PURPOSE OF THIS PRIVAVCY POLICY

This privacy policy aims to give you information on how the Institute of One World Leadership collects and processes your personal data through your use of our website and other means including post, telephone and email, including any data you may provide through our website when you sign up to purchase a product or subscribe to a service, personalise your preferences, participate in discussion boards, our newsletters, or other social media functions, submit a registration form or take part in a promotion or competition.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

WHO WE ARE

In this privacy policy IOWL means The Institute of One World Leadership (registered in Northern Ireland (NI655262) Custom House, Custom Square, Belfast, BT1 3ET)

By using our website www.owls.global, (our ‘Website’) you are accepting and consenting to the practices described in this policy.

Depending on the purpose for which you are providing your personal data, the data controller (or entity responsible for the data collected) will be either us and/or any of the IOWL Group. Within the context of this policy ‘we’ means the IOWL Group.

Personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do collect some Special Categories of Personal Data about you (this includes details such as your race or ethnicity, health and family information) but we will only collect this if we have a valid reason and data protection legislation allows us to do so.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter or complete a competition, promotion or survey;
    • carry out any transactions on our website;
    • provide CV’s or other information about yourself for specific purposes; or
    • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie policy for further details.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as our business delivery partners, suppliers, sponsors, event organisers, as set out below:
    • Technical Data from the following parties: (a) analytics providers; (b) advertising networks; and (c) search information providers.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from data brokers or aggregators.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
    • Identity and Contact Data from publicly available sources such as social media sites.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests as set out in the Glossary at the end of this policy (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have provided your consent to us to use your personal data in a certain way such as direct marketing by email.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

We may also process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.

Purpose/Activity:
To register you as a new customer

Type of data:

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Lawful basis for processing including the basis of legitimate interest:
Performance of a contract with you.


Purpose/Activity:
To register or renew you as a member including:

  1. Disclosing your membership status to members of the public
  2. Managing your member account and contacting you about member benefits and services
  3. Serve notice in accordance with the requirement of our Bye-laws, Regulations and code of Conduct
  4. Provide information about and communications from your local branch network

Type of data:

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Lawful basis for processing including basis of legitimate interest:

  1. Performance of a contract with you
  2. Necessary for our legitimate interests

Purpose/Activity:
To process and deliver your order including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us

Type of data:

  1. Identity
  2. Contact
  3. Financial
  4. Transaction

Lawful basis for processing including basis of legitimate interest:

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity:
To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey

Type of data:

  1. Identity
  2. Contact
  3. Profile
  4. Marketing and communications

Lawful basis for processing including basis of legitimate interest:

  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity:
To enable you to partake in a prize draw, competition or complete a survey

Type of data:

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and communications

Lawful basis for processing including basis of legitimate interest:

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:

  1. Identity
  2. Contact
  3. Technical

Lawful basis for processing including basis of legitimate interest:

  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation

Purpose/Activity:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data:

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)


Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:

  1. Technical
  2. Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)


Purpose/Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data:

  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business)


MARKETING

We may use your personal data to provide you with information about our services and/or products, which we consider may be of interest to you. Where we do this via email, we will not do so without your prior consent except for when you have previously purchased goods or services from us, in which case, you will receive marketing from us unless you have told us that you do not wish to receive that marketing.

OPTING OUT

You can opt out of receiving email communication from the IOWL and update your preferences of how and what we communicate to you by updating your profile in the members section (My World) and checking or unchecking relevant boxes to adjust your marketing preferences.

THIRD-PARTY MARKETING

We will never sell your personal data to third parties for the purposes of marketing and will get your express opt-in consent before we share your personal data with any company outside the IOWL group of companies for marketing purposes.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the IOWL Cookie policy.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We share your personal data within the IOWL Group. In general the personal data that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). However we may also transfer your data outside the EEA.

Please note that some countries outside of the EEA have a lower standard or protection for personal data, including lower security requirements and fewer rights for individuals. Where your personal data is transferred, stored and/or otherwise processed outside the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal data and to ensure that your personal data is treated securely and in accordance with this policy.

Unfortunately, no transmission of your personal data over the internet can be guaranteed to be 100% secure. However, your personal data is only accessible by appropriately trained staff, volunteers and contractors and stored on secure server with features enacted to prevent unauthorised access.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Any payment transactions will be encrypted using SSL technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal data from our records seven years after the date it was collected unless different retention periods apply, for example we will keep member data for 15 years after membership expiry in order to comply with requests for verification of membership status that are made to us. However, if before that date (i) your personal data is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove or anonymise from our records at the relevant time.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Note, however, that we may be unable to supply certain pieces of information that you have requested, if it is subject to legal privilege or relates to management planning. This will be notified to you, if applicable, at the time of your request.

You can submit a subject access request to the IOWL by emailing legal@owls.global.

To assist us in processing your request, you will need to provide the following information:

  • Full name
  • Membership number (If applicable)
  • Telephone number
  • Email address
  • Information sought (Please describe, in as much detail as possible, the information you wish to have access to and if appropriate, any dates relevant to the information sought.)

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

You can update your personal data by making amendments in the ‘My World’ section of our website.

Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request or as soon as possible thereafter. We may also anonymise rather than delete your data.

You can submit a request, by emailing deletionrequest@owls.global.

You will be asked for the following information to assist us in processing your request:

  • Full name
  • Membership number (if applicable)
  • Telephone number
  • Email address of your IOWL web account (if applicable)

If you would like to exercise any of the rights below, you can email on the contact details provided below. Please provide your full name, membership number (if applicable), contact telephone number and email address.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to opt out from receiving marketing messages from us, please see section above on OPTING OUT.

WHAT WE WILL NEED FROM YOU

We will need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

THIRD-PARTY LINKS

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 24 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACT DETAILS

Our full details are:
Full name of legal entity: The Institute of One World Leadership
Email address:dataprotection@owls.global
Postal address: Custom House, Custom Square, Belfast, BT1 3ET

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES / INTERNAL THIRD PARTIES

Other companies in the CIPD Group acting as joint controllers or processors and who are based in the United Kingdom, Ireland, Singapore and United Arab Emirates and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the United Kingdom and South Africa who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and Ireland who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, Ireland, Singapore and United Arab Emirates who require reporting of processing activities in certain circumstances.