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Data Protection Policy

Data Protection
Privacy and Cookies Policy

FOCUS Information Services is committed to protecting personal information and being transparent about what information we hold on anyone who has been in contact with us. We recognise that our members and contacts may be concerned about the information they provide to us, and how we treat that information. We also understand that privacy is a human right that benefits us all. Using data fairly is important to us as is using it securely.
PURPOSE
The purpose of having a Privacy Policy is to give a clear explanation about why and how FOCUS Information Services collects and uses any personal information. We ensure that we follow strict guidelines as per the EU General Data Protection Regulations 2017 and Privacy & Electronic Communications Regulations 2011. Our aim is to ensure that by respecting the privacy of our data subjects this will bring about benefits to them and in turn to FOCUS Information Services.
SCOPE
This policy applies to all activities undertaken by FOCUS Information Services within the UK. FOCUS collects data to provide the service that is at the core of our business. The processing of data will be handled securely and sensitively to the best of our abilities and in line with our data classification

Our Data Subjects

Our subjects include:
  • Members
  • Sponsors (Corporate and Marketing)
  • Employees, volunteers, contractors and freelancers
  • Business Contacts
  • Suppliers
If you have any questions about our Data Protection Policy or queries on how we use or have used your information please contact the Data Protection Officer:
By Post:
FOCUS Information Services Ltd.
13 Prince of Wales Terrace
London W8 5PG
By Phone:
020 7937 7799
By Email: office@focus-info.org with the subject/reference: DATA PROTECTION

FOCUS Information Services Limited is a private company limited by shares incorporated in England and Wales (No. 02189837). The registered office is c/o Goldwins, Chartered Accountants, 75 Maygrove Road, West Hampstead, London NW6 2EG. This policy will be reviewed periodically and may be changed/updated to reflect the review. Please ensure that you stay up to date by visiting our website.

Information Collection and Use

FOCUS is both a Data Controller (for the “off the street” members) and Data Processor (for the corporate members). The corporate members, who have been offered the FOCUS membership by their company, will receive our communication (both by email and by post) as part of our contractual obligation with these companies. They will have the right at any given moment to unsubscribe from our emails or our magazine distribution list. Moreover, FOCUS, like most website owners, receives and records information from various sources. The type of information we and/or our third party providers collect depends on the interaction between our members and contacts with us. This could be when joining as a member, registering for an event or seminar, or requesting information in a blank form on our website. We gather information through postal communications, visits to our websites, participation with our business/corporate partners, electronic communications, volunteering or communications through social media. We and/or our third party providers may also collect information publicly available through third party platforms (such as online social media platforms), online databases, or that is otherwise legitimately obtained.

Type of information collected

The type of information collected is also related to the interaction. This may include:
  • Name and Surname
  • Postal address and/or email address
  • Phone number
  • Nationality
  • Previous country and city lived
  • Number of children (no personal data) and their age if any
  • Specific concerns regarding the relocation if any

We may also collect information through cookies and similar technologies for analytical purposes. This information is usually de-identified information such as how people arrived at our website, pages they visited or general location. It may further collect information e.g. the device used to browse our website or app, the IP Address and related information, browsing history on our website, how people search our website or if they communicated with us. FOCUS is the sole owner of any information collected, either as an organisation or by third party on its behalf, web based or not.
This information is used for the purposes of meeting our object/objectives and meeting peoples’ objective for contacting us. We will not sell, share, or rent this information to others except as in meeting our objectives through for example third party outsource contracts/data processors or to the extent as required by law. Third party contractors are expected to meet our standards and are required to abide by our policies.
We will endeavour to undertake privacy impact assessment whenever there is fundamental change in the way we process data, implement suitable records management systems, and log data security incidents. This will enable us to keep rigorous control of information held and your privacy.

