SWM is committed to protecting privacy and takes its responsibility regarding the security of personal information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with SWM through your use of our website registration, bank information and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with UK and EU data protection laws (European Union General Data Protection Regulation (GDPR) (EU) 2016/679).
“SWM” (referred to as “we”, “us”, “our” or “SWM” in this policy) in this policy primarily refers to SWM Partners Ltd, 5 Prince Edward Street, Berkhamsted, HP3 4EZ, registered number 03668470 and is the “data controller” of all personal information that is collected and used.
What personal data we collect and where we obtain the data from
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, bank details and information about your access to our website.
We may collect personal data from you when you register to attend a conference/meeting in order to enable SWM to book flights; assist with visa applications; arrange accommodation, ground transportation and hotel meals; log special dietary requirements, provide meeting materials and facilitate reimbursement of your expenses.
We may also obtain your personal data from the organisation on whose behalf we are organising a conference or meeting, or as part of our normal course of business if you are, or work for, a supplier or customer of SWM.
Specifically, we may collect the following categories of information:
a. Name, home address, work title, work address, e-mail address, telephone number and bank details
b. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media
c. Location, including the IP address of your device
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
a. Providing services: We use the information you give us to perform services in relation to your conference/meeting attendance, hotel booking, flight, including requested flight changes;
b. Contacting you in the event of a flight time change or cancellation or meeting schedule/dates: We send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
c. Paying expenses: We use your bank details in order to pay your expenses;
d. Marketing: In relation to mailings to Customers and Vendors in the form of newsletters, calendars;
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected your data and the purpose for which we are processing your personal data.
In most cases, we will need to process your personal data so we can fulfil our contractual obligation as the organiser of the conference/meeting you are attending.
We may also process your personal data for one or more of the following:
- To comply with a legal obligation (e.g. Immigration or customs requirements);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
- In our legitimate interests to operate our business (e.g. for administrative purposes).
We will not retain your data for longer than is necessary to fulfil the purpose for which it is being processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g. accounting records) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made against us.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the 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 particular 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.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you. This point is not relevant to SWM as we do not use your data for these 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 or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- 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. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please contact us by email: firstname.lastname@example.org or by writing to SWM Partners Ltd, 5 Prince Edward Street, Berkhamsted. 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 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.
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.
We may also need to request further information from you, such as the dates of any events you attended in order that we can ensure we provide all the information you request.
22 May 2018 Version 1