Effective date: 23rd May 2024

Privacy policy

Responsible for CiPPPA website content:
TDi Sustainability (Project Management Office)

Registered office:
Bishop Fleming LLP, 10 North Place, Cheltenham, United Kingdom, GL50 4DW

Introduction

CiPPPA (Project Management Office: TDi Sustainability) is committed to safeguarding the privacy of visitors to its website. Please read the following policy to understand how any information you provide will be treated.

Obtaining, Purpose and Use of Information

Personal data means any information about an individual from which that person can be identified.

You are not required to provide any personal data on our website. However, you may choose to do so in order to contact us or sign up to our email newsletter or obtain access to our downloadable resources.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure client experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Contract: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Personal data submitted on this website will be used only for the purposes specified in the relevant part of the website and for any other purposes for which you give your consent. It will not be passed on to other parties.

You may provide us with personal data during introductions, in-person meetings, phone calls, emails, website interactions, or through other means.

While most personal data is directly collected from you, we may also obtain information from publicly accessible sources, websites associated with you or your company, social media platforms such as LinkedIn, or through referrals.

We collect, utilise, and process personal data solely for legitimate purposes that do not harm or prejudice you. These purposes (and our legal basis) include:

Provision of services to you, along with relevant information pertaining to these services (based on contract and “legitimate interests” where the data subjects are existing clients or contacts).
Maintenance of accurate and up-to-date contact records (based on consent and/ or legitimate interests ).
Relationship management and direct marketing, including newsletters, event notifications, notifications relating to changes in our privacy policy, dealing with your requests, complaints and queries (based on necessity to comply with legal obligations, consent or legitimate interests in order to keep our records updated).
To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data (based on legal obligations and legitimate interests for running our business provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
To deliver relevant website content to you and measure or understand how you use our website (based on legitimate interests to study how clients use ourwebsite, for us to develop it and to inform our marketing strategy).
To use data analytics to improve our website and its content, client relationships and experiences and to measure the effectiveness of our communications and marketing (based on legitimate interests to define types of clients, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To send you relevant marketing communications and make personalized suggestions and recommendations to you about CiPPPA that may be of interest to you based on your Profile Data (based on legitimate interests to carry out direct marketing, develop our products/services and grow our business).
To carry out market research through your voluntary participation in surveys (based on legitimate interests or consent).
Compliance with legal obligations, as required by law or regulation (based on legal requirement).

Data Collection via Website

Visiting our website (CiPPPA) is generally anonymous, with no activities aimed at personally identifying visitors. However, we may collect, store, and utilize personal data that relates to your website visits and the device used to access it, including:

Internet Protocol (IP) address, device identifier, browser type and settings, operating system, platform, and geographical location, providing always that you have consented to our collecting this.
Information regarding visitors’ use of the CiPPPA website, such as viewed pages and search terms.
Marketing and communications data including your preferences in receiving marketing from us and communication preferences.
You may also choose to provide personal data when using our website in order to contact us or sign up to our email newsletter, or to obtain access to our downloadable resources. Personal data submitted on this website will be used only for the purposes specified in the relevant part of the website and for any other purposes for which you give your consent. It will not be passed on to other parties.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.

Third Party Marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of Marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service purposes for example relating to order confirmations for a product/service, updates to our Terms and Conditions or checking that your contact details are correct.

Contact us form

When you use any of the ‘contact us’ forms on this website you are requesting we contact you and providing us with your contact details so that we may do so. When we use your personal data for the purposes of contacting you to respond, we are relying on your consent (which is given when you provide your contact details and invite us to “contact you”).

The information we collect

In order to deal with your request, we may collect, use, store and transfer different kinds of personal data. The personal data we collect on the ‘Contact us’ forms includes the following:

Full name
Title
Email address
Company
Specific content provided by user which might contain further personal and business data specific to each ‘Contact us’ online form

How we use your data

We process your data to communicate with you and to develop our understanding of our clients and their use of our services. All of the personal data we process is processed by TDi Sustainability, and located on TDi Sustainability’s servers in the European Union (Republic of Ireland) and London. Subject to your prior consent, It may be shared with CiPPPA partnership members solely to respond to your enquiry, and not for other purposes. We will not collect any personal data from you that we do not need to provide and oversee this service to you.

