This Privacy Notice tells you what to expect when we, IOSH (Institution of Occupational Safety and Health), collect personal data (as defined below) about you. It applies to the information we collect about:
- visitors to our websites;
- other people who use our services, e.g. Members, Training Providers, attendees at IOSH Events, Research & Funding applicants, and those who subscribe to our newsletters and other social media outlets.
It is important that you read this Privacy Notice together with any other fair processing notice that we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal data. This Privacy Notice supplements any other such notices and is not intended to override them.
For the purposes of the relevant data protection legislation, the data “controller” is the Institution of Occupational Safety and Health of The Grange, Highfield Drive, Wigston, Leicestershire, LE18 1NN.
Why we collect information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To allow you to register as a Member with us or to provide you with the services you have requested, such as IOSH events or the provision of Research & Funding;
- To administer Membership records which may include publication of disciplinary decisions in accordance with relevant Byelaws and Regulations that are part of the Membership Terms and Conditions;
- Where we need to comply with a legal or regulatory obligation; or
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
“Legitimate Interest” means our interest in conducting and managing our business to enable us to give you the best service and the most secure experience. We ensure that we consider and balance any potential impact on you and your rights 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).
Types of personal data we collect
“Personal data” means any information which identifies (or from which we can identify) a natural person. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- “Special Category Data”, which comprises your personal data revealing racial or ethnic origin, Religious or philosophical beliefs, Data concerning health, Data concerning a natural person’s sex life or sexual orientation.
- The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and religious beliefs. In certain situations, IOSH may collect and/or use these special categories of data (for example, information on learners’ medical conditions so that we can decide for access arrangements, reasonable adjustments and/or special considerations). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
- “Identity Data”, which comprises your first name, maiden name, last name, title, date of birth and gender.
- “Contact Data”, which comprises your email address, address and telephone number.
- “Financial Data”, which comprises the payment details you have provided to us.
- “Transaction Data”, which comprises details about payments to and from you and other details of services you have purchased from us.
- “Technical Data”, which comprises your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device(s) you use to access our website.
- “Profile Data”, which comprises your username and password, your interests, preferences, feedback and survey responses.
- “Usage Data”, which comprises information about how you use our website or services.
- “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third parties, and your communication preferences.
- We do not collect any “Special Categories” of personal data about children. We also do not use any automated decision-making processes.
When do we collect information
We may collect information on you in the following ways:
- Information that you voluntarily provide to us
When you sign up for a Membership, consult with our customer service team, send us an email, request information about our services, fill in forms on our website, or communicate with us in any way, you are voluntarily giving us information that we collect. We also collect information you give to us when we contact you during the registration process or in the process or managing your account or your organisations account. That information may include your Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data.
If you are becoming a Trustee of IOSH or are a serving trustee you will be obliged to disclose any criminal conviction imposed by a court, or any previous unspent convictions. Our lawful processing purpose is compliance with a legal obligation; to ensure that statutory automatic disqualification rules do not apply. In addition, and for the same lawful purpose we may also process criminal conviction information received from a third party We will treat this data in accordance with the principles of the general data protection regulation and it will not be retained following a decision on your application.
To meet our public interest objectives set out in the Royal Charter we may need to collect certain information regarding criminal convictions imposed by a court, or any previous unspent convictions where you are applying for admission, including re-admission to IOSH. To meet the same objective, we may ask you for this information at any time during your period of membership to assess your compliance with the code of conduct for IOSH membership, which forms part of your Membership terms and conditions. In addition, and for the same purpose we may also process criminal conviction information received from a third party.
Our lawful basis for this processing is that it is necessary for our legitimate activities as a not-for-profit body with a philosophical aim. Any such data will not be disclosed outside of IOSH without your consent and will be processed in accordance with the law. You may be asked whether you have any unspent criminal convictions as part of your application to become a member. We will hold any information you give us relating to unspent criminal convictions until your application is determined.
