal data relating to “partners”, we mean individuals who are representatives of those partners.
7. We may receive information about you from you or third parties when we are dealing with Club activities, for example promoting the Club to prospective members, registering you as a member, maintaining your Club registration, running events, assessing awards entries and personalising information about upcoming events and news to your professional interests.
8. Where we receive information about you from a third party, we will only use that information for the purposes of dealing with Club activities and to comply with any regulatory or legal obligations we are subject to.
Information that you give to us
9. You give us information about yourself when you make an enquiry about JPAC to us, become a member or partner, attend or speak at a Club event, nominate a Club member for an award, or when submitting information via our website (please see our Cookies notice), opt-in/consent forms, or by communicating with us by phone, post, e-mail, live chat, social media or otherwise. It includes additional information that you provide to us during the course of any Club activities. For example:
- your contact details;
- identification information;
- your image and voice in promotional photographs and videos, including those taken at events;
- any details from correspondence and information regarding Club activities;
- your job title and other biographical information, including any information we collect in any entry form or if you win awards we organise or that you provide to us as a speaker at a Club event; and
- your chosen nominees for awards we organise.
Information we receive from you or other sources
10. We may receive the types of information listed above about you from third parties or from published sources.
When this information may be collected
11. This information may be collected:
When organising and administering Club awards
Employers, referees, colleagues, recruiters, and professionals in the privacy community when we are collecting information submitted by you or a third party if you are nominated for an award.
When managing prizes for Club awards
Professional associations or other commercial partners where we are offering prize(s) which are sponsored or fulfilled by such third parties.
12. We may supplement the personal data collected from you with information from publicly available sources, such as information to validate your identity, address or to check nomination information you have submitted.
Information we automatically collect about you
13. We may automatically collect information about you which we may observe, detect or create without directly asking you to provide the information to us. This will mainly include information gathered automatically through your use of our website or online services. The settings on our website allow you to reject the non-essential cookies. Please see our Cookies notice for further details.
TYPE OF PERSONAL DATA WE PROCESS ABOUT YOU
14. In the course of performing the Club activities, we may process a range of personal data about you. To make it easier to understand the information that we use about you, we have divided this information into categories in the table below and provided a short explanation of the type of information each category covers (please note that not all categories may be applicable to you):
Personal data included in this category
your image and voice
your activities, actions and behaviours
your life experiences and circumstances
information which can be used to address, send or otherwise communicate a message to you (i.e. email address, postal address, employer name and job title)
information contained in our correspondence or other communications with you or about you, or about Club activities
your previous, current or future employment details
information which contains or reveals the location of your electronic device
information contained in a formal identification document or social security or other unique reference relating to you
we may record phone or video calls and meetings and retain transcripts of dialogue i.e. live chat conversations, for our records or for training purposes. If you visit one of our offices, your image may be recorded on CCTV for security purposes. Please see our main Privacy Notice for further information.
HOW AND WHY WE USE YOUR PERSONAL DATA
15. We may use the information we collect about you in the following ways.
Where it is necessary for us to perform a CONTRACT with you
16. We may use and process your personal data where we have entered into an agreement about carrying out Club activities including registering and managing your membership of the Club or the organisation and administration of awards organised by the Club.
17. We will use your information in connection with the agreement when it is needed to carry out that agreement or for you to enter into it.
Where we have a LEGITIMATE INTEREST
18. We may use and process your personal data where it is necessary for us to pursue our legitimate interests for the following purposes;
- to provide membership benefits to you and to organise and administer competitions;
- to provide career support to you if you participate in any mentoring programmes organised by the Club;
- to publish your surname and the county in which you reside if you win an award, in accordance with the terms and conditions relating to that award;
- to promote the Club and Club activities (by means other than direct marketing), including on the website and on social media platforms such as LinkedIn, and measure the effectiveness of those promotions;
- to assess and improve our Club activities and the experience for members and partners, including through recordings of any calls, live chat sessions and the use of website and social media analytics;
- for the prevention of fraud and other criminal activities;
- to verify the accuracy of the data that we hold about you and to create a better understanding of you as a member or partner;
- to create a profile of you based on any preferences you have indicated to us to enable us to decide what membership benefits to offer, Club activities to pursue or information to provide to you for marketing purposes;
- to undertake analysis to inform our marketing strategy (this may include the use of your data once it has been anonymised)
- to inform you about relevant events, products, news updates and announcements you may be interested in where we have not sought your consent and where this is permitted by law;
- to manage and deliver internal projects for improvement of the Club;
- for network and information security purposes to enable us to take steps to protect your personal data against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (e.g. where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- to assist in the management of queries, complaints or claims;
- for the establishment, exercise or defence of our legal rights.
Where required by LAW
19. We may use and process your personal data in order to comply with legal obligations to which we are subject, and for the prevention of fraud and other criminal activities.
Where you have provided CONSENT
20. We will seek consent from you where we wish to feature your identity and personal information prominently in a published press release, advertisement or testimonial or wish to include your image in a photograph or video in connection with public relations or promotional activities. Where the law requires, we will also rely on your consent to send news and events communications if you sign-up using an email address that is not a corporate work address (e.g. a webmail address).
