We at the Human Givens Institute appreciate that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits this website, www.hgi.org.uk ("Our Site") and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of Our Site;
"Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 9, below;
"Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
"Personal data" means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or when booking a course with us over the phone. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation ("GDPR"); and
"We/Us/Our" means the Human Givens Institute (HGI).
2. About Us
2.1 www.hgi.org.uk is a website operated and owned by The Human Givens Institute, a limited company registered in England under company number 4331916. Our registered office is: Preston Park House, South Road, Brighton, East Sussex UK BN1 6SB. Our office address is The Human Givens Institute, Church Farm Lane, Chalvington, East Sussex, BN27 3TD, UK. We are registered as a data controller on the Data Protection Register as required by the Data Protection Act 1998, registered number Z3386838.
2.2 We can be contacted by email at email@example.com, by telephone on +44 (0)1323 811662 (Mon–Fri, 9.00am–5.30pm, GMT) or by post at the above office address.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 5);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 11);
4.1.4 The right to be forgotten - i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 12 – please note: if you are a Graduate or Registered Member of the HGI, certain restrictions apply, see 5.17 below);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 11 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office, see: https://ico.org.uk Tel: 0303 123 1113.
4.3 For further information about your rights, please contact the Information Commissioner's Office or your local Citizens Advice Bureau.
5. What data do we collect?
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 how you heard about us
5.8 IP address;
5.9 web browser type and version;
5.10 operating system;
5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How do we get your consent?
5.12 When you provide us with personal information to complete a transaction online, via post or over the phone, or verify your credit or debit card to join as a Member, you consent to our collecting it and using it for that specific reason only. This is processed as part of the ‘contractual’ lawful basis. If you have filled out a form and agreed to receive emarketing from us, this is also processed as part of the ‘consensual’ lawful basis. You may also receive emails containing information pertinent to your membership, such as information you need to be aware of and subscription renewal reminders. This is classified under the ‘Legitimate Interests’ lawful basis.
5.14 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
Access to your data
5.15 You can check the information that we hold about you at any time by emailing us at firstname.lastname@example.org or calling our office on +44 (0)1323 811662 – we are open from 9am to 5.30pm Monday to Friday (GMT). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. If you find any inaccuracies, we will delete (if you are not a Graduate or Registered Member of the HGI) or correct them promptly, usually the next working day.
How to withdraw your consent
5.16 You may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at email@example.com or writing to us at: Human Givens College, Church Farm, Church Farm Lane, Chalvington, Hailsham, BN27 3TD, UK. However, if you are a Member of the Institute, withdrawing consent will affect our ability to fulfil your membership for you, which would then cease from that time.
5.17 However, if you are a Graduate or Registered Member of the HGI as we are legally required to keep your details on file and on the Online Professional Register for a certain period of time after you have ceased practising or being a member, in order to protect the public. There are addititional restrictions on removing your data if a complaint is upheld against you.
5.18 To opt out of emarketing, you can unsubscribe at any time by clicking ‘Manage my subscriptions’ at the bottom of any of our emails to you or by emailing us at firstname.lastname@example.org
6. How we use your data
6.1 All personal data is processed and stored securely (for more details on security see section 7), for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails or becoming a Registered Member of the HGI and entered onto our online register of HG therapists), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you and be able to fulfill our services to you), including processing your membership payment, entering your details on the Professional Register of Human Givens Practitioners (if appropriate) and sending confirmation and other related information to you
6.2.2 Providing and managing your Account
6.2.3 Providing and managing your access to Our Site
6.2.4 Personalising and tailoring your experience on Our Site
6.2.5 Keeping a record of your insurance, CPD and other related documents necessary for the fulfilment of HGI Membership requirements
6.2.6 Replying to emails from you
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the ‘Manage Your Preferences’ link included in marketing emails or by contacting is directly)
6.2.8 Market research
6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.3 With your prior permission and/or where permitted by law, We may use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. We aim to comply with your request within the next working day. If you are a Registered HGI Member, however, due to the PSA’s requirements and our own ethical standards we are obliged to keep your details on our Professional Register for 2 years after you have ceased to be a Member of the HGI, or retired from private practice.
7. How and where we store your data
7.1 We only keep your personal data for as long as We need to in order to use it as described above in sections 5 and 6, and/or for as long as We have your permission to keep it.
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.3 Steps We take to secure and protect your data include:
7.3.1 Computers that hold your personal data are password protected
7.3.2 Data is stored on our secure internal database and a protected Customer Relationship Management (CRM) and email marketing system. Due to the latter requirement, some or all of your data may be stored outside the European Economic Area ("the EEA") (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8. Do we share your data?
8.1 We take your privacy very seriously and do not disclose your personal information to any unconnected third parties.
8.2 In certain circumstances, however, We may be legally required to share certain data held by Us, which may include your personal data; for example, where We are complying with legal requirements, a court order, or a governmental authority, where We are involved in legal proceedings or if you violate our Terms of Service, Ethics Policy or Membership Requirements. Any such disclosure of personal information will be strictly controlled and made fully in accordance with the current UK legislation, in particular the UK Data Protection Act 1998 and the new General Data Protection Act (which comes into effect on 25th May 2018).
8.3 We may sometimes contract with third-parties to enable us to supply our services to you. These may include payment processing, liaising with our sister organisations (Human Givens College, HG Publishing and The Human Givens Foundation), or an online platform, which provides a specific related service, such as CRM or emailing platforms. The third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us or for you.
8.3.1 In some cases, the third-parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3.2 Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. The HGI banks with Lloyds Bank.
8.3.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such anonymous data with third parties such as prospective affiliates or partners. Data will only be shared and used within the bounds of the law.
9. Our use of 'Cookies
9.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
9.4 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
10. Age of consent
By using this website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence, and you have given us your consent to allow any of your minor dependents to use this site.
11. How to contact us
You can also call us on +44 (0)1323 811662 if you have any questions at all – we are open from 9am to 5.30pm Monday to Friday (GMT).
We recommend that you check this page regularly to keep up-to-date.
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Volume 25, No 1, 2018, the latest edition of the Human Givens Journal is now available.
Date posted: 11/06/2018