What is the purpose of this document?
Business Clan Ltd (“Business Clan”) is committed to protecting the privacy and security of your/the Delegate(s) personal information.
This privacy notice describes how we may collect and use personal information about you/the Delegate(s) when you register personal data with us in relation to a training course booked via Eventbrite, in accordance with the UK General Data Protection Regulation (“GDPR”).
Business Clan is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you/the Delegate(s). We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you/the Delegate(s)
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
By registering for a Course via Eventbrite we may collect, store, and use the following information about you/the Delegate(s):
• full name
• job title
• organisation name, registered address and registration number
• phone numbers
• email addresses
• accessibility requirements
• dietary requirements
• where you heard about the event
How is your/the Delegate(s) personal information collected?
We collect personal information through the Training Course Booking Registration Form on Eventbrite and through any subsequent emails with you about the Course.
How we will use information about you/the Delegate(s)
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:
1. Where we need to perform a contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information with your/the Delegate(s) explicit written consent. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Information about criminal convictions
Situations in which we will use your/the Delegate(s) personal information
The situations in which we will process your/the Delegate(s) personal information are listed below.
• to register and facilitate your/the Delegate(s) attendance on the Course
• to analyse attendance at and any subsequent marketing communications in relation to the Course
• to provide updates and details relating to the Course
• to manage your/Delegate(s) contacts, queries, complaints or disputes
• to take photographs and record videos of the Course and to produce promotional material to advertise the Course and to promote future courses
• to provide you with updates relating to other courses/events you might be interested in
• to market certain services which we believe will be of relevance or interest to you
• to handle any legal claims or regulatory proceedings and ensure legal regulatory compliance
Legal basis for processing personal data
The legal basis relied on by us for processing your/the Delegate(s) personal data in relation to holding the Course is out of necessity for the performance of a contract.
The legal basis relied on by us for communicating marketing to you is legitimate interests. Our legitimate interest is to promote our events that could interest you and to monitor the effectiveness of promotional campaigns.
We may photograph or film some of the Course. Where these feature long shots or group shots where individuals recede into the background the legal basis relied on by us is legitimate interests – the legitimate interest of having a record of the Course and the means to promote other courses run by us in future years. Where a photograph/film features individuals or small groups we will obtain the consent of the specific Delegate(s) by means of a consent form on the day of the Course.
Where you or Delegate(s) provide, in the registration form or by subsequent email, special categories of data (including data which reveals health or medical conditions) the legal basis for processing such information will be consent and our purpose will be to ensure safety and wellbeing on the Course.
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.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why we might share your/the Delegate(s) personal information with third parties
We will share your personal information with third parties where required by law, where it is necessary to facilitate your/the Delegate(s) attendance on the Course or where we have another legitimate interest in doing so. For example, we will communicate your/the Delegate(s) personal data to the venue and subcontractors engaged in relation to the Course.
Our legal grounds for doing so are that: it is necessary for entry into a contract; and it is in our legitimate interest to engage service providers to help with the organisation and provision of the Course.
We may share any of your/the Delegate(s) personal data that is relevant, where appropriate, with our legal and other professional advisers, in order to obtain legal or other professional advice about matters related to you/the Delegate(s) in the course of dealing with legal disputes with you/the Delegate(s). Our legal grounds for sharing this personal data are that: it is in our legitimate interests to seek advice to clarify our rights/obligations and appropriately defend ourselves from potential claims.
How secure is your/the Delegate(s) information with third-party service providers
All our third-party service providers are required to take appropriate security measures to protect your/the Delegate(s) 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.
We have put in place measures to protect the security of your/the Delegate(s) information.
Third parties will only process your/the Delegate(s) 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/the Delegate(s) 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/the Delegate(s) personal information on our instructions and they are subject to a duty of confidentiality.
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 we will retain personal information for
We will only retain your/the Delegate(s) 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.
In all cases, we will not keep your/the Delegate(s) personal data for longer than we need it for our legitimate purposes.
In some circumstances we may anonymise your/the Delegate(s) personal information so that it can no longer be associated with you/the Delegate(s), in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
Please inform us of changes to your/the Delegate(s) personal information
It is important that the personal information we hold about you/the Delegate(s) is accurate and current. Please keep us informed if your/the Delegate(s) personal information changes.
Your/the Delegate(s) rights in connection with personal information
Under certain circumstances, by law you/the Delegate(s) have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you/the Delegate(s) 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/the Delegate(s). This enables you/the Delegate(s) to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your/the Delegate(s) personal information. This enables you/the Delegate(s) to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You/the Delegate(s) also have the right to ask us to delete or remove your personal information where you/the Delegate(s) have exercised your right to object to processing (see below).
• Object to processing of your/the Delegate(s) personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your/the Delegate(s) particular situation which makes you/the Delegate(s) want to object to processing on this ground. You/the Delegate(s) also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your/the Delegate(s) personal information. This enables you/the Delegate(s) to ask us to suspend the processing of personal information about you/the Delegate(s), for example if you/the Delegate(s) want us to establish its accuracy or the reason for processing it.
• Request the transfer of your/the Delegate(s) personal information to another party.
If you/the Delegate(s) 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 our Data Protection Lead in writing.
No fee usually required
You/the Delegate(s) 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/the Delegate(s) 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/the Delegate(s) 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 our Data Protection Lead. 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.
Data Protection Lead
We have appointed a Data Protection Lead to oversee compliance with this privacy notice. If you/the Delegate(s) have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Lead. 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/the Delegate(s) personal information.
If you have any questions about this privacy notice, please contact our Data Protection Lead by emailing firstname.lastname@example.org.