1. POLICY PURPOSE
(a) Who We Are
The McBridge foundation will have a strong focus on millennials and hopes to give them the chance to participate in London’s great opportunities by trying to remove some of the obstacles that stand in their way. Therefore, we will support charities and organizations who have a focus in these areas: Preventing or relief of poverty / Advancement of education / Advancement of arts & culture / Conservation, protection and improvement of the environment.
This website is not intended for children, and we do not knowingly collect data relating to children.
This version was last updated on 09 July 2019. Please check this page periodically, as this policy may be updated, for example when the ways in which we use your personal data change or to comply with applicable law.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.
(e) Third-Party Links
This website 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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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, last name, email address, title, date of birth and gender.
- Contact Data includes email address, location and telephone numbers.
- 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 interests, preferences, feedback and responses to our materials and queries.
- Usage Data includes information about how you use our website.
- Communication Preference Data includes your preferences in receiving communications from us and our third parties and your communication preferences.
We do not ordinarily collect any special categories of personal data about you (this includes details about your race or ethnicity, criminal offenses or convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) through this website unless you provide this data to us voluntarily. If you provide us with any Special Categories of Personal Data in your communications with us, we will process such data only with your consent, in accordance with our legitimate, not-for-profit interests and in conformity with this Policy. We will not disclose this information to third parties without your consent, but we may collect this data via third parties.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms, corresponding with us by post, phone or e-mail, or communicating with us in person or otherwise. This includes personal data you provide when you:
- subscribe to our newsletters,
- updates or publications;
- request information to be sent to you;
- respond to a request for information or a survey; or
- give us feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data, Profile Data, Identity Data, Contact Data from sources such as Google, MailChimp and SurveyMonkey.
- Employment Profile Data from Google, LinkedIn and/or Facebook if you elect to use these services to interact with us.
- Sensitive Categories of Personal Data (if collected) via SurveyMonkey.
- Analytics providers such as Google, some of whose services may be based outside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will use your personal data only when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To keep you up to date regarding the Institute’s events, publications and activities.
- To understand your views regarding the issues the Foundation works on.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- With your consent, where applicable.
- Where we need to comply with a legal or regulatory obligation.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table, 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful Basis for Processing|
|To register you to receive updates, information and other communications from the Institute.||
Fulfillment of our relationship with you.Consent:
Where necessary or appropriate, we may request your consent for these purposes.
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||
1. Necessary for our legitimate interests (for running our business, providing administration and IT services, ensuring network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise).
2. Necessary to comply with a legal obligation.
|To deliver relevant website content and publications to you and measure or understand the effectiveness of the content we serve to you.||
Necessary for our legitimate interests (to study how our audience uses our website and responds to our work, to develop them, to grow our business and to inform our strategy).
|To use data analytics to improve our website, products and services, communications, messaging, and user and audience relationships and experiences.||
Necessary for our legitimate interests (to understand the audience for our message, to keep our website updated and relevant, to develop our business and to inform our strategy).
Where necessary or appropriate, we may request your consent for these purposes. Your explicit consent will be sought to process any Special Categories of Personal Data.
We strive to provide you with choices regarding certain personal data uses, particularly how we contact you. We have established the following personal data control mechanisms:
- The ability to opt out of receiving communications from us, which is included at the bottom of each e-mail we send you.
- The ability to contact us should you wish to change or query how we contact you.
Content Suggestions From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which information, publications and updates may be relevant for you.
You can ask us to stop sending you information about the Institute at any time by following the opt-out links on any message sent to you or by contacting us at any time.
When you opt out of receiving these messages, this will not apply to personal data provided to us as a result of any contractual relationship or other obligations or responsibilities we have to you.
With your consent, we may use technology to track the patterns of behaviour of visitors on our website. This can include using a cookie (a piece of information transferred to an individual user’s hard drive for record-keeping purposes). The cookie will store any information that you enter on our website, including name and address (physical address or e-mail address). It is possible for us to retrieve the information stored on the cookie.
Change Of Purpose
We will use your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the following parties for the purposes set out in the table in section 4 above.
- External Third Parties as set out in the Glossary.
- Specific third parties such as MailChimp and SurveyMonkey.
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 permit them to process your personal data only for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the McBridge Group. This will involve transferring your data outside the European Economic Area (EEA). When doing so, we ensure your personal data is protected by requiring companies in our group to follow the same rules as the Institute does in the United Kingdom.
Some of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts provisions that give your personal data sufficient protections; and/or
- Where providers are based in the United States, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the United States.
7. DATA SECURITY
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 process your personal data only on our instructions, and they are subject to a duty of confidentiality.
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.
8. DATA RETENTION
How Long Will You Use My Personal Data For?
We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.
In some circumstances you can ask us to delete your data. See “Request erasure” below for further information.
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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.
- 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.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove 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.
- 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.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to achieve the aims of the Institute and give you the 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
External Third Parties
- Service providers based in the European Economic Area or the United States that provide IT, communications and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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 that require reporting of processing activities in certain circumstances.
You may 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.