1. Our beliefs when it comes to user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We can't stand spam
- We may forward your information to relevant third parties who can help with furthering your education.
2. Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
This site's compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residence's specific data protection and user privacy legislation, you should contact our Data Protection Officer (details of whom can be found in section 8.0) for clarification.
3. Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer's IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 5.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Website forms
Should you choose to submit a form on our website, such as a user profile or registration form, the data you've submitted, including your name, telephone number and email address where applicable, will be stored on our website's database, which is only accessible by authorised members of the ICM team.
3.3 Email links
In various areas of this website there is the option to click to email or click to call. In both of these cases, upon clicking a link, our website will not record or store any of the information you subsequently submit. These links will prompt your device to launch either the default call or email app in use.
Emails sent and received by us use Simple Mail Transfer Protocol (SMTP), this service is provided to us by one of our third party data processors, Microsoft, on their Office 365 platform. For more information about Microsoft as a data processor, see section 5.0.
Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
4. How we store your personal information
Your personal information will be stored within ICM's database. The data currently stored in database can only accessible to those with the necessary system privileges.
5. Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0.
6. Data breaches
We will report any unlawful data breach of this website's database, or the database(s) of any of our third party data processors, to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
7. Data controller
The data controller of this website is: The Institute of Commercial Management.
Whose registered office is:
8. Data manager
Mrs Lynsey Campbell
Telephone: +441202 490555
Last update: 27/03/2019