21. You have the right to withdraw your consent at any time. Please see Withdrawing your consent section for further details.
Use of anonymised data
22. We may use data derived from the personal data we process for our legitimate purposes including our commercial research, after it has been anonymised.
23. Anonymised data is data from which individuals cannot be identified or made identifiable neither by us nor anyone else.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA
Our suppliers and service providers
24. Our agreement(s) with you may require us to provide information to third parties who will use your information for the purposes of providing services to us or directly to you on our behalf. Such third parties may include for example software providers and mailing services.
25. When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their services and we have an agreement in place that requires them to keep your data secure and not to use it other than in accordance with our specific instructions.
Others involved in Club activities
26. Manging your membership including the provision of membership benefits and awards may require us to provide information to third parties such our commercial partners, award judges and third parties fulfilling prizes. Any third party to whom we disclose information about you will be under an obligation to keep your information secure.
Other ways in which we may share your personal data
27. We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal data if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to protect your vital interests, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and clients. However, we will always take steps to ensure that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL DATA
28. All information you provide to us for our use is stored on our secure servers which are located within the UK. The third parties listed under Others who may receive and have access to your personal data may be located outside of the UK or they may transfer your data outside of the UK. Those countries may not have the same standards of data protection and privacy laws as in the UK, which means additional safeguards must be put in place.
29. We will not transfer your personal data to other countries unless we have in place appropriate safeguards, such as:
- the countries where the data is transferred are covered by the UK adequacy regulations. These countries have been assessed and approved by the UK government as having adequate protection of personal data;
- the transfer is based on standard contractual clauses (SCCs) ensuring appropriate safeguards. This may include requiring the recipients of the data to protect your personal data to an equivalent standard to that required in the UK;
- the transfer is based on a derogation for specific situations, as permitted by the data protection law; or
- where the recipient has subscribed to a UK-approved international framework, intended to enable secure international transfers.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR
30. If we collect your personal data, the length of time for which we retain it is determined by a number of factors including the type of data, the purpose for which we use that data and our regulatory and legal obligations attached to this use.
31. We maintain internally a full schedule of types of data and the specified period of time for which we will retain this.
32. Typically, the retention criteria are as follows for the following data types:
Data category / document
Membership and partner information
While you remain a member or partner representative and until the end of the calendar year following the year our relationship ends
Enquiries about membership and working with us as a partner
Until the end of the calendar year following the year we receive your most recent enquiry
Information used for judging awards
During the judging process and until the end of the calendar year following the year the prize is redeemed. Where nominees wish to withdraw, nomination information will not be retained
Details of award nominators
Until the end of the calendar year following the year the prize is redeemed
Photographs and videos
4 years unless we obtain your consent to retain the data for a longer period
|Information obtained during mentoring sessions
||We do not record any mentoring sessions but to the extent we receive or send correspondence with you in connection with them, we will hold these for 6 years from the date your participation in the mentoring programme ends
For legal and regulatory requirements
Time periods above might vary depending on legal and regulatory requirements
33. The only exceptions to this are where:
- the law requires us to hold your personal data for a longer period, or delete it sooner;
- you exercise your right to have the data erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see Erasing your personal data or restricting its processing); or
- in limited cases, the law permits or requires us to keep your personal data for longer (including indefinitely) provided we have certain protections in place.
34. You have a number of rights in relation to your personal data under data protection legislation. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, or clarification to enable us to find your personal data. Except in rare cases, we will respond to you within one calendar month from: (i) the date that we have received your clarification; (ii) we have confirmed your identity; or (iii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal data
35. You have the right to ask for a copy of the data that we hold about you by emailing or writing to us at the address at the end of this policy. We may not be able to provide you with a copy of your personal data if it concerns other individuals or we have another lawful reason to withhold that data.
36. We may charge you a reasonable fee based on administrative costs if you request a copy of data we have previously provided to you or if your request is manifestly unfounded or excessive.
37. In line with our environmental commitments, we will try to provide you with a copy of your data by electronic means where this is possible, unless you have specified otherwise in your request.
Correcting and updating your personal data
38. The accuracy of your data is important to us, therefore if you change your name or address/email address, or you discover that any of the other data we hold is inaccurate or out of date, please let us know by contacting us using the details set out at the end of this policy.
Withdrawing your consent
39. Where we rely on your consent as the lawful basis for processing your personal data, as set out under How we use your personal data, you may withdraw your consent at any time by emailing or writing to us at the address at the end of this policy. (Please use “Withdrawal of consent” as the subject heading of your email).
40. If you withdraw your consent, our use of your personal data up until the date you withdrew your consent is still lawful.
Objecting to our use of your personal data
41. Where we rely on our legitimate interests as the lawful basis for processing your personal data for any purpose(s), as set out under How we use your personal data, you may object to our using your personal data for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal data and where our interests override yours, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection legislation, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.
42. You may object to us using your personal data for direct marketing purposes and we will immediately comply with your request. If you would like to do so, please use the unsubscribe option made available in the relevant marketing communication. Alternatively, if you have signed up to receive marketing communication from us, you can access a preference management centre at any time where you can alter your preferences.
