Privacy Policy (APRIL 2018)

The Chamber is committed to handling your Personal Identifiable Information in a responsible manner, and we will provide the appropriate safeguards. The Chamber follows the guiding principles of the General Data Protection Regulations (GDPR) and the Privacy of Electronic Communications Regulations 2003 when it comes to your protecting your data. The CEO of the Chamber is the Data Controller as defined by the GDPR and can be contacted by email at lmw@knowsleychamber.org.uk or 0151 477 1356

Introduction:
The Chamber is a membership organisation for local businesses to participate and become part of a supportive local business community. A membership fee is payable upon joining and thereafter an annual subscription is payable. The member ship fee pays in part for the inclusion of your personal identifiable information (PII) on the Chamber’s member directory, for the legal expense insurance that is attached to membership and for access to legal specialists via the QDOS legal helpline.

This Privacy Statement describes our practices for collecting, storing and processing your PII and the controls we provide you to manage it. PII is any information that can identify you, such as your name, email or street address, or it may be information that could reasonably be linked back to you.

Membership:
We collect your PII at the point you complete a Membership Application Form. We process, store and retain your PII during the period you are a member of the Chamber. If you decide not to become a member we will delete your PII from our servers.

Working Well Programme:
We collect your PII at the point you engage with the Working Well programme. We process, store and retain your PII during the period you are engaged with the Working Well programme. If you decide not to engage on the Working Well Programme we will delete your PII from our servers.

Cookies:
We use cookies to enable a better user experience when using our website. We do not collect PII through our cookies and we do not use 3rd party cookies either for marketing or analytical purposes.

Lawful Basis:
We collect PII about you in order to enter into a commercial relationship, this can be at an early stage (pre-engagement) and/ or at contract stage. As such we do not rely on your consent to collect and store your data as without the data we collect we cannot provide the membership services for you, or provide information and support regarding the Working Well Programme. Therefore, processing is necessary for the performance of a contract with you, or to take steps to enter into a contract with you.

Additionally, processing may be undertaken for the purpose of furthering the legitimate interests pursued by the Chamber, except where such interests are overridden by the interests, rights, or freedoms of you, the data subject.
• We will request your explicit consent to send you our newsletter and event information which may contain marketing material.
• We will request your explicit consent to include your PII as provided on our website member directory.
• We will request your explicit consent to send you information and provide support under the Working Well programme.

PII we collect from you:
Contact Information – includes your name, business name, address, contact names, email address and your phone number(s), staff numbers, bank account information, how long you have been trading and in which sector. For Working Well we will require the above information and data on staff gender (number of male/female staff), part-time/full-time workers, number of days absence and reasons for absence.

Use of Your Personal Information:
We use your PII to allow the Chamber to engage with you to provide membership services, such as information regarding meetings, newsletters, or network events. We will use your PII to provide support, information, advice and guidance for the Working Well programme.

When we share your information:
• The Chamber does not share, trade or sell your membership PII with third-parties.
• As we are a Local Growth Hub partner (April 2018 – March 2019) we are required to enter your basic details (company name, address, telephone number, email and nature of enquiry) on a common system (Evolutive) which is used by other Local Growth Hub partners to monitor and record support across Liverpool City Region and to avoid duplication.
• We will share information on Working Well with Knowsley Public Health.

Changes to this Statement:
We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice on our websites or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.

Data recipients:
Any PII we collect, hold and process is retained on servers based in the UK. We maintain reasonable and proportionate security measures on our computer equipment and have a written agreement in place with our ‘cloud’ host in relation to their processing activities on our behalf. Access to data is restricted to those who have a legitimate reason to retrieve it.

Data transfers:
We do not transfer personal data to any third-party recipient other than those shown above.

Retention policy:
The data we collect directly from you is the minimum we require to facilitate the lawful processing described above. PII placed on our system will be deleted as soon as practicable after termination of a commercial contract between us. Any PII collected and processed for finance purposes will be held for the maximum time as determined by any legal requirement (normally 3 years)

Your rights as a data subject:
The regulations provide a number of rights to you as the Data Subject. The Chamber is committed to upholding those rights, and those applicable to the PII we collect and process are listed below. In addition to these rights, you have the right to escalate any concern to the Information Commissioners Office www.ico.org.uk.

• The Right to be Informed
You should be clear about what, why and in what way your personal information will be processed at the time it is processed. This privacy policy sets out that information
• Right of Access
You have the right to know what personal information is held, by whom and why. You can send a Subject Access Request to see what personal information and any supplementary information relating to you is held by us. We will provide you with the information we hold within one month of your request, unless the provision of that information is particularly complex, in which case, we may extend the deadline by a further two months. This information will be provided free of charge unless you require multiple copies of the same information, in these circumstances, we retain the right to charge a reasonable administrative fee.
• The Right to Rectification
If the information we have collected and processed is inaccurate or incomplete, you have the right to have it rectified. We will respond to your request for rectification within one month, unless the request is complex or multiple.
• Right to Erasure
You have the right to have your personal data erased and to prevent processing in some specific situations, these include:
o Where personal data is no longer necessary regarding the purpose for which it was originally collected
o When you withdraw consent
o When you oppose the processing and there is no superseding legitimate interest for continuing the processing
o If the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
o If the personal data must be removed in order to comply with a legal obligation
• Right to Restrict Processing
If you contest the accuracy of the personal data we hold, we will restrict the processing of your data until accuracy is verified. The restriction of processing can occur for other reasons too, such as if you require us to retain your data in the advent of a legal claim
• Right to Data Portability
You have the right to move, duplicate or transfer your data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

Other websites:
This privacy policy only applies to the Chamber; if you follow a link to another website from ours, you should read their own privacy policy.

Changes to our privacy policy:
We keep our privacy policy under review and we will place any updates on our website. This privacy policy was last updated in April 2018

How to contact us:
You can write to Knowsley Chamber, First Floor, Yorkon Building, Huyton, L36 9FB