Privacy & User Consent


This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

The Chartered Institute of Export & International Trade, which collects and processes data for and on behalf of the Global Customs Academy (GCA), is pleased to provide the following Privacy Notice:


Personal Data

This Privacy Notice provides you with clear information as to how we process your personal data. We are obliged to use your information in line with all applicable laws. We do so in a manner that is fair by using your information in a way that you would reasonably expect when providing our services.

The Chartered Institute uses the information collected from you to provide membership, education, training and consultancy services of Global Customs Academy, make telephone contact and to email you marketing information which it believes may be of interest to you and your business. In you making initial contact you consent to Global Customs Academy and The Chartered Institute maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. The Chartered Institute also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, The Chartered Institute will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to Global Customs Academy websites, including but not limited to personally identifying information like Internet Protocol (IP) addresses. The Chartered Institute, on behalf of the Global Customs Academy, may from time to time use such information to identify website visitors and may also collect statistics about the behaviour of visitors to its websites.

Global Customs Academy websites use cookies, which are strings of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Global Customs Academy websites use cookies to help identify and track visitors and their website access preferences. Those GCA website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Global Customs Academy websites. –more information about cookies

Any information The Chartered Institute, on behalf of the Global Customs Academy, holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

The Chartered Institute, on behalf of Global Customs Academy, will only collect the information needed so that it can provide you with membership, education, training, consulting and marketing services, neither the Global Customs Academy nor The Chartered Institute sells or brokers your data.


 Legal basis for processing any personal data

To meet the contractual obligations of the Global Customs Academy and The Chartered Institute to GCA members, students and clients and to also respond to marketing enquiries.

In order to meet the requirements with respect to GDPR we request that you update your privacy policy with information about Sopro’s status as an appointed data processor.

Under the GDPR, it is stipulated that:

“Where a data controller has an online presence, the WP29 recommends that the controller provides a privacy notice which is layered. The data subject should have a clear overview of the information available to them and on finding detailed information within the layers of the notice. The Guidelines provide that the first layer should always contain information on the processing which has the most impact on the data subject and processing which could surprise the data subject.”

There are various interpretations of that statement, while we understand some clients are taking the GDPR regulations more seriously than others, in order to meet our Compliance processes, we require all clients to include a statement in keeping with (or to the effect of) the statement set out below. This is to ensure data subjects are notified of Sopro as an appointed data processor within the terms of their online privacy policy.


Clause for insertion as follows:

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected].”



Through agreeing to this privacy notice you are consenting to The Chartered Institute processing your personal data on behalf of the Global Customs Academy for the purposes outlined. You can withdraw consent at any time by emailing or writing to us, see last section for full contact details.



The Chartered Institute, on behalf of the Global Customs Academy, may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. The Chartered Institute requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Neither the Global Customs Academy nor The Chartered Institute broker or pass on information gained from your engagement with us without your consent. However, we may disclose your Personal Information to meet legal obligations, regulations or valid governmental requests. The Global Customs Academy and the Chartered Institute may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Global Customs Academy, its clients and/or the wider community.


Retention Policy

The Chartered Institute, on behalf of the Global Customs Academy, will process personal data during the duration of any membership or contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.


Data storage

Data is held in the EEA and the USA using different (multiple) servers. Where data is transferred to countries outside the EEA, we will ensure the appropriate safeguards are in place.


Your rights as a data subject

At any point whilst the Chartered Institute is in possession of or processing your personal data on behalf of Academy, all data subjects have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that the Chartered Institute refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

The Chartered Institute at your request can confirm what information it holds about you on behalf of the Global Customs Academy and how it is processed.

You can request the following information:

  • Identity and the contact details of the person or organisation (The Chartered Institute or the Global Customs Academy) that has determined how and why to process your data.
  • Contact details of the Director General where applicable
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of the Global Customs Academy or The Chartered Institute or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
  • To access what personal data is held, identification will be required

The Chartered Institute will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Chartered Institute is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made using our Subject Access Request Form or by phoning +44 (0)1733 404400 or writing to us at the address further below.

Subject Access Request Form (.pdf)



In the event that you wish to make a complaint about how your personal data is being processed by the Chartered Institute or its partners, on behalf of the Global Customs Academy, you have the right to complain to the Chartered Institute’s Director General. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

The Chartered Institute of Export & International Trade, attention of the Director General

Export House, Minerva Business Park, Lynch Wood, Peterborough PE2 6FT

Telephone +44 (0)1733 404400 or email [email protected]


Data Protection Regulator

The Information Commissioner’s Office Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone 0303 123 1113 or via their website



last update 10-07-2024

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