{"id":3,"date":"2019-06-20T12:16:25","date_gmt":"2019-06-20T11:16:25","guid":{"rendered":"http:\/\/dev.ukcustomsacademy.co.uk\/?page_id=3"},"modified":"2023-07-05T10:37:04","modified_gmt":"2023-07-05T09:37:04","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/www.globalcustomsacademy.com\/privacy-policy\/","title":{"rendered":"Privacy & User Consent"},"content":{"rendered":"\n\n\t

Introduction<\/strong><\/h3>\n

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.<\/p>\n

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.<\/p>\n

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:<\/p>\n

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Personal Data<\/strong><\/h3>\n

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.<\/p>\n

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.<\/p>\n

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.<\/p>\n

The 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. The Academy websites use cookies to help identify and track visitors and their website access preferences. Those Academy website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Academy websites. –more information about cookies<\/a><\/p>\n

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.<\/p>\n

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.<\/p>\n

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Legal basis for processing any personal data<\/strong><\/h3>\n

To meet the contractual obligations of the Academy and IOE&IT to Academy members, students and clients and to also respond to marketing enquiries.<\/p>\n

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.<\/p>\n

Under the GDPR, it is stipulated that:<\/p>\n

“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.”<\/p>\n

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.<\/p>\n

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Clause for insertion as follows:<\/strong><\/h3>\n

Third Party Processors<\/p>\n

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:<\/p>\n

“Digital Marketing Service Providers<\/p>\n

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:<\/p>\n

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http:\/\/sopro.io<\/a>. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io<\/a>.”<\/p>\n

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Consent<\/strong><\/h3>\n

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.<\/p>\n

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Disclosure<\/strong><\/h3>\n

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.<\/p>\n

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.<\/p>\n

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Retention Policy<\/strong><\/h3>\n

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.<\/p>\n

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Data storage<\/strong><\/h3>\n

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.<\/p>\n

Your rights as a data subject<\/p>\n

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:<\/p>\n

Right of access<\/strong>\u00a0– you have the right to request a copy of the information that we hold about you.<\/p>\n

Right of rectification<\/strong>\u00a0– you have a right to correct data that we hold about you that is inaccurate or incomplete.<\/p>\n

Right to be forgotten<\/strong>\u00a0– in certain circumstances you can ask for the data we hold about you to be erased from our records.<\/p>\n

Right to restriction of processing<\/strong>\u00a0– where certain conditions apply you have a right to restrict the processing.<\/p>\n

Right of portability<\/strong>\u00a0– you have the right to have the data we hold about you transferred to another organisation.<\/p>\n

Right to object<\/strong>\u00a0– you have the right to object to certain types of processing such as direct marketing.<\/p>\n

Right to object to automated processing, including profiling<\/strong>\u00a0– you also have the right not to be subject to the legal effects of automated processing or profiling.<\/p>\n

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.<\/p>\n

IOE&IT at your request can confirm what information it holds about you on behalf of the Academy and how it is processed.<\/p>\n

You can request the following information:<\/p>\n