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 Institute of Export & International Trade (IOE&IT), which collects and processes data for and on behalf of the UK Customs Academy (the Academy), is pleased to provide the following Privacy Notice:
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.
IOE&IT uses the information collected from you to provide membership, education, training and consultancy services of the 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 the Academy and IOE&IT 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. IOE&IT also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, IOE&IT 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 the Academy websites, including but not limited to personally identifying information like Internet Protocol (IP) addresses. IOE&IT, on behalf of the 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.
Any information IOE&IT, on behalf of the 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.
IOE&IT, on behalf of the Academy, will only collect the information needed so that it can provide you with membership, education, training, consulting and marketing services, neither the Academy nor IOE&IT sells or brokers your data.
Legal basis for processing any personal data
To meet the contractual obligations of the Academy and IOE&IT to Academy members, students and clients and to also respond to marketing enquiries.
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.”
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:
Through agreeing to this privacy notice you are consenting to IOE&IT processing your personal data on behalf of the 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.
IOE&IT, on behalf of the Academy, may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. IOE&IT requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.
Neither the Academy nor IOE&IT 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 Academy and IOE&IT 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 the Academy, its clients and/or the wider community.
IOE&IT, on behalf of the 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 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 IOE&IT 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 IOE&IT 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.
IOE&IT at your request can confirm what information it holds about you on behalf of the Academy and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (IOE&IT or the 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 Academy or IOE&IT 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
IOE&IT 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 IOE&IT 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 IOE&IT or its partners, on behalf of the Academy, you have the right to complain to IOE&IT’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 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 https://ico.org.uk/