PRIVACY NOTICE
The Lockton Charitable Association Privacy Notice
Last Updated: 28 August 2020
Introduction
The Lockton Charitable Association is committed to protecting and respecting your privacy.
This privacy notice (“Notice”), together with the Terms of Use, sets out how we look after your personal data when you visit our website (regardless of where you visit it from). This Notice also describes how we collect and use personal data about you from your other interactions with us, and tells you about your privacy rights and how the law protects you. Depending on how you interact with us, different sections of this Notice will apply to you.
For the purposes of this Notice, “we”, “us” or “our” refers to The Lockton Charitable Association, a Charitable Incorporated Organisation registered in England and Wales, a charity registered in England and Wales under charity number 1169204 and in Scotland under charity number SC048148 and have our registered office at The St Botolph Building, 138 Houndsditch, London, EC3A 7AG.
Please also use the Glossary to understand the meaning of some of the terms used in this Notice.
This Notice is provided in a layered format so you can click through to the specific areas set out below.
Contents of this Notice
This Notice sets out the following:
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1. Purpose of this Notice
This Notice aims to give you information on how The Lockton Charitable Association collects and processes your personal data through your use of this website, including any data you may provide through this website, for example when you sign up to our newsletter or fill in our contact us form.
We are committed to protecting the privacy needs of children and encourage parents and guardians to take an active role in their children’s online activities and interests. We do not intentionally collect information from children, and we do not target our website to children.
It is important that you read this Notice, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. This Notice supplements the other notices and is not intended to override them.
1.2. Controller
The Lockton Charitable Association is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Laws to notify you of the information contained in this Notice.
1.3. Data Protection Manager
We have appointed a data protection manger to oversee compliance with and questions in relation to this Notice.
If you have any questions about this Notice, including any requests to exercise your legal rights, please contact our Data Protection Manager using the details set out below:
CONTACT DETAILS
Data Protection Manager
The Lockton Charitable Association
The St Botolph Building
138 Houndsditch
London
EC3A 7AG
Email: dataprotection@uk.lockton.com
1.4. Changes to this Notice and your information
This Notice may be updated from time to time. We encourage you to review this Notice regularly when you visit our website to learn more about how we are using your personal data and safeguarding your privacy.
This version is dated 28 August 2020 and historic versions can be obtained by contacting our Data Protection Manager.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5. Third Party Links
Our website may, from time to time, contain links to and from third-party websites, plug-ins and applications, including without limitation websites of our partner networks and affiliates. Clicking on those links may allow third parties to collect or share data about you. Please note that these third-party websites have their own privacy notices and we do not control those websites or accept any responsibility or liability for these privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit. This Notice is specific to our website.
2. THE DATA WE MAY COLLECT ABOUT (YOUR PERSONAL DATA)
The types of personal data that we process may include:
Personal data does not include data where the identity has been removed (anonymous data).
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM
We might collect your personal data from various sources, including:
4. THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS, OF OUR PROCESSING OF YOUR PERSONAL DATA
4.1. We set out below the purposes for which we might use your personal data:
Please note that in addition to the disclosures we have identified against each purpose, we may also disclose personal data for those purposes to our service providers, contractors and agents that perform activities on our behalf.
4.2. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Marketing communications from us
You will receive marketing communications from us if you have requested information from us (including for example where you have provided your explicit consent by way of opting-in to receiving our marketing communications in accordance with applicable law), or (where you are a corporate entity) where we consider the marketing material to be relevant to you and, in each case, you have not opted out of receiving that marketing.
Such marketing communications may include information relating to how you can be involved in our charitable work, our fundraising campaigns or events, which we think, may be of interest to you.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third parties.
Managing your Marketing Preference (including Opting Out)
You can manage your marketing preferences or ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting our Data Protection Manager at any time.
4.3. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Statement.
4.4. Change of Purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Manager.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4.5. Legal Grounds for Processing
We will only use your personal data when the law allows us to. In particular, we will rely on the following legal grounds to use your personal data:
4.6. Disclosure of your Personal Data
We may have to share your personal data with the parties set out below for the Purposes set out in the table above.
4.7. The Purposes, Categories, Legal Grounds and Recipients, of our processing of your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, including the categories of personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate, and the third parties with whom we need to share your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact our Data Protection Manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
5. DATA SECURITY
Unfortunately, the transmission of data over the internet or any website cannot be guaranteed to be completely secure from intrusion. However, we have put in place appropriate physical, electronic and procedural security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have also 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.
6. RETENTION OF YOUR PERSONAL DATA
How long will you use my personal data for?
We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
In some circumstances you can ask us to delete your personal data: see Section 8 (Your Legal Rights and Contact Details of the ICO) below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. INTERNATIONAL TRANSFERS
We may need to transfer your data to our affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the GDPR.
If you would like further details of how your personal data would be protected if transferred outside the EEA, please contact our Data Protection Manager.
8. YOUR LEGAL RIGHTS AND CONTACT DETAILS OF THE ICO
If you have any questions about this Notice or in relation to our use of your personal data, you should first contact our Data Protection Manager. Under certain conditions, you may have the right to require us to:
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provide you with further details on the use we make of your personal data/special category of data;
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provide you with a copy of the personal data that you have provided to us;
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update any inaccuracies in the personal data we hold;
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delete any special category of personal data/personal data that we no longer have a lawful ground to use;
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where processing is based on consent, to withdraw your consent so that we stop that particular processing;
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object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
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restrict how we use your personal data whilst a complaint is being investigated.
In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
If you wish to exercise any of the rights set out above, please contact our Data Protection Manager.
No fee usually required
You will not 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.
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 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your Right to Complain to the ICO
If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights in Section 8: Your Rights and Contact Details of the ICO, or if you think that we have breached the GDPR, then you have the right to complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Please see below for contact details of the ICO.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
9. GLOSSARY OF TERMS
Key data protection terms:
Data Protection Laws means all laws and regulations relating to the Processing of personal data, including the GDPR, as the same may be in force from time to time.
GDPR is the EU General Data Protection Regulation and the new UK Data Protection Act, which replaces the UK Data Protection Act 1998 from 25 May 2018.
Data Controller is an entity which collects and holds personal data. It decides what personal data it collects about you and how that personal data is used.
Information Commissioner’s Office (ICO) is the regulator (or National Competent Authority/Data Protection Authority) for data protection matters in the UK.
personal data is any data from you which can be identified and which relates to you. It may include data about any claims you make.
Processing of personal data includes collecting, using, storing, disclosing or erasing your personal data.