GDPR: DATA PRIVACY NOTICE FOR MEMBERS
CUBO ("We") are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
- Data controllerA controller determines the purposes and means of processing personal data.
- Data processorA processor is responsible for processing personal data on behalf of a controller.
- Data subjectNatural person
Categories of data: Personal data and special categories of personal data
- Personal data The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
- Special categories personal data The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
- Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
CUBO is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters contact Jan Capper, CEO, our data representative, on firstname.lastname@example.org.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To process your membership application and renewal
- To inform you of matters of governance
- To inform you about member benefits and activities
- To inform you about higher education developments, events, reports and research
- To give you the opportunity to network with other members via our website
- To conduct surveys to improve membership benefits and value
- To connect you with the corporate partners and sponsors of CUBO - see section 6
- For non-members we only collect personal data necessary to provide the service that you have specifically registered for, ie events, newletters, etc
You may give us information about you by filling in forms on the CUBO website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to membership, book onto a CUBO event, participate in discussion boards or other social media functions on our site, enter a competition, or complete a survey.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data [name, job title, professional e-mail address and work phone number, profile description and photograph]
We have obtained your personal data from you directly or from another CUBO Member for your institution.
5. What is our legal basis for processing your personal data?
Our lawful basis for processing your general personal data:
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract - MEMBERSHIP OF CUBO
For non-members we only perform processing necessary to provide the service that you have specifically registered for, e.g. events, newsletters, etc, and any related payments or enquiries.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared for the performance of the contract only with:
- such marketing agencies as we may properly contract and authorise to send communications about CUBO membership, events, news and benefits.
- such professional consultants as we may properly contract and authorise to communicate with you about surveys and research
- CUBO corporate partners once per year [name, job title, professional email address and employer name only]
7. How long do we keep your personal data?
Following termination of your membership, we keep your personal data for no longer than 6 months and we only retain your data for the following purposes: to recognise you as an ex-member and in case of complaint/legal claim. You may request to remain in the CUBO association management system for longer if you intend to remain in the sector and would like to preserve your profile and connections within the site.
8. Providing us with your personal data
We require your personal data as it is a contractual requirement for us to successfully deliver the membership services.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction on further processing;
- The right to object to the processing of personal data.
10. Transfer of Data Abroad
Your personal data is stored on the YOURMEMBERSHIP association management software in the United States. We and YOURMEMBERSHIP have signed an EU GDPR Data Processing Addendum to our existing contract.
11. Automated Decision Making
We do not use any form of automated decision-making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use before starting the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our CEO on email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
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