Faculty and Community Members, Partners in Learning and ICAEW Academy of Professional Development Privacy Notice

This notice, including its Appendices that apply to residents of certain countries (referred to as this “privacy notice”), explains what Personal Data The Institute of Chartered Accountants England and Wales (ICAEW) holds about ICAEW Faculty and Community Members, Partners in Learning (tutors working in ICAEW recognised professional education providers and higher education institutions), and individuals who enrol in professional development training as a delegate in our Academy of Professional Development (you). This notice does not cover individuals who may also be members or students as part of these groups, there are separate privacy notices for these individuals which can be found on the ICAEW website. It explains how we collect it, and how we use and share Personal Data. Please ensure that you read this privacy notice (including the Appendix applicable to you) and any other privacy notices we may provide to you from time to time when we collect or process Personal Data about you while you are part of one of these ICAEW groups.

ICAEW is the controller for the Personal Data collected from Faculty and Community Members, Partners in Learning, and individuals who enrol in professional development training as a delegate in our Academy of Professional Development unless this is stated otherwise. ICAEW is registered with the Information Commissioner’s Office (ICO) with registration number (Z5765897). In this privacy notice, references to ‘we’, ‘us’ or ‘our’ mean ICAEW. You can contact ICAEW in a number of ways as follows:

• Email: dataprotection@icaew.com
• Post: The Data Protection Office, ICAEW, Metropolitan House, 321 Avebury Boulevard, Milton Keynes, MK9 2FZ UK
• Telephone: +44 (0)1908 248 250

Personal Data is any information which directly or indirectly identifies an individual, for example, your name, address, membership and/or member number, NI number, qualifications, date of birth, photos, videos or voice recordings.

Special categories of Personal Data are a set of Personal Data that we are required to look after even more carefully. Subject to the relevant data protection law, special categories of Personal Data may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. In limited circumstances, we collect special categories of Personal Data about you through the application process, for example, we may collect details of your health data to ensure that we can make reasonable adjustments for you.

We collect Personal Data about you when you join an ICAEW faculty or community, when you take a qualification via a registered Partner in Learning, or you attend an event or course within the Academy.

We collect Personal Data about you when you give us Personal Data in direct interactions with us, for example by completing the registration process, attending courses and webinars. We also collect Personal Data from other sources as set out below.

Personal Data collected directly from you

Identity Data	Name, date of birth.
Contact Data	Your address, email address and phone number.
Diversity and Inclusion Data	Details of your gender, nationality, ethnicity and disability information.
Education Data	Details of your academic and professional qualifications including, educational establishments, dates of study, subjects studied and results.
Career Data	Current employer, employment history, details of membership of Professional Bodies.
Financial Data	Details of your bank account and credit card details.
Webchat Data	Any personal data provided by yourself to us via webchat.
Website Data	Information collected during your use of our website. Please see our website privacy notice (Website and email privacy notice | ICAEW policies | ICAEW) for more details.
Cookie Data	Where your personal data is processed through the use of cookies.

Personal Data provided by third parties

Corporate member firms	Your name, email address.
Social media	Your name, email address and phone number, social media profile such as LinkedIn and Facebook.

Some of the Personal Data we process is mandatory meaning that if you do not provide it to us, we will be unable to provide some or all services to you.

Processing Personal Data from you allows us to administer and manage the process of registering you as ICAEW Faculty and Community Members, Partners in Learning (tutors working in ICAEW recognised professional education providers and higher education institutions), and as a delegate in our Academy of Professional Development. In order to comply with Personal Data protection laws, we need a lawful basis (a reason) to process your Personal Data. We use the following lawful bases to obtain and use your Personal Data. Subject to the relevant data protection law, we may use the following lawful bases to obtain and use your Personal Data.

1. Performance of a Contract – We need to process your Personal Data to take steps at your request, prior to entering into a contract with you and for the performance of our contract with you. This could include but isn’t limited to:
• as part of your membership in an ICAEW faculty and/or community
• when you register for a course or event as part of our Academy for Professional development
2. Consent – Some Personal Data is processed because you have given your consent. Consent can be withdrawn at any time by either logging into your online member account and amending your preferences or by contacting us at dataprotection@icaew.com.
3. Legal or Regulatory Obligation – In some cases, we need to process Personal Data to comply with a legal or regulatory obligation which we are subject to.
4. Legitimate Interest – Where processing the Personal Data is in our legitimate interests (or those of a third party) provided that your fundamental rights do not override such interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Personal Data for our legitimate interests.

The table below describes the ways in which we use your Personal Data and the legal bases we rely on to do so, subject to the relevant data protection law. Where appropriate we have also set out our legitimate interests in processing your Personal Data.

