1. We are committed to safeguarding the privacy of ICoCA Members, subscribers, website visitors, and service users. As a general principle we will not distribute your personal information to outside parties without your consent. This privacy statement explains how we collect, share and use personal information, and how you can exercise your privacy rights.
2. The following section sets out the general categories of personal data that we may process and the purposes for which we may process this data.
2.1. We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services for regular improvement of our website and services.
2.2. We may process your account data (“account data“). The account data may include your name, email address and affiliation you have provided when signing up through our registration form. The account data may be processed for the purposes of communicating with you, registering you in our secure and confidential Membership Database and to send you the account details to receive access to the ICoCA Membership Application Form.
2.3. We may process information relating to your Membership with the ICoCA (“Member data“). The Member data may include your name, your affiliation, your job title or role, your contact details, address, Membership details, and information contained in communications between us and you or your employer. The Member data may be processed for the purposes of maintaining a database of Members, communicating to you about your Membership, its maintenance and governance of the ICoCA.
2.4. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“subscription data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive newsletters, other communication and limit the publication of your information. You can access the privacy controls via the link at the bottom of newsletter emails.
2.5. We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication.
2.6. We may process event registration data (“event registration data”). This data may include your name, email address, address, phone number, birth date, employer, job title or role, country based in, language and event preferences. This data may be processed for the purposes of providing you with relevant event information and services, sending you communications about events you have registered for and keeping records of those registrations. We may disclose event registration data to our suppliers or subcontractors insofar as reasonably necessary for the proper organisation and management of events.
2.7. We may process any of your personal data identified in this statement where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. The following section summarises the rights that you have under data protection law in the European Union. Some of the rights are complex, and not all of the details have been included in these summaries. Your specific rights will differ depending on your country of residence and/or citizenship. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
3.1. Right to access. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
3.2. Right to correct or update. You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you updated.
3.3. The right to request deletion. In some circumstances you have the right to request deletion of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to processing your data; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to request deletion. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
3.4. The right to restrict processing. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose deletion; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
3.5. The right to object processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
3.6. The right to complain to a supervisory authority. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
3.7. The right to withdraw consent. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
3.8. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section.
4. The following section sets out our data retention policy and procedure.
4.1. We will hold your personal information on our systems for as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with ICoCA.
4.2. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. We may update this statement from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes by email.
6. If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send us a message at firstname.lastname@example.org. You may also contact us by postal mail at:
International Code of Conduct for Private Security Service Providers’ Association, 7bis, avenue de la Paix, CH-1202 Geneva, Switzerland