- Information that we collect automatically
How we use your information
We have set out below a description of all the ways in which we intend to use any personal data, and the legal bases on which we intend to rely on to do so. We have also identified what our Legitimate Interests are where appropriate. You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in relation to specific activities by contacting us. We may use and disclose your personal information for the following purposes:
a) To manage our relationship with you or your organisation
In providing you with the services you have requested from us (including when you join IOSH as a Member), we will use your Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data to provide you with those services, including to process any payments received from you. We will also use this information to manage your Membership account, to keep adequate records of any past purchases, to deal with any enquiries or requests, as well as to contact you regarding the services you have asked for. We may send you important updates about any changes to the way in which our services work. Where you have purchased services from us, we may also ask you to complete a review or survey about your recent purchase or send you further information about similar services we think would be of interest to you. This is necessary to develop our range of products and services and grow our business.
If we have obtained your express opt-in consent, we may send you, or permit selected third parties to send you, specific forms of marketing, for example regarding other services. We shall make sure it is clear when you are able to give us permission to do this, for example, we have an online form and boxes that you need to tick if you wish to receive any such marketing materials. All our marketing emails have an active opt in or out option on them. To view or amend these you can contact our Customer Services Centre who will be able to help. You have the right to withdraw your consent to receiving direct marketing at any time by contacting us. IOSH is committed to ensuring the easiest way for individuals to change their marketing preferences and development is underway for a new online service for you to amend these and all your personal information.
d) IOSH Events
The personal information collected about you by us when you book on to an IOSH event will only be used by IOSH or an IOSH approved third party supplier (i.e. delegate registration company) to contact you about the IOSH event that you have confirmed attendance to, unless you have opted in to receiving other types of communications during the booking process.
e) To administer and protect our business and this website
iosh.co.uk, its sub-domains and microsites belong to IOSH. We may also use your information to protect our business and our website, and to help us monitor or improve the services that we offer. This includes troubleshooting, statistical and data analysis, testing, system maintenance, support, reporting and hosting of data. We also use your information to improve our website so that content is presented in the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure. This is necessary for the running of our business, provision of administration and IT services, network security and prevention of fraud. We may also need to use your information in the context of a business reorganisation or group restructuring exercise.
f) Other purposes
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another lawful reason and that reason is compatible with the original purpose. If you require an explanation of why we are using your personal data or the legal basis on which we are using it, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Lawful basis for processing
The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:
- Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for your consent to collect special categories of your personal information so that you may sit an examination or assessment with reasonable adjustments or access arrangements, or we may ask for your consent to send you our email newsletter).
- Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services, or to retain information about any misconduct / malpractice / maladministration as a condition of our business).
- Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, to provide you with a certified Membership, or to enrol you on a course which you have paid for).
- Where there is a legitimate interest in us doing so. The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual). In broad terms, our “legitimate interests” means the interests of the running of IOSH and ensuring that certifications are granted to learners in line with our policies, procedures and regulatory requirements. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When will we share your personal data?
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. We shall not share your personal data with any third parties for marketing purposes without your express consent. We shall however, share your personal data with third parties, for the following reasons:
a) Service Providers
We will share your personal data with service providers where this is necessary to provide you with services that you (whether in your own name or on behalf of your organisation) have ordered. Examples of Service Providers include payment processors, hosting services, suppliers, sub-contractors and delivery services. We may also need to share your personal data with third party software or IT support providers for system administration, data security, data storage, back up, disaster recovery and IT support. We share your information with the following parties, for the following purposes:
- Newsletter/Magazine/Marketing emails
– We use a third-party mailing house, Synergy Printers, to fulfil and post hard copy magazines to our members worldwide. For more information, please see the Synergy privacy statement: synergy-print.co.uk/privacy-policy/
– We use a third-party provider, Smart Focus, to deliver our marketing emails. These emails are only sent to individuals who have consented to do so. For more information please see the Smart Focus privacy statement: www.smartfocus.com/en/privacy-and-cookies-policy.
- Security and performance
– IOSH uses SiteCore to help maintain the security and performance of the IOSH website. To deliver this service it processes the IP addresses of visitors to the IOSH website.