Purpose and/or activity	Type of Data	Legal basis for processing
To register you as a faculty or community member, provide you with advice in relation to your registration as a member, to enable you to sign up for and use a member account on our website, to administer and manage your faculty or community journey.	Identity Data Contact Data Career Data Education Data Financial Data Member Data	Performance of a contract: to enable you to register as a member and to communicate with you once you become a member. Legitimate interest: where you are joining as part of a corporate membership who share your data with us to join a faculty.
To take payment or provide you with a refund	Financial Data	Performance of a Contract: to allow us to take, if necessary, refund, payments made by you for the provision of services by ICAEW.
To register you as a Partner in Learning tutor. To provide you with free access to teaching resources relating to ICAEW qualifications. To provide regular updates regarding developments with ICAEW qualifications via a tutor alert and annual conference. To provide you with a dedicated link to your website which features any partnership arrangement with ICAEW. To provide you with the ICAEW partner in learning logo and corresponding brand guidelines.	Identity data Contact data Professional qualification details	Performance of a Contract: to enable you to register as a partner in learning and to communicate with you once you become a partner in learning.
To provide you with updates and information, including changes to regulations or changes to the way rules are applied and other updates relevant to you; to send you other information or updates relating to our services that you may be interested in including our faculty magazines and direct marketing emails. We will only send direct marketing emails and our faculty magazine to you with your consent. Please see the Direct Marketing section in this table below for more information	Identity Data Contact Data	Performance of a contract: to deliver to you the services included in your membership.
For non-UK residents becoming faculty or community members, to manage and administer international routes to becoming a faculty or community member; to assess ability of prospective referee to act as a referee for prospective international member; and to assess eligibility	Identity Data Contact Data Career Data Education Data Financial Data Criminal Offence Data Member Data Diversity and Inclusion Data	Performance of a contract: to enable you to register as a faculty or community member and to communicate with you once you become a faculty or community member.
Direct Marketing, sending you emails to promote our/relevant third-party services, sending you our faculty magazines by post	Identity Data Contact Data	Consent: where you have consented to receiving the communications. Legitimate Interests: in our legitimate interests as a professional body and regulator of chartered accountants, we will use your Personal Data for marketing purposes where we have a relevant or appropriate relationship with you or where there is a reasonable expectation of us doing so.
To provide you with member benefits	Identity Data Contact Data Career Data	Consent: where you have opted in to receive promotional emails from third parties.
Providing professional development training	Identity Data Contact Data Career Data Education Data	Performance of a contract: to deliver to you the services included in your membership.
Research	Identity Data Contact Data Career Data Education Data	Consent: where you have consented to take part in our research activities. Legitimate Interests: in our legitimate interests to understand more about non-members and how better to serve them.
Audit related activities to ensure ICAEW understands its business practices	A Sample of all Personal Data	Legitimate Interests: where we have a legitimate interest in auditing our internal processes and procedures to ensure that we are complying with applicable laws and internal and managing risk appropriately.
Anonymisation of personal data for the onward activities of Management Information and Business Intelligence	All Personal Data	Legitimate Interest of the ICAEW for business improvement and intelligence purposes.
To distribute financial reports to business partners for analysis and accruals for the month-end process	Identity Data Contact Data Financial Data Career Data	Legitimate Interest for ICAEW to meet its financial month-end obligations
Performing system testing in order to enhance and improve our products or services	Identity Data Contact Data Education Data Career Data	Legitimate Interest: In our legitimate interest to review and improve our services provided to you.
Serving you with targeted and retargeted advertisements and monitoring the success of those advertisements	Identity Data Contact Data Cookie Data	Legitimate Interests: in our legitimate interests as a professional body and regulator of chartered accountants, we will use your Personal Data for marketing purposes where we have a relevant or appropriate relationship with you or where there is a reasonable expectation of us doing so and also to monitor the success of these advertisements in order to understand how better to serve ads to you. Consent: Where you have consented to the use of cookies to provide you with targeted advertisements

Where the information we process is special category or sensitive data such as your health data, subject to the relevant data protection law, the additional bases for processing that we rely on may include:

1. Where you have provided ICAEW with your explicit consent to the processing.

We keep Personal Data that we obtain about you for no longer than is necessary for the purposes for which it is processed, except as otherwise required or permitted by law. How long we keep your Personal Data will depend on how long you remain an associate of ICAEW, the nature of the Personal Data concerned and the purposes for which it is processed.

No automated decision making is used in relation to Faculty and Community Members, Partners in Learning, and individuals who enrol in professional development training as a delegate in our Academy of Professional Development.

ICAEW may share your Personal Data with third party processors who provide services to the organisation where we have a legal obligation, contract or other legitimate interest to do so, subject to the relevant data protection law. These services include, but are not limited to:

1. payment providers;
2. business system providers;
3. publishers and mailing houses;
4. training providers;
5. website content and hosting providers, including analytics.

