The Institute of Commercial Management WEBSITE PRIVACY POLICY
1.0 OUR BELIEFS WHEN IT COMES TO USER PRIVACY AND DATA PROTECTION
· User privacy and data protection are human rights
· We have a duty of care to the people within our data
· Data is a liability, it should only be collected and processed when absolutely necessary
· We can’t stand spam
· We may forward your information to relevant third parties who can help with furthering your education.
2.0 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:
· UK Data Protection Act 1988 (DPA)
· EU Data Protection Directive 1995 (DPD)
· EU General Data Protection Regulation 2018 (GDPR)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residence's specific data protection and user privacy legislation, you should contact our Data Protection Officer (details of whom can be found in section 9.0) for clarification.
3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Google Analytics makes use of cookies, details of which can be found on Google’s Developer Guides.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is supplied to us from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.
* The Whoisvisiting system will only look up information when a static IP address is being used. Differences between a static and dynamic IP address. More information about how Whoisvisiting uses IP addresses.
List of cookies on this website:
3.2 Website forms
Should you choose to submit a form on our website, such as a Contact Us form, the data you’ve submitted, including your name, telephone number and email address where applicable, will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). In addition, a record of your submission will be stored on our website’s database, which is only accessible by authorised members of the ICM team and is maintained by our third party data processor, Webflow. For more information about Webflow, please visit their privacy policy here.
3.3 Email links
In various areas of this website there is the option to click to email or click to call. In both of these cases, upon clicking a link, our website will not record or store any of the information you subsequently submit. These links will prompt your device to launch either the default call or email app in use.
Emails sent and received by us use Simple Mail Transfer Protocol (SMTP), this service is provided to us by one of our third party data processors, Microsoft, on their Office 365 platform. For more information about Microsoft as a data processor, see section 6.0.
Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
4.0 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.2, if you submit a form on the website, some personal information may be stored within ICM’s database but only if relevant. This is the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (Webflow). However, whilst identifiable, the information is only accessible to those with the necessary system privileges.
Our future aim is to have our database fully encrypted to further secure the information.
5.0 ABOUT THIS WEBSITE’S SERVER
This website is hosted by Webflow, one of our third party data processors. They, in turn, use both Amazon Cloudfront and the Fastly Content Delivery Network to distribute copies of the website around the world. The reason for the distributed nature is to ensure speed and reliability of the website globally.
Some of Webflow’s & Amazon’s security benefits are:
· SSL Certificate for encryption between the visitor and the website
· Security guarded data Centres
· Security fencing and feeds
· Intrusion detection technology
· Backup power systems
· Video surveillance systems
· Enterprise-grade website security
Full details of Webflow’s hosting can be found here.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0.
- Webflow (Privacy policy) EU-US Privacy Shield Application Compliant
- Google (Privacy policy) EU-US Privacy Shield Compliant
- Amazon Web Services (Privacy Policy) EU-US Privacy Shield Compliant
7.0 DATA BREACHES
We will report any unlawful data breach of this website’s database, or the database(s) of any of our third party data processors, to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 DATA CONTROLLER
The data controller of this website is: The Institute of Commercial Management.
Whose registered office is:
ICM House,
Yeoman Road,
Ringwood,
Hampshire,
UK,
BH24 3FA
9.0 DATA MANAGER
Mrs Lynsey Campbell
Telephone: +441202 490555
Email: info@icm.education
10.0 CHANGES TO OUR PRIVACY POLICY
This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the Change Log below.
10.1 CHANGE LOG
· 23/05/2018 - Privacy policy instigated