THE SABSA INSTITUTE C.I.C
EXTERNAL DATA PROCESSING NOTICE
- IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Processing Notice
This is the privacy policy or processing notice (notice) of the SABSA Institute C.I.C. (referred to as we, us, our or TSI in this processing notice).
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us as a SABSA member (including a customer of one of our accredited education providers delivering SABSA courses on our behalf) or suppliers (or as an employee or representative of same) or visit and use our website (regardless of where you visit it from), currently https://sabsa.org/ (our website), as a SABSA member, supplier, or otherwise.
It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any website you have used to access our website or any website that you access from it. It does not cover any of your personal data which may be separately collected by our accredited education providers as separate and independent data controllers.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
This version 2 of our privacy notice was last updated on 14 October 2024. Historic versions can be obtained by contacting us.
Controller
Under the EU or UK General Data Protection Regulation (GDPR) or other applicable data protection law, we act as a data controller (make decisions) in relation to any of your personal data that we collect.
If you have any questions about this notice, including any requests to exercise any of your legal rights, please contact us using the details set out below.
Contact Details
Our full details are:
Full Name of Legal Entity: The SABSA Institute C.I.C., a community interest company incorporated in England and Wales under company number 08439587
Email Address: info@sabsa.org
Postal Address: 110-114 Duke Street, Liverpool, England, L1 5AG
Third-Party Links
Our 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 processing notice of every website you visit.
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 set out below.
- Identity Data includes first name, last name, image, online username or similar identifier, title, date of birth and gender;
- Professional Data includes the company you work for or otherwise represent, job title;
- Social Media Data – where you have responded to a promotional item or offer from us through social media facilities such as LinkedIn (if applicable), we may receive profile information about you which can include your profile picture or similar identity or professional data to that described above;
- Contact Data includes email address, physical address and telephone numbers;
- Financial Data includes bank account details for third party suppliers who we may pay for goods or services (for the avoidance of doubt, we do not collect or hold financial data from our members, instead payments will be brokered through a certified payment provider, shared with them in an encrypted and tokenised manner – all of these details are password secured on our servers and only accessible to the relevant staff or software providers);
- 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 our website;
- Usage Data includes information about how you use our website and services;
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
- Employment Data includes data which may be provided to us during a recruitment campaign and included on your CV, covering letters and on any responses to job applications and selection processes, including (whilst we are unlikely to request this), to the extent you provide them, your racial or ethnic origin, religious or philosophical beliefs and trade union membership.Please note that as an employee of TSI, a separate policy may be in force.
Other than Employment Data, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through use of the website or when otherwise dealing with or concerning you. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Your 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 data
Where you are sharing personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this notice with that person/those people, including where you are acting to register other individuals on their behalf.
- HOW IS YOUR PERSONAL DATA COLLECTED & USED?
We use different methods to collect personal data from and about you. The ways we collect it, what we collect and how and why we use that personal data is set out below.
Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, to keep internal records for administration purposes related to such contracts, for the purposes contemplated in any separate terms of use for our websites that you have entered into, including for the purposes set out in the “Our Standard Business Operations” section below.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing.
| Personal Data Type | Collection Method | Basis of Use | Purpose |
| Contact before and during your Membership and/or Training | |||
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| Whenever you interact with our website or tracked emails | |||
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| Whenever you apply for a job with us | |||
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| Ancillary processing | |||
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Please note that the above lists are non-exhaustive. We will generally only use your Personal Data for the purposes for which we collected it, unless permitted by law or we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated and incompatible purpose, we will notify you where necessary and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Where we rely on legitimate interest, you can contact us for more details on the consideration of these interests.
NOTE:
Legitimate Interest can mean our interest or the interest of another party. 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).
Consent
Whenever we rely on your consent (as noted above), you have the right to revoke such consent at any time by emailing info@sabsa.org. Unless another basis of use exists, we will collect your consent to use your personal data for our marketing and remarketing purposes generally by using tickboxes or where your actions clearly demonstrate your consent (such as by providing your contact details for a specified purpose).
Marketing
If you are a customer of ours, we may contact you from time to time by call or email to provide some information about our products or services. 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, as appropriate, 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 experience or other transactions.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing unrelated to our company.
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, service experience or other transactions.
Children
Our websites and services are not intended to be used by children under 16 years old. We will never knowingly collect data from children below 16 years old. If you become aware of such a child (or another person) supplying data to us, please contact us.
We will take care when processing such data and only do so where one of the legal grounds set out above applies.
We may have to share your personal data with the parties (all established in the UK or EEA unless otherwise stated) set out below for the purposes set out in the table in paragraph 3 above:
- 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 processing notice.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- professional advisers including lawyers, bankers, auditors and insurers based in the European Economic Area or United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
- Accredited Education Partners (AEPs), who offer certification and professional training courses on our behalf, including those listed here: https://sabsa.org/accredited-education-partners/ (who may be based outside of the EEA or United Kingdom);
- with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable);
- service providers, including (as at the date noted above and who may be updated from time to time):
- Stripe, who is engaged to provide payment services;
- Credly, who is engaged to provide badging services for SABSA training / certification courses (who may process personal data outside of the UK / EEA;
- Hosting service providers such as Microsoft, whose privacy policies are available at: https://privacy.microsoft.com/en-gb/privacystatement or WordPress, whose privacy policies are available at: https://en-gb.wordpress.org/about/privacy/
- other parties where you ask us to share that data, or we ask you and you consent.
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.
Where you are a data subject resident in the UK / EEA, we do not transfer your personal data outside the UK or EEA other than to the UK / EEA other than to AEPs (who may process your personal data outside of those jurisdictions where they are providing services in such jurisdictions) and Pearson Inc T/A Credly who are engaged to provide training and badging services respectively, and are based in the United States of America (and reserve rights to process your personal data outside of those jurisdictions).
For these recipients, we ensure that a similar degree of protection is enforced as is required within the UK by ensuring that the recipients use and are bound by standard contractual clauses which may be enforceable by you regarding data protection (as well applying appropriate additional security measures), or the recipient countries have been deemed to provide an adequate level of protection by the UK (which currently mirror the decisions taken by the European Commission (further details available here)).
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. We have also 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.
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. Please contact us if you would like more information regarding the security measures we use.
Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our websites, and before it reaches us, such data is transmitted at your own risk. We also cannot guarantee that our security measures will never be overcome or compromised.
- DATA RETENTION
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, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will keep your data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any products you have purchased from us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for other purposes, in which case we may use this information indefinitely without further notice to you.
- 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.
- 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, 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. Note, however, that we may not always be able to comply with your request for specific legal or compelling legitimate reasons which will be notified to you, if applicable, at the time of your request.
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 we receive a number of requests. In this case, we will notify you and keep you updated.
Supervisory Authority Contact
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.