2. Sign up to newsletter form

By using any of the ‘sign up to our newsletter’ forms, or ticking the ‘sign up to our newsletter’ form on the ‘contact us’ forms on our website you give us your consent to contact you in reply.

When you sign up to receive our newsletter, the data you provide will be used exclusively for this purpose. It will be stored on our database of newsletter recipients.

For an effective registration we need your name and a valid e-mail address. The data will be used exclusively for newsletter distribution and will not be passed on for third parties.

You can unsubscribe from our newsletter at any time by clicking the unsubscribe link in any one of the newsletter communications or sending a written request to [email protected].

Disclosure of your Personal Data

We may share your personal data where necessary with the parties and for the purposes set out below:

CiPPPA partnership members solely to respond to your enquiries and for no other purposes.
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 privacy policy.

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.

International Transfers

We transfer personal data outside the UK solely to enable CiPPPA partnership members to respond to your specific enquiries, and for no other reason. Where we transfer the personal data outside the UK and the EEA, we do so ensuring that the appropriate safeguards are in place, in accordance with Data Protection laws.

Confidentiality and Security

CiPPPA (Project Management Office: TDi Sustainability) employs appropriate technical and organisational measures to protect personal data both online and offline from unauthorised use, loss, or destruction. Access to personal data is restricted to authorised personnel and third-party service providers, limited to necessity.

We employ industry-standard efforts to maintain data confidentiality, including encryption and firewalls. Reasonable administrative, technical, and physical security controls are in place to prevent data loss, misuse, or alteration.

While we strive to secure information transmitted over the Internet, we cannot guarantee absolute security or immunity from unauthorised access. In the event of a data breach, affected parties will be notified, as required by applicable regulations.

Your Rights

TDi Sustainability (in its capacity as Project Management Office for CiPPPA) has a legal obligation to ensure that your information is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes. You have the right to request details of the information we hold about you and to delete or rectify any inaccurate information about you by sending a written request to [email protected].

You can unsubscribe from our newsletter at any time by clicking the unsubscribe link in any one of the newsletter communications or sending a written request to [email protected].

Any information collected about you will be used lawfully, in compliance with the Data Protection Act 1998 and the General Data Protection Regulation 2018. Your personal data will not be disclosed, sold, rented, or shared with any external parties beyond TDi Sustainability, which acts as the Project Management Office for CiPPPA. Access to your personal data is restricted to authorized employees and contracted service providers, who manage this data solely for the purpose of contacting you based on your preferences.

You have a number of 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 “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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing above for details of how to object to receiving direct marketing communications).
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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
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
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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

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 could 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 could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

Cookies

TDi Sustainability uses cookies on the CiPPPA website for storing session data so we can track our website usage, if you have consented to their use. A cookie does not give us access to your computer or any information about you other than the data you choose to share with us.

Google Analytics

We utilize Google Analytics cookies to analyze visitor behavior on our website, aiding in the improvement of navigability. Google Analytics cookies are first-party cookies and can only be accessed by TDi Sustainability, acting as the Project Management Office for CiPPPA. Detailed information on Google Analytics cookies can be found here.

Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: [email protected].

Postal address: Bishop Fleming LLP, 10 North Place, Cheltenham GL50 4DW

Telephone number: +44 (0) 07769 223 294

Concerns or Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. You may contact TDi Sustainability at [email protected].

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy from time to time to ensure that it complies with current legal requirements or to implement changes to our services in the Privacy Policy Statement, for example, when introducing new services. In this case your further visit will be subject to the new privacy policy. Be sure to check back here periodically for any 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, for example a new address or email address.

This Privacy Policy Statement does not extend to anything that is inherent in the operation of the Internet, and beyond the control of TDi Sustainability and is not to be applied in any manner contrary to applicable laws, rules or regulations.

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 policy of every website you visit.