Data protection law changes on 25^th May 2018.  We believe that this policy complies with the new legislation, however we will continue to review this policy in the run-up to the implementation of the General Data Protection Regulations, and at regular intervals thereafter.  We reserve the right to make changes to the policy when this is deemed necessary. 

We will comply with data protection law.  The personal information we hold about you should 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. 

Your privacy is protected by law.  We can only use personal information when we have a legitimate reason for doing so.  This might be:

1. To fulfil a contract we have with you (this is our primary reason).
2. When we have a legal duty.
3. When it is in our legitimate interest; or
4. When you consent to it.

As a membership subscription organisation, we require a certain amount of personal information to fulfil the contract between us and IPA members.  The information we require as a minimum is:

• Full name
• Date of birth
• Gender
• Address
• Contact number
• Email address
• Employer
• Type ratings
• Bank details

We do not share your details with any third parties other than to facilitate the continuation of your membership, and we do not send marketing material to our members. 

How we use your personal information:

The following are examples, and non-exhaustive.  

• Address – for the purposes of targeting certain geographic areas to attract members (e.g. AGM locations, employment law workshops).
• Age – to monitor the demographic of our membership.
• Gender – to monitor diversity.
• Employer – to monitor trends within the industry.  To ensure effective communication with members on issues specific to their company. 

We will not share any of these details with any third parties, unless required to fulfil the contract between the IPA and its members or required by law.  Where litigation (Employment Tribunal or court of law) is advanced on your behalf, we cannot act without using the personal information you provide to us. 

We do not envisage that we will use your personal information to make automated decisions.  Should this change, we will amend this policy accordingly and advise you. 

Sending data outside the EEA:

We will only send your data outside the EEA to:

• Follow your instructions.
• Comply with a legal duty.

If you choose not to give personal information:

We need to collect certain personal information as detailed above to enable us to provide the services available to you as an IPA member.  If you choose not to give us, or keep us updated with this personal information, it may delay or prevent us from meeting our obligations to you.  It may also mean that we cannot provide the services needed as part of your membership.  Failure to provide us with or keep us updated with personal information may result in members missing critical information relating to a) the IPA or b) their employment/employer. 

Marketing:

We do not undertake direct marketing.  As an IPA member, you may be eligible for benefits, discounts or products.  On joining the IPA, you will be advised of membership benefits, and who provides these, but your personal information will not be shared with any providers.  Unless specific consent is received for us to contact any provider on your behalf, the member will be required to make contact directly with any third party necessary to provide a benefit or product to an IPA member. 

How long we keep your personal information:

We will keep your information for the duration of your IPA membership.  Should you no longer be a member we may keep your data for up to 6 years for the following reasons:

• To be able to respond to questions or complaints about your membership.
• To evidence that you have been treated fairly in our dealings with you.
• To maintain any records according to any rules that apply to us. 

Obtaining a copy of your personal information:

You can make a subject access request (SAR) by contacting the IPA office at 38 – 42a South Road, Haywards Heath, West Sussex, RH16 4LA.  This will not normally incur a charge.  We do reserve the right to make a reasonable charge, should we consider your request is unnecessarily onerous, or refuse the request if we have legitimate grounds for doing so. 

Incorrect information:

If you think we may hold incorrect or incomplete information about you, please let us know. 

Changes to the use of your personal information:

In certain circumstances you have the right to:

1. Request erasure - of your personal information where there is no good reason for us continuing to process it.
2. Object to processing – of your personal information where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground.  We do not undertake direct marketing, however if we did so in the future, you can also object to us processing your personal information for direct marketing purposes.  You would be notified separately of changes to this policy if direct marketing became applicable. 
3. Request the restriction of processing – of your personal information.  This enables you to ask us to suspend the processing of personal information about you.
4. Request the transfer of your personal information to another party.

There may be legal reasons for us to retain your personal information even if you are no longer an IPA member.  Please contact us if you wish to change the use of your personal information. 

How to withdraw your consent:

If you have been required to provide your consent to us collecting/processing your personal information, that consent may be withdrawn at any time.  Please contact us should this apply to you.  Please bear in mind that withdrawing consent may result in us not being able to provide certain services. 

Complaints:

If you have a complaint about how we have used your personal information you can contact us at 38 – 42a South Road, Haywards Heath, West Sussex, RH16 4LA.  You may also make a complaint to the Information Commissioner’s Office. 

Cookies:

By using our website you agree to the use of cookies.  We may also use analytical tools to collect data through our website on an anonymised basis.  Nobody using our website can be identified through these analytics, therefore none of the data gathered would constitute personal information. 

Please note that you do not have to accept cookies. 

Links through our website:

Our website may contain links to other websites.  Once you leave our website we have no control and cannot be held responsible for any privacy or security issues that may arise by using that website. 

Where personal data is stored:

Personal data stored electronically is held on our secure servers and protected by appropriate security measures. Where personal data is held manually all IPA staff are subject to obligations to maintain the security of that personal data.  Debit or credit cards details provided to us are encrypted.