– IOSH moderators and IOSH staff can see your internet protocol (IP) address when you post a message on our forums. This information is for use by IOSH only and is only used to prevent misuse of the discussion forums. We will not disclose your IP address to anyone, unless we are legally permitted or required to do so.
- Online Payments
– We use WorldPay to collect online payments on our main website. WorldPay is a secure on-line payments gateway.
– We use YAF to manage and facilitate our forums. This software requires members that want to post a comment to enter a name and email address. This information is stored by YAF for administrative purposes only.
- People who contact us via social media
– We use a third-party provider, Orlo to manage our social media interactions.
b) Advertising partners
We use third-party services, Google Analytics and SiteImprove, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be transparent about this. We will always make it clear when we collect personal information and will explain what we intend to do with it.
c) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition
We may share your personal data with 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 Notice.
d) To protect the rights, property, or safety of our business and other customers
We reserve the right to disclose or share your personal data to comply with any legal or regulatory requirements, enforce our terms and conditions (or any other agreement we enter into with you), or to protect the rights, property, or safety of our business and other customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may also need to share information with HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom, who require reporting of processing activities in certain circumstances. We may also share your personal data with our professional advisers including lawyers, bankers, auditors, accountants and insurers based who provide legal, financial and banking, audit, insurance, accounting and consultancy services.
The enquiry results are forwarded to the IOSH Information and Intelligence team from Alcumus monthly for quality assurance purposes. Once the analysis is completed (within one month), all the enquiry results, including the personal information, is deleted. Whilst the enquiries are being reviewed, the document is stored within a restricted access folder by IOSH.
Membership and Customer Support Helplines
When you call IOSH helplines we collect and retain only the information that is relevant to the extent required to answer the enquiry. We use this information to either update members records, pay an invoice or answer their question. IOSH use a third party, Taylor Bennett Partners LLP, for conference registration and bookings. They will only use your information to contact you about the event you have signed up to and to fulfil your booking. We will only share your personal information with selected third parties for postal or telephone marketing if you have consented to receiving such marketing about specific types of events.
Research Fund Application
All personal information you provide to IOSH will be securely maintained, stored and treated as private and confidential. Information collected may be used by the research department or committee, its peer reviewers and internal committees/commissioning panels to: administer the grant application process; to identify peer reviewers for grant applications; and to notify users about funding opportunities. IOSH may pass on relevant data to internal committees and independent reviewers to perform tasks on its behalf to help make the funding process operate effectively. IOSH may also divulge information to its internal committees in order to make funding decisions and improvements. In consultation with you, and if you have given us your permission to in advance, IOSH may also wish to use some of the information you provide in your application to promote the Research Fund and research activities sponsored by IOSH. This could include articles on the research pages of the IOSH website, news stories and joint press releases, interviews, case studies, articles in IOSH Magazine, or negotiated pieces in other media outlets. Third Party Websites 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 notice of every website that you visit. Our website search and decision notice search are powered by SiteCore. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either IOSH or any third party. International Transfers. Some of our external third parties may be based outside the European Economic Area (“EEA”) from time to time, so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain Service Providers, we may use specific contracts approved by the European Commission which give personal data the same protection that it receives in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield Network, which requires the provision of a level of protection acceptable to the European Commission of personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Where will we store your personal data?
We are committed to the security of your information and have security procedures in place to protect the loss, misuse or alteration of information under our control. In addition, we also have security measures in place to protect the user database and access to this database which is restricted internally. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a username and/or password which enables you to access certain parts of our site, you are responsible for keeping this username and/or password confidential. We ask you not to share a password with anyone. We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit. Please note that the transmission of information via the internet is not completely secure. Although we shall do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.
How long will we keep hold of your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. We may also retain your personal data for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. In some circumstances you can ask us to delete your data: see the “Right to be Forgotten” section below for further information.
