1. Introduction

Welcome to the BSBMTCT privacy notice. This notice includes information on how BSBMTCT collects and processes your Personal Data, and the various ways we may interact with you, including via this website.

BSBMTCT is an organisation for those with a professional interest in haematopoietic cell transplantation and cellular therapies.

BSBMTCT takes your privacy seriously. This notice tells you how we look after your Personal Data when you interact with us and gives you information as to your privacy.

Please read this privacy notice together with any other privacy notices we may provide as part of your interactions with us, therefore, this privacy notice supplements any other notices, and is not intended to override them.

2. Data Controller

If you have any questions about this privacy notice, including any requests to exercise Your Privacy Rights please contact us at:

BSBMTCT
Email address: julia.lee@kcl.ac.uk

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us at julia.lee@kcl.ac.uk in the first instance.

3. Changes to this Privacy Notice

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

4. The data we may collect about you

Personal Data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).

Depending on how you interact with us we may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (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 devices you use to access our websites.
• Marketing and Communications Data includes your preferences in receiving marketing and or newsletters from us and any communication preferences collected.
• Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity.  

5. How is your personal data collected?

We use different methods to collect data from and about you, including via:

Direct interactions

You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes Personal Data you provide when you do any of the following:

• approach and/or contract with us to perform services
• give us feedback
• contact us online in a networking or social media forum
• make an enquiry to our website
• you send us your CV or biography
• you contact us to request our services

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources

We may receive Personal Data about you from various third parties and public sources as set out below:

• (a) analytics providers;
• (c) search information providers such as Google, Chrome
• (d) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, if applicable.

6. How we use your personal data

Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform a contract we are about to enter into, or have entered into with you.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where it is in the public interest to do so.
• With your explicit consent (which you may withdraw at any time).

We have set out below a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact julia.lee@kcl.ac.uk if you need details about the specific legal ground we are relying on to process your Personal Data, where more than one ground has been set out in the details below.

Clients and potential Clients

PURPOSE/ACTIVITY

To manage our relationship with you which will include:

• (a) Communicate with you regarding services we are delivering on your behalf
• (b) Notify you about changes to our terms or privacy policy
• (c) Ask you to give feedback on performance
• (d) Recommend goods or services that may be of interest to you
• (e) To understand your role in your organisation

TYPE OF DATA

• (a) Identity
• (b) Contact
• (c) Profile/Job title
• (d) Marketing and Communications

LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST

• (a) Performance of a contract with you
• (b) Necessary for our legitimate interests (to keep our records updated and gather feedback on performance)
• (c)  Necessary for our legitimate interests (to develop our products/services and grow our business)

HOW LONG WILL WE KEEP IT?

For the period of our contract with you plus up to 5 years unless specified differently in our contracts.

WHO DO WE SHARE IT WITH?

• Authorised subcontractors as set out in contract arrangements

Just browsing (website user)

PURPOSE/ACTIVITY

To ensure that you can navigate the website appropriately and have a positive user experience

TYPE OF DATA

Our website hosting provider may collect your IP address. This will provide them with information such as location (town) and your computer or mobile device. We do not have control over the data the provider collects.

We generate log files about browsing patterns. This is statistical data which does not identify you as an individual. It is useful for us for security reasons and so that we can see which pages are most popular and whether a particular event has increased traffic to our website.

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyse how visitors use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for its own purposes in accordance with its own privacy policy. You may refuse the use of Google Analytics cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this website. Google has an Opt-out Browser Add-on to provide website visitors the ability to prevent their data from being used, please visit the following website for further information: Google Analytics Opt-out

LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST

Necessary for our legitimate business interests to promote services

HOW LONG WILL WE KEEP IT?

Due to the fact that we cannot identify users by their IP address and for the security and performance of our web services, we keep this data indefinitely.

7. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

8. Change of purpose

We will use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Disclosures of your personal data

We may have to share your Personal Data with the parties set out below as well as in the table in paragraph 6 above.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

10. Data security

We have put in place appropriate safeguards to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

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

11. Data retention – how long will you use my personal data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including 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. We are required by law to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being customers for legal reporting purposes.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. 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.

Object to processing of your Personal Data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. 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.

Withdraw consent at any time where we are relying on consent to process your Personal Data. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at EMAIL ADDRESS HERE.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

13. 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 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.

14. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to contact us:

BSBMTCT
julia.lee@kcl.ac.uk