Privacy Policy

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Introduction

This Privacy Policy explains how personal data is collected and used by Norfolk Chambers of Commerce (company number: 00049631) (referred to as “NCoC“, “we“, “us“, “our” throughout this Privacy Policy). 

In this Privacy Policy, any reference to you includes:

  • you personally; and
  • any legal entity (such as a company, partnership, LLP or similar) which you represent in any of your interactions with us as envisaged under this Privacy Policy, as the context may so require.

At NCoC, we respect your privacy and are committed to protecting your personal data.  We take data protection very seriously and will ensure that we uphold the trust that our clients and others place in us when they provide us with their personal information.

This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.

This Privacy Policy contains the following sections:

  1. Important information
  2. Third-party links
  3. Data protection principles

4.         How we collect information about you

5.         What information we collect and how we use it

6.         Disclosures of your personal data

7.         International transfers

8.         Data security

9.         Data retention

10.       Your legal rights

11.       Glossary

Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy, including “personal data” and “personal information“.

  1. Important information

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how NCoC collects and processes your personal data, including any data you may provide when you contact us via e-mail, telephone, post, through social media or our website (https://norfolkchambers.co.uk), or where you subscribe to our newsletters or other publications, attend our events, register an account on or use our website, purchase any services or membership from us, interact with us in person, respond to any survey or other similar medium, get in contact with us, or otherwise engage with any of the services we provide to you.

Unless expressly stated otherwise, this website is not intended for children and we do not knowingly collect data relating to children.

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.

You should also read the Privacy Policy of the British Chambers of Commerce (company number: 00009635) (“BCC“), which can be found here: https://www.britishchambers.org.uk/page/privacy-policy, which, along with this Privacy Policy, provides details on how we and the BCC collect and process your data collectively, and what protections have been taken to protect your rights under the law.

Controller

NCoC is the “controller” for the purposes of data protection law, and is therefore responsible for your personal data.

As part of our commitment to you, we have appointed data compliance managers who are responsible for overseeing questions in relation to this Privacy Policy and NCoC’s data protection compliance in general.  If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 10below), please contact the data compliance managers using the following details:

Contact details

E-mail address:           [email protected]

Telephone number:    01603 625977

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.  

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 26 November 2020.

We keep this Privacy Policy under regular review and may amend it from time to time.  Please check back regularly to view the latest version.  Hard copies of this Privacy Policy are available from us on request.

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.

  1. 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 policy or notice of every website you visit.

  1. Data protection principles

NCoC adheres to the principles set out in data protection legislation when handling personal data.  These principles require personal data to be:

  1. Processed lawfully, fairly and in a transparent manner.
  2. Collected only for specified, explicit and legitimate purposes.
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
  4. Accurate and where necessary kept up to date.
  5. Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
  6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
  7. Not transferred to another country without appropriate safeguards being in place.
  8. Made available to data subjects and to allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

  1. How we collect information about you

We may collect, use, store and transfer different kinds of personal data about you.  We collect and process personal data about you when you:

  • request information from us about our services, memberships, Strategic Partner Programme, and operations;
  • engage with us as a prospective member, for the purposes of joining as a member or purchasing services from us;
  • create an account on our website, or otherwise provide information relating to a new membership or provision of services;
  • request information on any events, networking meet-ups or similar opportunities which we provide or offer to provide to you;
  • attend an event or networking meet-up (whether in person or virtually) arranged or hosted by us;
  • request any information in respect of any training opportunities;
  • provide us with international trade documentation, to be processed as part of our services;
  • engage with any of our social media accounts, website or other electronic means which are managed or regulated by us;
  • subscribe to any newsletter or other publications issued by us;
  • respond to a client survey, or otherwise provide your opinions on policy related matters which impact upon your business, or that of your clients/customers;
  • contact us via e-mail, telephone, post or through social media; and/or
  • submit an enquiry to us.

Personal data is usually collected from you through direct interaction with us (either in person, by phone, by e-mail, by post, via social media or through this website).  For example, you will provide your personal information when you submit an enquiry as to our membership or Strategic Partner programmes, or otherwise engage with us for our services.  

We may also collect personal data when you use this website, through automated technologies, analytics providers or search engine providers.  We use cookies to assist the site running as effectively as possible. For further details, please see our cookies policy here: https://norfolkchambers.co.uk/cookie-policy#:~:text=A%20cookie%20is%20a%20small,personally%20identifiable%20information%20about%20you.

Please note: on occasion, the BCC will act as a data processor on behalf of NCoC. The BCC may process information from the NCoC and other regional chambers, and specifically may collect the first name and email address from each member of the NCoC for the purposes to conducting a national survey.

The BCC has provided the types of personal data which it collects on from, or on behalf of the NCoC in its Privacy Policy, as well as its legal basis for doing so. It also has set out how such data will be used, as well as its retention policy and other legal requirements as necessary under law. We advise that you review the BCC’s Privacy Policy before using our website, or otherwise engaging in any membership, or for the provision of services from us. The BCC’s Privacy Policy can be located here: https://www.britishchambers.org.uk/page/privacy-policy. If you are not satisfied with the BCC’s processing of your personal data, please stop using our website (and any membership or services you procure from us) and contact us immediately.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to provide our services.  If so, we may have to terminate our contract with you but we will notify you if this is the case at the time.

