Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will market Social Impact programmes to Trading Company contacts. We will market Trading Company products to Social Impact volunteers. We cross-market on the basis of legitimate interests.
Promotional offers 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the IGD Group of companies for marketing purposes.
Events
We may use your Contact Data and Identity Data in an app for an event you are attending including the event delegate list and to allow other delegates to send you messages within a dedicated event app. We may also share your Contact Data and Identity Data with any retail partner of an event, solely for the purposes of administration of that event. Details of this will be provided at the point of ticket purchase.
Subscriptions
We may use your Contact Data, Identity Data and Transactional Data to inform your company about your use of our services.
Volunteers for charitable activities
If you volunteer for one of IGD's charitable activities, we will use your personal details to communicate with you about IGD's charitable activities. We may share your details with trusted third parties who deliver services on our behalf, but we will not sell your details for marketing purposes.
Unless you have registered as a teacher on our Educator Hub, we will automatically add you to our database to send you details of our commercial opportunities.
We will market Trading Company products to Social Impact volunteers. We cross-market on the basis of legitimate interests.
Educator Hub registration, webinars, Learning Platform
IGD will use data gained via registration for the Educator Hub, and feedback data from webinars and Learning Platform to help us understand how our free teaching resources have been used and to help us plan better for the future.
We will contact users via email to gain feedback on our resources. We do this to measure our charitable impact and improve the services we provide.
All data from the feedback surveys will be aggregated and anonymised. We may use your quotes however, we will not publish your name or school or employer without your consent.
Feedback from the surveys will be published on our website, reports and communication emails.
In respect of the Learning Platform only, we may send a) a report on your progress; and b) aggregated and anonymised data from the feedback surveys, to your employer.
Educator Hub opt-in for sharing data with trusted third party
If you have opted-in, we may share your details with trusted third parties who deliver services on our behalf, but we will not sell your details for marketing purposes.
Free Learning
If you attend one of our free learning events, we will send you newsletters about our free learning opportunities. We may also use your Contact Data, Identity Data and Transactional Data to inform your company about your use of our services.
Access to insight / IGD forms
IGD will in some cases ask you to fill in your details before you can access its latest insight. This is to help us understand how our free insight has been used and to help us plan better for the future. If you fill in a form then we will also market to you on the basis of legitimate interests, to develop our products/services and grow our business.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
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 our cookies policy.
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.
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.
Post-graduates and foundation course attendees
If you took the IGD/University of Edinburgh post-graduate qualification on or after 1996 or a foundation course after 2002, we will keep your data for 50 years. We do this for the purpose of keeping a record of students, to be used for verification purposes.
Schools partnership programme
We will share your data usage with your company nominated project manager.
5. Disclosures of your personal data
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 notice.
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.
If you are a job-seeker and have attended a work experience programme, we will only tell the Job Centre whether you have attended a session if you grant us permission to inform the Job Centre by ticking the “opt-in”.
6. International transfers
We share your personal data within the IGD Group. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Many of our external third parties are based outside the European Economic Area (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:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, 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 US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 only process your personal data 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 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.
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.
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.
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 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.
10. Glossary
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). 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.
THIRD PARTIES
Internal Third Parties
Other companies in the IGD Group acting as joint controllers or processors and who are based in Canada and Singapore.
External Third Parties
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers 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 who require reporting of processing activities in certain circumstances.
- Service Providers such as venues, our agents and sub-contractors, providers or services to IGD the Charity.
11. Cookies policy
The Site uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on, or want to enter, the Site (for example to remember who you are without you having to re-enter your username and password each time you are on the Site). We only use cookies for your convenience in using the Site, for measuring the effectiveness of our web-based services and not for obtaining or using any other information about you.
If you are a non logged-in user, you will be prompted via a cookies banner to set your cookies preferences. If you are a logged-in user, we rely on legitimate interest to collect and use information via cookies for the uses set out in the table above.
Your browser can also be set to not accept cookies, but this could restrict your use of the Site. If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.
IGD uses third party companies to analyse user trends and diagnose technical problems. These third party companies may also use cookies to collect anonymised data in order to measure the effectiveness of our services.