We may share your Personal Data with organisations where we have a legal obligation, contract or other legitimate interest to do so, subject to the relevant data protection law, including:

1. Building landlords and facilities management organisations (CCTV and access control systems);
2. External auditors
3. access your Personal Data to perform our contractual obligations (such as providing member services to you) and to deal with your requests or complaints;
4. Third party content sponsors, in order to assist them in delivering an event that you have registered to attend or where they are providing content so that they can send you relevant information that may be of interest to you. Identity Data, Contact Data and Career Data will only be sent for individual subscribers where they have consented or corporate subscribers where we have told you that we will do so, and you have not objected.
5. Your Employer - if you are a member as part of a corporate firm membership, to ensure that we have an accurate and up-to-date list of members.

Your Personal Data may be transferred to other third-party organisations in certain scenarios in accordance with law:

1. If we are discussing selling or transferring part or all of our business. Personal Data may be transferred to prospective purchasers under suitable terms as to confidentiality.
2. If we are reorganised or sold, Personal Data may be transferred to a buyer who can continue to provide services to you.
3. If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority, for example the Police, we may need to share your Personal Data; or
4. If we are investigating or defending any legal claims your Personal Data may be transferred as required in connection with defending such investigations and/or claims.

In some cases, we or our suppliers may need to process Personal Data outside your country, the European Economic Area (EEA) and/or United Kingdom (UK). Where this is the case we will only share the minimal amount of Personal Data necessary for the purpose of processing and, where possible, we will share the Personal Data in an anonymised form.

Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK Information Commissioner’s Office.
2. where we use certain processors, we may use specific contracts approved by the UK Information Commissioner’s Office which gives Personal Data the same protection it has within the UK. When we rely on this measure, we will ensure that the third-party can comply with the provision of such contracts and we have confirmed that the country to which the Personal Data is transferred has adequate data protection laws in place to protect Personal Data.

Please contact us at dataprotection@icaew.com if you would like further information about the specific mechanism used by us when transferring your Personal Data.

We have appropriate security measures in place to prevent Personal Data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Under the relevant data protection law, you may have rights including:

1. Your right of access – You have the right to request access to, or ask us for copies of, your Personal Data.
2. Your right to rectification – You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete.
3. Your right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.
4. Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
5. Your right to object to processing – You have the right to object to the processing of your Personal Data in certain circumstances.
6. Your right to data portability – You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.
7. Rights related to automated decision making, including profiling - You have the right to ask for explanations on a decision based on automated processing that may significantly affect you, and the right not to be subjected to a decision based solely on automated processing (including profiling) which may significantly affect you. We do not make any employment decisions, solely using automated decision-making technologies.

In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request, subject to the relevant data protection law. If we need to extend the time for responding to your request, we will let you know within the period. We do not charge a fee for any such requests unless there are exceptional circumstances.

If you wish to exercise any of your rights, please contact our Data Protection Office via email using dataprotection@icaew.com.

If you have any concerns about the Personal Data we use about you, 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, by contacting them at www.ico.org.uk, or the relevant data protection authority of your country as mentioned in the applicable Appendix. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the relevant data protection authority, so please feel free to contact us in the first instance via email using dataprotection@icaew.com.

This Appendix applies to individuals who reside in the People's Republic of China (for the purposes of this privacy notice, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan) (China).

This Appendix supplements the main body of this privacy notice should be read together with the main body. In the event of any conflict or inconsistency between this Appendix and the main body of this privacy notice, this Appendix shall prevail.

Legal basis for processing your Personal Data

We process your Personal Data for the purposes mentioned in the main body of this privacy notice with your consent or as otherwise required or permitted by applicable law (e.g. where the processing is necessary for concluding or performing a contract with you, where the processing is necessary to perform legal obligations, etc.).

Processing of your Personal Data upon the expiry of the relevant retention period

We will irreversibly destroy or anonymize your Personal Data upon the expiry of the relevant retention period in a way that prevents that information from being restored or reconstructed.

Sensitive Personal Data

Sensitive Personal Data is Personal Data that, once leaked or illegally used, may easily cause the personal dignity of a natural person to be infringed or his/her personal or property security to be endangered. It includes data related to biometrics, religious belief, specific identity, medical health, financial account and location tracking, the Personal Data of a minor under the age of 14 (Minor Personal Data), as well as government issued ID information. The sensitive Personal Data about you we process may include Diversity and Inclusion Data and Financial Data. We only process your sensitive Personal Data where such processing is strictly necessary for the relevant purposes identified in the main body of this privacy notice. Our processing of your sensitive Personal Data will adhere to the safeguards mandated by applicable laws and regulations. However, depending on the specific type of sensitive Personal Data involved, such processing may result in various impacts, including potential harm to your reputation, property, or personal safety in the event of a data breach.