  1. What information we collect and how we use it

The personal data that we collect will include:

  • Contact details including your name, address, telephone number, job title, e-mail address and social media log-in and account details;
  • Contact history, such as any communications with us by telephone, e-mail, post, through our website or via social media;
  • Details about any your interests, including company directorships or secretarial roles, shareholdings, or other controlling interests in a legal entity;
  • Payment details, including bank account details, direct debit details, and transaction history;
  • Transaction history, including any services engaged for, publications received, memberships undertaken, or any previous other engagement you have had with us;
  • Website profile data, including usernames and passwords;
  • Social media account details, including linking your account to any website, Twitter, Facebook, LinkedIn, Google+ or similar page or account you may hold;
  • Personal and professional interests, preferences, feedback and survey responses, as well as any views you have provided on policy positions held by, or being investigated by, the NCoC or BCC;
  • Marketing preferences; and
  • Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access the website.

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 under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the website to calculate the percentage of users accessing a certain section of our website.  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 will not collect or process Sensitive Personal Data (as defined in the Glossary) about you at any time. 

We will generally use your personal data to:

  • Provide you with the information and services that you request from us;
  • Contact you by post, e-mail, telephone and via social media regarding the services and information that you have requested from us;
  • Generally administer our relationship with you;
  • Provide you with information regarding our membership or Strategic Partner programmes, or any other programmes, services or initiatives operated by the NCoC or BCC;
  • Provide you with information regarding any networking opportunities or events which you, or any of your clients/customers may be interested in;
  • Personalise your experience on our website, and in providing our services to you, to provide information and contacts relevant to you and your business;
  • Provide you with our newsletters and other publications;
  • Provide you with information relating to any training opportunities which may be related to you and/or your company/business;
  • Request, receive, collate and analyse your opinions on policy related matters, be that as part of a survey or otherwise;
  • Process and respond to queries raised by members of the public and other relevant stakeholders;
  • Develop and provide new services and products;
  • Respond to any enquiries that you submit to us;
  • Display your details in any case studies and/or testimonials which we publish on our website, where you have consented to this separately;
  • Send you information by post or e-mail about new services, offers, updates and news (see the “Marketing” section below for further details);
  • Facilitate and manage your membership with us;
  • Create and administer your account on our website;
  • Comply with our legal and regulatory obligations;
  • Keep a record of your relationship with us;
  • Prevent and detect fraud;
  • Provide client service and support (including investigating complaints);
  • Train our staff and carry out quality control;
  • Review and improve our services;
  • Use data analytics to improve our website, marketing, client relationships, user experience and our organisation in general; and
  • Administer and protect the website and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).

Lawful basis for using your information

In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have a membership with us, have signed-up to any of our events, or have requested our services, and we need to provide them to you).

Generally, we do not rely on consent as the lawful basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

There are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for NCoC to process your information.

Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.

Marketing

We may use your contact details to send you marketing communications if you are a client and you have expressly given consent to receive those marketing communications. 

If you are not a client and you have requested information from us, we may also use your contact details to send you marketing communications unless you have opted-out of receiving that marketing.

Given that a core service that we provide is networking, we include details of our members in the directory on our website and will share these details with BCC and other regional chambers.

We will not share your information for marketing purposes with any company or other entity outside of NCoC and BCC, unless we have your opt-in consent to do so.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time or clicking the “unsubscribe” button in the relevant e-mail.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a contract for services, membership, or any engagement with our Strategic Partner programme that you have with us.

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.

  1. 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 paragraph 5above.

  • The BCC.
  • Other UK regional branches of the British Chambers of Commerce, a list of which can be found here: https://www.britishchambers.org.uk/page/join-a-chamber.
  • Other global branches of the British Chambers of Commerce, a list of which can be found here: https://www.britishchambers.org.uk/page/global-business-network-map.
  • Any sub-contractors and/or agents we may work with from time to time to provide you with the services that you have subscribed for, or otherwise purchased from us.
  • Any organisations that from time to time provide hosting services for our website.
  • Any designers who are involved in the creation or design of any of our publications.
  • Service and infrastructure providers who provide IT, design, security, software, marketing, advertising and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.
  • HM Revenue & Customs, law enforcement agencies, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • 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, carry out a restructure 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 provide third-party advertising companies with Aggregated Data so that you may receive tailored advertisements, services, and information based on your visits to our website. However, 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 do not and will not sell your personal data to any third party.

  1. International transfers

Some of our external third party service providers or partners may be based outside the European Economic Area (EEA), in which case, their processing of your personal data may involve a transfer 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 that 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 (such as New Zealand or Switzerland).
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has under EU data protection law.

Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.

  1. 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 staff, agents, contractors, other individuals 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.

  1. 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 on request by contacting us using the details above.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw 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.

  1. Glossary

“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).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

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 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 privacy 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.

YOUR LEGAL RIGHTS

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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Gold and Strategic Partners