This Privacy Statement sets out what personal information ITOPF collects, what we collect it for, how we share it and your rights in relation to your personal information in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (Data Protection Legislation).
1. Controller details:
ITOPF Limited (“we”, “us”, “our”) is the controller of your personal information. This means that we are responsible for deciding how and for what purposes we collect and use personal information about you.
Our contact details are as follows:
ITOPF Limited (company no. 9448631)
69 Old Broad Street
Telephone: 020 7566 6999
2. What data does ITOPF collect?
2.1 ITOPF collects, uses and processes a range of personal information about you, including some special categories of personal information. This may include:
a) Your contact details, including your title, name, address, telephone number and personal e-mail address.
b) Your image that may be taken occasionally as part of digital photographs of the sites affected by oil spills if you happen to be on the site assisting with ITOPF’s oil spill response.
c) Marketing and Communications data - such as preferences about the type of marketing material you would like from us or your communication preferences, including the language you would prefer to receive communications in.
d) We may also have details of your family members that you may have provided when signing up to an event.
e) Your disability data to ensure that we provide you with the appropriate support and adjustments when you attend our events or visit us at our offices.
f) Your dietary requirements to facilitate our events and to provide you with an acceptable service.
2.2 ITOPF does not intend to collect, use and process any other special categories of your personal information, such as:
a) Information about your health, other than your disability data
b) Information about your racial or ethnic origin, religious or philosophical beliefs, sex life and sexual orientation
c) Trade union membership
d) Information about criminal convictions and offences.
ITOPF will ask for your explicit consent in case it collects any of the special categories of your personal information above.
3 . How do we collect your personal information?
We collect your personal information because you provide it to us directly through a variety of different methods including when you:
a) Subscribe to our publications
b) Request resources or marketing to be sent to you
c) Sign up to one of our events
d) Seek one of our services from us
e) Apply or tender for one of our awards
f) Provide us with your details as part of networking events
We may also collect your personal information indirectly through other sources. These other sources may include:
a) Third-parties such as government agencies, regulatory bodies and partner organisations that may share your data with us in connection with oil spill response.
We may automatically collect your personal information about your use of our website – see section on Cookies below.
4. Why and how do we use your personal information?
4.1 We will only use your personal information when the law allows us to. Please see below the legal bases for processing. We will use your personal information in one or more of the following circumstances:
Personal information category
Your contact details, including your title, name, address, telephone number and personal e-mail address
Your disability data
Your contact details, including your title, name, address, telephone number, personal e-mail address and bank account details.
* where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests.
We do not carry out any automated decision-making, including profiling, using your personal information.
5. Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.
6. Sharing your personal information?
6.1 ITOPF may also share your personal information with third-party service providers (and their designated agents), including:
a) external IT services
b) external auditor
c) professional advisers, such as lawyers and accountants
d) external administrators and data processors.
6.2 ITOPF may also share your personal information with other third parties:
(a) in the context of a potential sale or restructuring of some or all of its business;
(b) including government authorities and international organisations in the context of assisting in and handling oil spill response;
(c) including a regulator in the context of compliance with the law or where we need to comply with a legal obligation; or (d) where it is necessary to administer the contract we have entered into with you or where it is necessary for our legitimate interests (or those of a third party).
7. How does ITOPF protect your personal information?
7.1 ITOPF has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities.
7.2 Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
7.3 ITOPF also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner's Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
8. How long does ITOPF keep your personal information?
8.1 ITOPF will retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.
8.2 When assessing what retention period is appropriate for your personal information, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal information;
- the lawful grounds on which we based our processing;
- the types of personal information we have collected;
- the amount and categories of your personal information; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
9. Transferring personal information outside the European Economic Area
9.1 ITOPF may transfer your personal information to countries outside the European Economic Area (EEA) and the United Kingdom (UK). Countries outside of the EEA and the UK may not have the same level of legislative protection as in the EEA or the UK. However, if we do need to transfer your data outside of the EEA and the UK we will put in place appropriate measures and agreements to ensure a similar degree of data protection in line with Data Protection Legislation.
10. Your rights in connection with your personal information
10.1 It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your contact details.
10.2 As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
a) be informed on how we handle, process, and share your personal information.
b) request access to your personal information.
c) request rectification of your personal information.
d) request the erasure of your personal information where there is no good reason for us to continue processing it.
e) restrict the processing of your personal information.
f) object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) as set out in the table above. We may have a compelling interest to continue our processing of your personal information and we will inform you, if that is the case.
g) request the transfer of your personal information to another party if the processing is based on consent, carried out by automated means and is technically feasible.
10.3 If you wish to exercise any of these rights, please contact Lisa Stevens, Information, Communication & Education Manager at ITOPF's address, detailed in section 1 of this Privacy Notice.
10.4 Where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time (for example, to receive certain marketing materials or publications from us). This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact Lisa Stevens, at the address detailed in section 1 of this Privacy Notice.
10.5 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
10.6 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10.7 If you believe that ITOPF has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner's Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – ico.org.uk/make-a-complaint/
ITOPF website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets number of cookies in order to better understand how users use it. The software will save a cookie to your computer's hard drive in order to track and monitor your engagement and usage of the website but will not store, save or collect personal information.
Users are advised that if they wish to deny the use and saving of cookies from ITOPF's website onto their computer hard drive they should take necessary steps within their web browsers security settings to block all cookies from our website and it's external serving vendors.
For more information on the cookies set by Google Analytics please go to: code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html.
Session & TYPO3 Content Management Cookie
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We use session cookies to record an individual users preferences that the user has specified, so that each time the user returns their preferences remain. Commonly this would be language settings, shopping carts, anything where you have indicated a preference. Where forms are used on the site, we hold the information in a session cookie so that we can improve the user experience on the site. Should a user, for example, forget to fill in parts of a form when submitting a form, we can auto-fill the values for those fields that have been filled in, thereby reducing the amount of fields a user needs to amend. This information is stored only in your browser and is destroyed once your browser is closed.
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These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site for you. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
We use third party companies as suppliers for some of our website functions. Their use of the data is controlled by our contract with them and they are only allowed to use the data strictly for the purpose we have stated e.g. the data is not used in connection with data from other companies and we are not tracking user behaviour outside our own sites.
This privacy notice was last updated on 27 May 2022.