The Sustainable Markets Initiative (“SMI”) operates globally to create sustainable markets and put nature, planet and people at the heart of global value creation. In this policy wherever you see the words ‘we’, ‘us’ or ‘our’, it refers to the SMI.
2. What is Personal Data?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as 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 address, email address and telephone numbers.
Organisational Data includes details of an organisation that you represent and/or your role within in.
Financial Data includes bank account and payment card details.
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 this website.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your Personal Data collected?
The SMI uses different methods to collect data from and about you including through direct interactions, automated technologies or interactions, and third parties or publicly available sources.
3.1 Direct Interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us feedback or contact us; or
give us information about you in your capacity as representative of an organisation.
3.2 Automated Technologies or Interactions
3.3 Third Parties or Publicly Available Sources
We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
advertising networks; and
search information providers
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources.
Contact and Organisational Data from colleagues working within your organisation.
4. How we use your Personal Data
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:
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.
Where we need to comply with a legal obligation.
In order to be able to operate efficiently, effectively and economically, it is in the legitimate interests of the SMI to hold such personal data on its members, partners and volunteers as will enable the SMI to communicate with its partners, volunteers on matters relating to the operation of the SMI, e.g.:
the holding of meetings;
providing information about the SMI’s activities – particularly those activities which, by their nature, are likely to be of particular interest to individual members, partners and/or volunteers;
seeking help, support and advice from members, partners and/or volunteers, particularly where they have specific knowledge and experience;
ensuring that any particular needs of the members, partners and/or volunteers are appropriately and sensitively accommodated when organising meetings and other activities of the SMI;
managing our relationships with an organisation that you represent.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
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 override 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:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.
Please note that none of these rights are absolute and we reserve the right to refuse your request where exceptions apply. If you would like to contact us in regard to above rights please email email@example.com
6. Data Retention
Whatever your relationship with us, we will only store your personal information for as long as necessary to fulfil the purposes we collected it for, including 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, regulatory, tax, accounting or other requirements.
Once the legitimate need for retention has expired, personal information will be confidentially disposed of or permanently deleted.
If you object to further contact from us, we will keep some basic information about you on a “suppression list” in order to avoid sending you unwanted communications in the future.
7. Who else can access your Personal Data
We are committed to protecting your data and therefore it will never be sold to external organisations and will only be disclosed to those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between the SMI and that organisation to protect the security of your data. These Parties may include:
Suppliers who send out communications on our behalf, such as invitations to our events;
Members who participate in SMI events and activities;
Partners who lead and sponsor SMI events and activities;
Other charities of HRH The Prince of Wales* or Operational Committees where we share information for internal procedures and policies only.
Should we merge with another organisation to form a new entity, your data may be transferred to the new entity.
*For more information please visit this website
8. How we secure your data
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. Safe protocols are used for communication and transferring Personal Data where required (such as password protection and encryption).
Where we use external companies to collect or process data on our behalf, we ensure that they have the appropriate security in place to keep your data safe and expectations are clearly documented. We may need to transfer your personal data outside of the European Economic Area (EEA) to allow them to perform services on our behalf. In doing so your data may be stored or processed outside of the EEA. Where this happens, we will endeavour to ensure that your data is being processed in accordance with the appropriate security requirements in line with our legal responsibilities, and by submitting your details in such circumstances you agree to this transfer.
Despite all of our precautions no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we will always strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention that you do so at your own risk.
9. Cookies and other technologies we use
10. Contact us
If you have any queries about this policy or any complaints with regard to the administration of the policy please contact us at firstname.lastname@example.org