Responsible Finance respects your privacy and is committed to ensuring your personal information is protected. On 25th May 2018 the EU General Data Protection Regulation (the GDPR) came into force in the EU (including the UK) and enhances an individual’s rights in relation to personal information about them. This privacy notice will inform you how we collect and look after your personal information in accordance with the GDPR and tell you about your privacy rights, including how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
This privacy notice tells you what to expect when Responsible Finance collects and processes your personal information.
It is important that you read this privacy notice together with any other privacy 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 notice supplements the other notices and is not intended to override them.
Controller
Responsible Finance is the controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).
Contact details
If you want to request information about our privacy policy you can email us at [email protected] or write to:
Responsible Finance
7-10 Adam Street
London
WC2N 6AA
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 24th May 2018 and historic versions can be obtained by contacting us.
Duty to inform us of changes
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.
Third party links
Both our website and e-newsletters 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 or e-newsletters, we encourage you to read the privacy notice of every website you visit.
If you contact us via social media, the personal information you provide will remain on that platform and that platform will be the data controller. We encourage you to read the privacy notice of the relevant platform.
Third party data processors
We use third party service providers for parts of our website, IT systems and when we communicate digitally with you. Sometimes they will process the personal information which you provide us with.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
Under the GDPR, we must have a legal basis for processing your personal information. In the situations described in the next sections, we process your personal information for one of the following legal bases:
- Legitimate interests*. We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. It is in our interests to ensure that our processes and systems operate effectively and to process information to help us continue working to increase access to fairer finance across the UK.
- Consent**. We may process your information where you give us your consent to do so. You have the right to withdraw this consent at any time by contacting us at [email protected].
THE SITUATIONS WHERE WE COLLECT DATA ABOUT YOU, WHAT DATA WE COLLECT AND WHY WE COLLECT IT
- Visitors to Responsible Finance’s Website
When someone visits www.responsiblefinance.org.uk or www.findingfinance.org.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- Use of cookies by Responsible Finance
This website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of the website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Read more about the individual cookies we use by clicking here.
- Mailing Lists
As part of the registration process for our bi weekly e-newsletters, we collect personal information. We use that information for several reasons: 1) to provide you with information on subjects you’ve asked us to tell you about; 2) to contact you if we need to obtain or provide additional information; 3) to check our records are right and to check every now and then that you’re happy and satisfied. Importantly however, we do not rent or trade email lists with other organisations and businesses.
We use a third-party provider, Campaign Monitor, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Campaign Monitor’s Privacy Notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer at [email protected]
- Job applicants
If you apply for a job, we will ask for certain information in order to progress your application, assess your suitability for the role you have applied for and fulfil legal or regulatory requirements. The information will only be shared with the relevant hiring manager(s).
We will ask for your contact details to contact you about your application. We will also ask for your CV and a covering letter to assess your suitability for the role. If you apply to us for a job through a recruitment agency we will receive your contact details, CV and covering letter from them.
If you are shortlisted for a role, we will ask for you to provide proof of your identify so we can check that you have the right to work in the UK. As part of the assessment process you may be asked to attend an interview, where we might take interview notes, and to complete tests.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. We process this information to seek assurance as to your trustworthiness, integrity and reliability. You will therefore be asked to provide proof of your qualifications and referee contact details. In order to set up your employee record you will also be asked to provide bank details and emergency contact details. In order to comply with Financial Conduct Authority regulations you will also be asked to declare any business or other interests you have.
You will be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Given the nature of our business, for certain roles, we require a candidate who is made a conditional offer of employment to disclose their criminal record history before starting employment and annually during employment. In all cases we carry out the checks in accordance with applicable law. If we need to conduct these checks, you will be provided with further information prior to us doing so.
- Interactions with Responsible Finance employees
If you meet an employee of Responsible Finance for example, at an event, and give them your contact details they will keep this information in order to contact you in the future about topics which might be of interest to you. They will also share this information with other staff members at Responsible Finance and occasionally, they will pass it on to third parties who they think you would be interested to hear from. Similarly, we will sometimes receive your contact details from a third party who thinks you would be interested in hearing from us.
RETAINING YOUR DATA
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. 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. Further details of retention periods for different aspects of your personal data are available from us by contacting us at [email protected].
CHANGE OF PURPOSE
We will only use your personal data 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which 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.
DATA SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
We have also put in place measures to deal with any suspected personal data breach and will notify you and any regulator of a breach where we are legally required to do so.
YOUR RIGHTS
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
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 several requests. In this case, we will notify you and keep you updated.
COMPLAINTS OR QUERIES
If you have any questions about this Privacy Notice or want to submit a written complaint about how we handle your personal information, please contact us at [email protected]. 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 (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.