WHAT IS THE PURPOSE OF THIS POLICY?
The NTIA is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your membership / association with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all employees, workers, contractors, consultants, members, partners, associates, suppliers, sponsors and affiliates.
The Night Time Industries Association (“NTIA”, “Organisation”, “We”) are registered in England and Wales under Company number 9418544 and have our registered office at 303, Ballards Lane, London, N12 8NP.
The NTIA is a business-to-business membership that provides a stronger, unified voice to the hospitality and night time sector through lobbying, advice, support, guidance, representation and such.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date; and
- Kept only as long as necessary for the purposes we have told you about.
The NTIA is a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. We use the data we collect from you to improve our services. By doing so, we will:
- Ensure your data is kept safe and private;
- Not sell your data or pass to third-party organisations without your consent;
- Always give you ways to update / view your data; and
- Give you ways to manage and review your marketing choices at any time.
This notice applies to the current and former members, prospective members, newsletter subscribers, social media contacts, survey participants, partners, associates, suppliers, sponsors and affiliates of ours in respect of whom we hold personal data.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
HOW WE USE YOUR DATA
As a membership organisation, we must use and manage our members data in order to communicate with you and share details of our products, services, membership benefits and campaigns. It is what the law calls ‘legitimate reason’. The same applies when you book an event or buy a publication from us. To some extent, we also have a contractual obligation to contact you as per the Terms and Conditions you agreed on when you joined or being in force for the time being. We also collect/use your date when you update your details.
Your information as a member will be used for:
- Managing your membership – renewals, payments, amendments, changes, etc.;
- Providing membership services and benefits, via email, post, phone and SMS or WhatsApp;
- Keeping you updated about the industry, changes to legislation, events, etc.;
- Contacting you for surveys and research;
- As part of the benefits of your membership, some of your data (as with contact details and addresses) might be shared with our regional or other member-led groups which might interest your business, to facilitate their engagement with you. Likewise, you will also have access to their details. Each such group is subject to a confidentiality agreement and shall always keep your data secured;
- In order to take advantage of some of your membership benefits, your data will have to be processed. This will be subject to changes if new benefits are added to our portfolio. At the moment, these benefits are:
- If you buy a ticket to an event or order a publication from us, we will also collect the necessary data for that booking or to provide you access to the publication or to post it to you. All relevant information about these transactions will be specified to you at the time of the booking/purchase. As this is a transaction, we will have the legal obligation to process your data on this occasion.
- We will also process your data if that is necessary for compliance with a legal obligation which we are subject to.
Your information as a respondent to a survey or newsletter subscriber will be used for:
If you enter credit card information on the Site in connection with a membership purchase, that information is sent directly from your browser to Stripe our third-party service provider we use to manage credit card processing and we do not store it on our servers.
The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
When you submit personal information to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.
Categories of personal information collected by the NTIA may include Member Profile Information (name, email address, business address, contact telephone number), Sales & Support History (Purchase history, and other sales support interactions), Security & Login Information (Your login events, password changes, email changes and mobile device information), Site Activity (Pages you viewed and “like activity”), Marketing Activity (Marketing programs you have joined, content downloaded, etc.), User Feedback (feedback you have provided the NTIA via email, app/website and other channels), and/or Content You Contributed (reviews, email communication).
Information We Collect Automatically
When you use the Site, your device is automatically providing information to us so we can respond and customise our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Site. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, Site type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Site.
Automated means of data collection include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Site. For example, when you access a NTIA website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Site, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
WHO HAS ACCESS TO YOUR DATA?
- Employees and Contractors of the NTIA; that is to provide your membership benefits and services.
- Third-party contractors and suppliers of the NTIA as described above, all part of the services of your membership subscription.
The data that we collect from you will be stored in accordance with the stipulations of the new GDPR and will always be kept secure.
In any event, your data will only be transferred to any third-party mentioned in this policy if they have a code of practice in place for Data Protection. We will take all reasonable steps to ensure your data is treated securely and in accordance with this Policy.
HOW LONG WE KEEP YOUR DATA
Your data is part of your membership records and will be managed on our CRM system while your membership lasts as an auto-renewal contract and, in the event you cease to be a member, we will store the data for another 6 years for our financial records, after which the data will be destroyed.
ACCESSING YOUR PERSONAL INFORMATION
As part of your membership, you can check and update your personal information, as well as your communication preferences at any time by contacting our Head of Member Services: [email protected].
Any suspicious activity must be immediately communicated to the NTIA.
If you have any queries, comments or need any further assistance, please contact us at [email protected].
THE KIND OF INFORMATION WE MAY HOLD ABOUT YOU
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).
There are “Special Categories” of more sensitive personal data which require a higher level of protection.
Depending on the circumstances and business relationship we hold with you, we may collect, store, and use the following categories of personal information about you:
- Your personal contact details such as name, title, addresses, telephone number, and email addresses;
- Secondary contact details you provide us in relation to your business including name, title address, telephone number, and email addresses;
- Bank account details (business or personal);
- Credit card details (business or personal);
- Start date(s) of contracts and memberships;
- Location of workplace;
- Copy of licensing information (personal licence holders, premises licence, DPS information);
- Business information relating directly to your membership or business services we provide you;
- Payments history;
- Information about your use of our information and communications systems; and
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you (such as paying you or providing a service or benefit), or we may be prevented from complying with our legal obligations.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use if for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process your personal information without your knowledge or consent where this is required or permitted by law.
We may have to share your data with third parties, including third-party service providers and other entities within the Association.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We will not transfer your personal information outside the EU without your explicit consent.
If we do, you can expect a similar degree of protection in respect of your personal information.
WHICH THIRD-PARTY SERVICES PROVIDERS PROCESS MY PERSONAL INFORMATION?
“Third-parties” includes third-party service providers (including contractors, consultants, designated agents) and other entities within the Association. The following activities are carried out by third-party service providers: member benefits provision and administration, third-party service providers in partnership with the NTIA.
HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES WITHIN OUR ASSOCIATION?
All our third-party service providers and other entities in the Association are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party services providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHAT ABOUT OTHER THIRD PARTIES?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the Association. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We have put in place measures to protect the security of your information, for example to backup and protect the integrity of our electronic communications and data storage systems. Details of these measures are available upon request.
Third parties may only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to designated data processors and other third parties who have a business need to know. They may only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
As a member you must inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enable you to receive a copy of personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy of the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge you 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.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please write to us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purpose you originally agree to, unless we have another legitimate basis for doing so in law.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. 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.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the process of your personal information.
If you have any questions about this data protection / privacy notice, please contact us on [email protected]