Consent

Emails/Phone
We will only contact members and contacts with regards to the products/services concerned or similar. For all other email/phone contact we will seek expressed consent via email before communicating with members. Therefore, if they received an email from us, their email address is either listed with us as someone who has expressly shared this address for the purpose of receiving email communications from us, or otherwise have an existing relationship with us and have consented to receiving communications from us via email/phone.
Post
Legitimate interest
Consent is given if, having obtained a postal address, communication is sent by post and that the correspondence is related to FOCUS’ ‘legitimate interest in pursuance its objects/aims and objectives’. The opportunity to opt out will be given to the addressee. Options will then be noted in accordance with their response/choice(s).
Data Subject Rights
Data subjects have the following rights:
  • Right to Erasure
  • Right to Access/Portability Requests
  • Right to Rectification (change or correct personal information)
  • Right to Reduction in time limit
For more information on your rights and control of your data please visit:
https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/the-right-of-access/

FOCUS will recognise your rights and endeavour to resolve any issues within 28 days.
Please contact the Data Protection Officer (DPO) by email at office@focus-info.org or at our office address (13 Prince of Wales Terrace, London W8 5PG) by post or in person, by phone at 020 7937 7799, if you wish to exercise any of these rights.

Mode of Communication Preference(s)/Choices

Our members and contacts can choose how they would like to receive communication including direct marketing mail from us – through postal mail or email. If they choose not to receive direct marketing communications from us we will honour their choice. This will not affect how we communicate with them in other matters. We respect their time and attention by controlling the frequency of correspondence/communication with them. Our members may modify their preferences at any time by phone (020 7937 7799), post to our address or via email (office@focus-info.org) or by using the unsubscribe message as instructed via email.

Controlling Personal Information

Personal information is information that can identify a person, such as name, address, telephone number, and email address.
As a member, you may choose to restrict the collection or use of your personal information:
  • whenever you are asked to fill in a form on the website, look for the box that you can leave unticked to indicate that you do not want the information to be used by anybody for direct marketing purposes;
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change their mind at any time by writing, phoning or emailing us.

We will not sell, distribute or release your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

Other Information

CARD INFORMATION SECURITY
We care about the safety and security of your transaction. We use high grade encryption and the https security protocol to communicate with your browser software. This method is the industry standard security protocol, which makes it extremely difficult for anyone else to intercept the card information you give us. Companies we work with to process card transactions also use high grade encryption and security protocols. FOCUS has applied to be PCI Compliant and the monitoring of its web access point/ports is monitored by the IT teams at Zebedee Creations and Ontinuity. Non-compliance is immediately reported to us and we take all necessary steps to fix breaches at the earliest opportunity. We also undertake annual assurances/checks on third party processors by ensuring that they are PCI Compliant by asking for confirmation of current status.

Accuracy of Information

In addition to maintaining privacy and security controls over information people share with us, FOCUS works continually to accurately process the information. During business hours, staff is available to answer questions about your financial transaction or personal information on 020 7937 7799.

International Transfers/VPN and Storage/Destruction of Data

Where it is necessary for FOCUS to transfer information abroad, FOCUS is committed to using a safe and secure transfer process including encryption where necessary. We will also seek to ensure that recipients have a data protection policy which meets our requirements or that they adhere to our Data Protection Policy/standards. Virtual logins will be password protected. Storage of information is important to us because our members’ and contacts’ privacy is paramount. We will store information in the safest possible way that we can and protect information in transit with suitable access codes/passwords. Risk assessments will be undertaken whenever necessary to guarantee adequate protection/reduce risk of interception by unauthorised ‘persons’. At all times we will endeavour to use administrative, technical and physical measures to protect your personal information. We will take reasonable steps to securely destroy or permanently de-identify personal information when we no longer need it. Information will only be held for as long as our policies allow or as required by law. Data held on hardware no longer in use/required by FOCUS will be destroyed by a competent IT Support and Management Service company.

Compliance Check

Internal and external checks are conducted regularly to ensure the privacy, security and appropriate processing of your information by us.

