Privacy Policy

Purpose of this Privacy Notice

Under the new General Data Protection Regulations (GDPR) we are required to inform you about what information we collect about you, what we do with that information, on what legal basis we hold that information and how you can request access to or request deletion of any information we hold about you.

This privacy notice aims to give you information on how CBR UK collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, donate or request further information from us through this website as well as other interaction with us outside of the website.

This website is not intended for children and we do not knowingly collect data relating to children.

CONTROLLER  

Centre For Bio-Ethical Reform UK (CBR UK) is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Centre For Bio-Ethical Reform UK

Name or title of data privacy manager: Ivana Forman

Email address: [email protected]

Postal address: 23 New Broadway, Tarring Road, Worthing, West Sussex, BN11 4HP

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 our privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and we will place any updates on our website. This privacy policy was last updated on 4 March 2021.

Previous Privacy Policy Dates: 21 May 2018, 20 July 2018, 8 February 2019.

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 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 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 follows:‍

• Identity data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.‍
• Contact data includes billing address, email address and telephone numbers.‍‍
• ‍Financial data includes bank account and payment card details.‍
• Technical data includes internet protocol (IP) address, 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 this website.‍
• Profile data includes your preferences, feedback and survey responses.‍
• Usage data includes information about how you use our website.‍
• Marketing and communications data includes your preferences in receiving marketing from us and your communication preferences.
• ‍Video/audio data includes video and audio recording of the general public from any Educational Displays or events by CBR UK.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, or electronic means such as but not limited to email, social media posts or website sign ups, or on the streets during an Education Display or during a CBR UK event. This includes personal data you provide when you:
  ‍
  - subscribe to our newsletter
  - request information to be sent to you
  - enter a competition, promotion or survey
  - give us some feedback or
  - give us information for donation purposes‍
  ‍
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.‍
• Video/audio. During any public Educational Displays Body Worn Video and audio cameras are used by display team members. There will be occasions when we live stream recordings from these displays. We may also conduct interviews and film in the public square for journalistic purposes. 
  
• Cookies. Cookies are text files placed on your computer to collect standard internet information and visitor behaviour information. This information is used to track your use of the website to enhance your use of it and for us to compile statistical reports on website activity.
  
  - For further information visit aboutcookies.org or www.allaboutcookies.org
  - You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

We will only use your personal data when the law allows us to.  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.
• 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.
• Where you have given us consent.

You have the right to withdraw consent to marketing at any time by contacting us or by following the unsubscribe link given in every email sent.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We ensure your personal data is protected by requiring all projects under CBR UK to follow the same rules when processing your personal data.

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.

EDUCATIONAL DISPLAY FILMING – The use of body worn video/audio cameras

Body Worn Video and audio cameras are used under the lawful basis of legitimate interest for the security and protection of volunteers and public and for monitoring and reporting any unlawful behaviour of the public towards CBR UK staff and volunteers, and vice versa. Footage will be used to provide evidence of, or lack thereof, to the necessary authorities or other legal bodies as required.

Video and audio of all displays is held for a limited period on a secure, encrypted server so that proof or disproof of any claims of illegal activity by CBR UK and its volunteers or of the public can be substantiated. If there are no incidents all footage is deleted after the limited period. To see a copy of our Filming Data Retention Policy please contact us.

OTHER RECORDING OF VIDEO/AUDIO

Live streaming from other recording devices may also be used under the lawful basis of legitimate interest for journalistic purposes to promote the organisations objectives and in the public interest. The Data Protection Act 2018 provides exceptions to full complaince with GDPR, outside of the exceptions will be in full GDPR compliance.

Other filming may take place under the lawful basis of legitimate interest for journalistic purposes and for the creation of promotional material to further the objectives of the organisation and in the public interest. The lawful basis of Consent will be used when legally required and the data subject will always be made aware of the purpose of use of the filming undertaken.

From time to time we will process your information or pass it to a third party with whom CBR UK has a Data Processor Agreement in place to facilitate the above activities, for example to a mailing house who send out newsletters on behalf of CBR UK, or a payment processing company who handles electronic donations.

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.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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 employees, agents 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.

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 upon request.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. They include the following:

• The right to access your personal data
• The right to request correction of your personal data
• The right to request erasure of your personal data
• The right to object to processing of your personal data
• The right to request restriction of processing your personal data
• The right to request transfer of your personal data
• The right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us using the information below.

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. Photographic ID such as passport will be required to confirm your identity if any video of the data subject is requested.

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 several requests. In this case, we will notify you and keep you updated.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

• By email to: [email protected] 

• By mail to: CBR UK, 23 New Broadway, Tarring Road, Worthing, West Sussex, BN11 4HP

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/product 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 impact on you (unless we have your consent or are otherwise required or permitted to by law).

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.

Third parties  

Internal third parties  

Other projects in the Centre For Bio-Ethical Reform UK Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

External third parties  

• Service providers acting as processors based in the USA who provide IT and system administration services.

• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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