We will not knowingly collect or process Minor Personal Data except with consent of the parent or guardian or as otherwise permitted by law. When we collect or process Minor Personal Data, we will process such data in accordance with the safeguards set out in applicable laws and regulations.

If you are a parent or guardian who believes that we collect or process any Minor Personal Data of your child without your consent or would like to erase, correct, or exercise any other right regarding any Minor Personal Data of your child, or have inquiries or complaints about how we process Minor Personal Data, please contact our Data Protection Office, which is in charge of protection of Minor Personal Data, through the means mentioned in the main body of this privacy notice.

Sharing of your Personal Data

With your express consent where required, we may share your Personal Data with third parties as described in the main body of this privacy notice.

Overseas transfer of your Personal Data

As ICAEW operates globally, with your express consent where required, we may transfer your Personal Data outside of China, including to the UK and other jurisdictions where we, our service providers and other relevant third parties conduct business. In particular, your Personal Data may be transferred to our office in the UK for our storage and processing in accordance with this privacy notice.

We may also share your Personal Data with third parties outside of China. The following list specifies the identity of the third parties outside of China that we may share your Personal Data with, basic information about their data processing activities and links to the relevant privacy policies (which you may refer to for more details about how they process your Personal Data, their contact information, and procedures to exercise data subject rights with them).

Your additional rights

Besides the rights listed in the "Your Rights" section in the main body of the privacy notice, you also have the following rights:

1. Your right to deregister your account – You can request to deregister any account you may have with us. However, if you deregister your account, certain services or processes may be disrupted or become unavailable.
2. Your right to withdraw your consent – You can withdraw your consent to our processing of certain Personal Data about you when we rely on your consent for such processing. Please note that your withdrawal may lead to certain consequences (e.g. disruption or unavailability of certain services or processes) if such processing is strictly necessary for a certain purpose and consent is the only legal basis for our processing.

Inquiries or complaints

If you have any requests to exercise rights, inquiries or concerns about the Personal Data we use about you, please contact us at china@icaew.com. You also have the right to make a complaint at any time to the Cybersecurity Administration of China (CAC) or its local counterparts.

This Appendix applies to individuals who reside in the Republic of Singapore. It supplements and should be read together with the main section of this privacy notice. In the event of any conflict or inconsistency between this Appendix and the main body of this privacy notice, this Appendix shall prevail.

Consent

We will collect, use or disclose your Personal Data for purposes which you have provided your consent which can be express, deemed or by notification, unless exempted, in accordance with Singapore’s Personal Data Protection Act (2012) and its regulations (PDPA). Where we have collected, used or disclosed your personal data based on consent, you may withdraw consent with reasonable notice, and we will inform you of the likely consequences of the withdrawal.

Purpose limitation & notification

We will only collect, use or disclose Personal Data for the purposes that a reasonable person would consider appropriate under the given circumstances and for which you have given consent (unless exempted by law).

Accuracy, access & correction

We will make reasonable effort to ensure that your Personal Data collected is accurate and complete. You have right to access Personal Data which we hold about you, request a copy of that information and details of what we have done with that information (i.e., how long we kept it for and to whom we disclosed it) within a year before your request.

You have a right to request us to correct your Personal Data where it is inaccurate or out of date. We will make the necessary corrections as soon as practicable and send the corrected data to other organisations to which your Personal Data was disclosed pursuant to this privacy notice within a year before the correction was made.

Retention limitation

We will cease retention of your Personal Data or dispose of it in a proper manner if it is no longer necessary for the purpose for which it was collected and we have no other legal ground for processing the data, or if the collection, use or disclosure of your Personal Data was based on consent and the consent has been withdrawn.

Transfer limitation

For international transfers (i.e., a cross-border disclosure) of your Personal Data from Singapore to overseas, we will put in place contractual measures to ensure the overseas recipients process your personal data in accordance with our instructions and have in place technical and organizational measures to protect your personal data with a level of protection comparable to the protection under the PDPA.

Data breach notification

We will notify you of any data breach that is or is likely to be of significant scale, or results in or is likely to result in significant harm to you.

Data portability

Where required by law, at your request, we will transmit your Personal Data that is in our possession or under our control, to another organisation in a commonly used, machine readable format.

Marketing communication

We may send you marketing messages (e.g., voice calls, text or fax messages) to your Singapore telephone number, if we have an ongoing relationship with you or your Singapore telephone number is not listed in the Do Not Call Registry or we have obtained your clear and unambiguous written consent. You may at any time opt out of such messages by using the same medium by which the message is sent. Exceptions to the foregoing include our communications regarding services purchased by you, market survey or research and B2B messages.

Inquiries or complaints

If you have any requests to exercise rights, inquiries or concerns about the Personal Data we use about you, please contact our Data Protection Officer at dataprotection@icaew.com. If we are unable to help you, you may contact Singapore’s Personal Data Protection Commission (http://www.pdpc.gov.sg).