PART A: PRIVACY NOTICE (last updated 14th November 2024)
This privacy notice tells you what to expect us to do with your personal information.
How to complain
Contact details
Post
The Brentano Suite, Unit 720, Catalyst House, Centennial Park, Centennial Avenue, Elstree, Elstree, Hertfordshire, WD6 3SY, GB
Telephone
020 8191 7500
secretariat@theABI.org.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
Names and contact details
Addresses
Gender
Occupation
Date of birth
Transaction data (including details about payments to and from you and details of products and services you have purchased)
Employment details (including salary, sick pay and length of service)
Credit history and credit reference information
Criminal records data (including driving or other convictions)
Information relating to compliments or complaints
Video recordings
Audio recordings (eg calls)
Records of meetings and decisions
Account access information
We collect or use the following personal information for the operation of client or customer accounts:
Names and contact details
Addresses
Purchase or service history
Account information, including registration details
We collect or use the following personal information to comply with legal requirements:
Name
Contact information
Identification documents
Any other personal information required to comply with legal obligations
Criminal offence data
We collect or use the following personal information to protect client welfare:
Names and contact information
Health and wellbeing information
Emergency contact details
We collect or use the following personal information for recruitment purposes:
Contact details (eg name, address, telephone number or personal email address)
Date of birth
Employment history (eg job application, employment references or secondary employment)
Education history (eg qualifications)
Details of any criminal convictions (eg Disclosure Barring Service, Access NI or Disclosure Scotland checks)
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Address
Witness statements and contact details
Photographs
Relevant information from previous investigations
Customer or client accounts and records
Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Where a complaint is raised about a sector practitioner who is not or no longer a member of the ABI, we may need to process personal data to assist the complainant or safeguard the ABI should the practitioner later apply for membership. We balance those interests against the rights and freedoms of the individual.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Where a complaint is raised about a sector practitioner who is not or no longer a member of the ABI, we may need to process personal data to assist the complainant or safeguard the ABI should the practitioner later apply for membership. We balance those interests against the rights and freedoms of the individual.
Our lawful bases for collecting or using personal information to comply with legal requirements:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to protect client welfare are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
On a data subject approaching the ABI, we may process personal data by way of our due diligence process.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Where a complaint is raised about a sector practitioner who is not or no longer a member of the ABI, we may need to process personal data to assist the complainant or safeguard the ABI should the practitioner later apply for membership. We balance those interests against the rights and freedoms of the individual.
Where we get personal information from
Directly from you
Regulatory authorities
Legal bodies or professionals (such as courts or solicitors)
Publicly available sources
Previous employment
Credit reference agencies
Suppliers and service providers
How long we keep information
Membership personal data is retained for a period of 2-years after the membership status has ended, unless in a contentious scenario when the period may be extended for up to 6-years
Who we share information with
Data processors
ABI Secretariat Limited
This data processor does the following activities for us: All administration and data protection activity
Others we share personal information with
Other financial or fraud investigation authorities
Insurance companies, brokers or other intermediaries
Professional or legal advisors
Emergency services
Regulatory authorities
External auditors
Organisations we’re legally obliged to share personal information with
Publicly on our website, social media or other marketing and information media
Previous employers
Suppliers and service providers
Professional consultants
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Various, where for example an applicant provides refereee details outside the UK
Category of recipient: Referees
Country the personal information is sent to: various
How the transfer complies with UK data protection law: An exception listed in UK GDPR
Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
Organisation name: Various, where for example, an applicant provides referee details outside the UK
Category of recipient: Referees
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: An exception listed in UK GDPR
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