Complaints Policy

If members or contacts are unhappy with any aspect of our work, have a specific complaint or any comments we encourage them to get in touch with us. We will be happy to speak with them and try to resolve any issues. We will at all times try to convey through induction and annual training an awareness to staff and volunteers of the importance of data protection. We record complaints received, pass this onto the relevant department, have the complaint reviewed and resolved. Breaches will be notified to the Information Commissions Office (ICO) as per regulations.

External Links

Our website does contain links to other sites. We make an effort to keep the content and links up-to-date and to delete those that are obsolete. Unless we expressly state otherwise, FOCUS makes no representations whatsoever concerning the content of those sites. The fact that FOCUS has provided a link to a site is not an endorsement with respect to such site, its owners, or its providers. There are risks associated with using any information, software, or products found on the Internet, and FOCUS cautions you to make sure that you understand these risks before retrieving, using, relying upon, or purchasing anything via the Internet. In addition, we encourage our users to read the privacy and cookies policies of these linked sites. FOCUS is not responsible for the privacy practices of other websites. You may not create a link to this site that incorporates or relies upon, in whole or in part, any content from any page on this website, or that incorporates any copyright or otherwise intellectual property of FOCUS without written permission from us.

Cookies - Website Users

A cookie is a small data file that a website transfers to computers’ hard drive with people’s permission. Once people agree, the file is added and the cookie helps companies to analyse web traffic or lets people know when they visit a particular site. Cookies allow web applications to respond to people as an individual based on their previous actions. The web application can tailor its operations to their needs, likes and dislikes by gathering and remembering information about their preferences, personalising their experience on our website.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to user needs. We only use this information for in-house statistical analysis purposes.
Overall, cookies help us provide you with a better experience when on our website; it enables us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
People can choose to accept or decline cookies on our website. Most web browsers automatically accept cookies, but people can usually modify their browser setting to decline cookies if they prefer. This may prevent them from taking full advantage of the website. By accepting that they have read this policy, FOCUS deems that consent has been given for it to process data in accordance with said policy – i.e. dropping cookies.

Google and Facebook Site Stats

You may have clicked on an ad for the FOCUS website that was delivered by Google or a similar browser/social media site.
In the case of Google, the company measures the performance of the advertising it delivers. By providing a tool to more accurately measure the performance of the ads we deliver, Google (and advertisers) will be able to improve the quality and relevance of the ads that you see.
To measure performance, Google uses small strings of text/file (known as cookies) that are placed on the computer when people click on ads. Cookies typically remain active on computers for about 30 days. If people visit certain pages of the advertiser's website during that period, Google and the advertiser will be able to tell that they saw the ad delivered by Google. If you'd like to know more about how Google and similar organisations handle information gathered from the use of cookies, please read Google's privacy policy (http://www.google.com/privacy.html). If you want to disable the use of cookies, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Be aware, however, that some websites may not function properly if you refuse to accept cookies.

Copyright Statement

All material on webpages under the domain focus-info.org, @FOCUSinfo or @FOCUSinfoUK is, unless otherwise stated, the property of FOCUS Information Services Ltd. These materials are protected by copyright and other intellectual property laws. Information received through this website may be displayed, reformatted, and printed for personal, non-commercial use only. People may not reproduce or retransmit the materials, in whole or in part, in any manner, without the prior written consent of FOCUS with the following exception only: People may make single copies of the materials available through this website, solely for their personal, non-commercial use, and only if they preserve any copyright or other notices contained in or associated with them. They may not distribute such copies to others, whether or not in electronic form, whether or not for a charge or other consideration, without prior written consent of the owner of the materials.

Questions or Suggestions

It is important to us at FOCUS that we hear what members and contacts have to say about our organisation or our policies. If you have any suggestions, questions, concerns, or complaints or want to let us know what you think about our organisation, please contact us at 020 7937 7799 or email office@focus-info.org