43. You may also contest a decision made about you based on automated processing by emailing or writing to us at the address at the end of this policy.
Erasing your personal data or restricting its processing
44. In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at the address at the end of this policy. Please note that this right is not an absolute right. Provided we do not have any continuing lawful reason to continue processing or holding your personal data, we will make reasonable efforts to comply with your request.
45. You may also ask us to restrict processing your personal data where you believe our processing is unlawful, you contest its accuracy, you have objected to its use and our investigation is pending, or you require us to keep it in connection with legal proceedings. We may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal data in a structured data file
46. Where we rely on your consent as the lawful basis for processing your personal data or need to process it in connection with your contract, as set out under How we use your personal data, you may ask us to provide you with a copy of that data in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.
47. You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not be able to provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that data.
Complaining about the use of your personal data
48. If you wish to complain about the way we use your personal data, you can e-mail us using the details set out at the end of this notice. If you are dissatisfied with our response to your complaint and remain concerned about the way we have processed your personal, you have the right to complain to the Information Commissioner’s Office (ICO) data or seek to enforce your rights through a judicial remedy. Please visit the ICO’s website for further details.
How we protect your personal data
49. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your personal data, we have in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
50. Where we collect any special categories of personal data about you, we will apply additional security controls to protect it.
51. Where we have given you (or where you have chosen) a password which enables you to access any of our online or electronic resources, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Links to other websites
52. Our website may contain links to other websites run by other organisations. Please see our Cookies & website privacy notice. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites even if you access them using links that we provide, and their security cannot be guaranteed.
53. If you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
Use of 'cookies'
54. Like many other websites, our website uses digital cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). 'Cookies' are small pieces of information sent to your computer and stored on its hard drive to allow our website to recognise you when you visit. Our settings for cookies enable you to reject the non-essential cookies.
MARKETING AND OTHER COMMUNICATIONS
56. You will only receive email marketing information from us (which may be tailored to you) in connection with the Club if you have provided corporate contact details (e.g. a work email address for an incorporated business) or where we have your prior consent to do so, and in each case you have not subsequently withdrawn your consent or opted-out from receiving such communications.
57. If you would like to withdraw your consent or opt-out of receiving any marketing communications, you can do so using the unsubscribe option presented to you in those communications. Alternatively, you can also access our online preference management centre at any time where you can alter your preferences. You will receive an email from us at intervals of no less than 2 years where you will be asked to confirm your contact details to ensure we keep accurate records.
58. Unsubscribing to from our marketing information will not remove our ability to contact you regarding any agreement between us or in relation to administrative matters concerning your membership of the Club. If you are a member, you will continue to receive updates on developments in privacy and data, unless you ask us expressly to stop sending these to you.
59. We may contact you in response to an article or social media promotion that you have carried out or target promotional material about the Club through social media (for example, your news feed on LinkedIn) using your job roles, work experience, and other biographical information held by the social media platform to improve the relevance of that material to you.
60. If you are a client or contact of Shoosmiths, we may contact you personally to notify you of changes in the law that might affect you or your business, or specific events/information that may benefit you or your business.
61. We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. Any such recipients will be contractually bound to safeguard the data we entrust in them and will not contact you to offer other services.
62. Please see Objecting to our use of your personal data and automated decisions made about you above for further details on how you can do this.
63. We use a number of different social media platforms to communicate with you and to promote products and services. In particular, we use your personal information when you post content or otherwise interact with us on our official pages on LinkedIn, Twitter, and other social media platforms. We also use the Page Insights service for LinkedIn to view statistical information and reports regarding your interactions with the pages we administer and advertisements we target on those platforms and their content. Where those interactions are recorded and form part of the information we access through these Page Insights services, we and the relevant platform are ‘joint controllers’ of the processing necessary to provide that service to us.
64. As ‘joint controllers’, we and LinkedIn are jointly responsible to you under data protection laws for this processing and so we have together:
entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
agreed that we are responsible for providing to you the information in this privacy statement about our relationship with LinkedIn; and
agreed that LinkedIn is responsible for responding to you when you exercise your rights under data protection law in relation to LinkedIn’s processing of your personal information as a joint controller.
65. LinkedIn also processes, as our processor, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing these platforms carry out when they display our advertisements to you in your news feed at our request after matching details for you that we have requested or provided. These advertisements may include forms through which we collect contact information you give to us.
66. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. For further information regarding LinkedIn and its use of your personal information, please see:
- LinkedIn’s Page Insights Joint Controller Addendum which includes information regarding how our and LinkedIn’s responsibilities to you are allocated as controllers of your personal information;
- LinkedIn’s help pages regarding its Page Insights and its terms and conditions relating to its advertising services.
67. If you wish to contact us with any queries about this Notice or about the way we process your personal data, you can write to our Data Protection team at Shoosmiths LLP, The XYZ Building, 2 Hardman Boulevard, Spinningfields, Manchester M3 3AZ. Alternatively, you can contact us by e-mail at: [email protected].
Last updated: August 2023