Under certain circumstances, you have the following rights:
- to request that we provide you with a copy of the personal data that we hold about you (“Access Request”);
- to request that we rectify any personal data that we hold about you (“Right to Rectification”);
- to request that we erase any personal data that we hold about you (“Right to be Forgotten”);
- to restrict the level of processing we carry out with your personal data (“Restriction of Processing”);
- to obtain from us all personal data that we hold about you in a structured, machine readable form, and have this information transmitted to another organisation (“Data Portability”);
- to object to our processing your personal data in certain ways (“Right to Object”); and
- to withdraw your consent at any time to our processing of your personal data.
Please see the relevant sections below for further details on your rights as a data subject. You can exercise any of the above rights by emailing us at [email protected]. You also have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy in any way with how we have treated your personal information. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.We shall comply with any request made under this section as soon as possible, and normally within one month from the date of your request. However, if necessary, for example if your request is particularly complex or we receive a number of similar requests, we may extend this period by an additional two months, but we shall notify you if we need to do this. You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, please note that where we receive requests under this section which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may:
- charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or
- refuse to act on the request.
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.
You can access the Data Protection Policy here.
You have the right to request a copy of the information that we hold about you at any time. This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it. Please note that in most circumstances, we shall not make a charge for this. However, we may charge a reasonable fee based on administrative costs for any further copies requested.
Right to rectification
You have the right at any time to ask us to rectify any personal data that we hold for you which is incorrect or incomplete. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data that you provide to us. If we have disclosed any incorrect or incomplete data to any third parties, we shall inform them of any necessary amendments or corrections made to your personal data under this section.
Right to be forgotten
You have the right to ask us to erase the personal data that we hold about you in circumstances where:
- it is no longer necessary for us to handle your personal data for the purpose for which it was originally collected;
- you have withdrawn your permission for us to hold your personal data (where this was the basis on which it was collected or used);
- you object to the processing of the data and there is no lawful overriding reason for us to continue processing your personal data;
- the personal data was unlawfully processed; or
- we must erase your personal data in order to comply with a legal obligation.
Please 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.
Restriction of processing
You can ask us to restrict how we use your data in the following circumstances:
- where you believe that the information, we hold about you is inaccurate, you can ask that we refrain from using your data until we can verify the accuracy of it;
- where we have unlawfully processed your data, you can ask that we restrict our usage of it rather than erase it completely;
- where we no longer need to hold your information, but you wish us to retain your information for establishing, exercising or defending a legal claim; or
- where you have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.
You have the right to obtain from us all personal data which you have provided to us in a structured, commonly used and machine readable form, provided that such data was processed based on your consent, or for the purpose of a contract between us and the processing was carried out by automated means. Please 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. This will allow you to move, copy or transfer personal data easily from one IT environment to another. Alternatively, we can transmit such data directly to another organisation. Please note that we shall not be able to comply with a data portability request if this will affect the rights and freedoms of others.
Right to object
You have the right to object to our processing of your personal data where we are doing this for the performance of a task carried out in the public interest (which we shall have told you about, if applicable), or where we are carrying out processing for the purposes of legitimate interests pursued by us. You also have the right at any time to ask us not to process your personal data for direct marketing or profiling purposes (to the extent that such profiling is related to such direct marketing). We shall have informed you before the time we obtained your personal data whether we intend to process your personal data for this purpose, or if we intend to disclose your information to any third party for such purposes.
Right to withdraw consent
Where you have given us your consent to our processing of any of your personal data, you have the right to withdraw your consent at any time, for example if you no longer wish us to share your information with third parties for marketing purposes (where you have previously consented to this). 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you are not happy with the way your information is being handled, or with the response received from us, you can seek resource through our internal complaints procedure by writing to us at:
Data Protection Officer
Institute of Occupational Safety and Health
If you have any questions about our Privacy Notice or wish to exercise any of your legal rights, you can email [email protected] or write to Data Protection at the address above.
Changes to this Privacy Notice
We keep our Privacy Notice under regular review. This Privacy Notice was last updated in August 2020.