Personal data, means any information about a living individual from which that person can be identified. It does not include data from which an individual cannot be identified (anonymous data). 

We only collect personal data relevant to the type of transactions or interactions that you have with CIPD. For example, we may collect, use, store and transfer personal data about you as follows:
 
•    Identity Data such as 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.
•    Financial Data includes bank account and payment card details.
•    Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
•    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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
•    Usage Data includes information about how you use our Website, products and services.
•    Marketing and Communications Data includes your preferences in receiving marketing from us and third parties (who you have consented to receive communications from) and your   communication preferences.
•    Assessment Data such as examination history, subject, grade, type of CIPD qualification and centre.
•    Student Data which may include Unique Candidate Identifier (UCI), centre number, admission number, year group, course leader’s name, class.

We also collect, use and share 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
 
We do collect some Special Categories of Personal Data about you (this includes details revealing race or ethnicity or information about your health) but we will only collect this if we have a lawful basis to do so under data protection law.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (such as when you join as a CIPD member) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with member services and benefits). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

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

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:
 
•    Join as a CIPD member and during your membership with us, such as volunteering, contributing to our policy campaigns and research activity (including membership surveys)
•    Apply for our products or services or register to attend one of our events;
•    Create an account on our Website;
•    Subscribe to our service or publications;
•    Request marketing to be sent to you;
•    Enter or complete a competition, promotion or survey;  
•    Carry out any transactions on our Website;  
•    Provide CVs or other information about yourself for specific purposes; or
•    Give us some feedback.

Automated technologies or interactions. As you interact with our Website or use a CIPD app, 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Cookies can be used to show you relevant CIPD content on social media services or other websites – these are known as ‘retargeting’ or ‘advertising’ cookies. For more information on the cookies we use and how you can control your cookie preferences see our cookie policy.

Third parties or publicly available sources. We may receive personal data about you from various third parties such as our business delivery partners, suppliers, sponsors, event organisers and public sources, as set out below:

•    Technical Data from the following parties: (a) analytics providers; (b) advertising networks; and (c) search information providers.
•    Identity Data and Contact Data from our centres if you are studying a CIPD qualification.
•    Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
•    Identity and Contact Data from data brokers or aggregators for direct marketing purposes.
•    Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU in order to verify your identity or confirm your details.
•    Identity and Contact Data to provide you with better targeted marketing, where you have made information about you and your interests available in the public domain including posting on one of our social media pages such as Facebook, Twitter or LinkedIn depending on your settings or the privacy polices of these social media and messaging services. To change your settings please refer to the privacy notices available on their respective websites.

CCTV. Our Wimbledon offices have CCTV in certain public areas, and you may be recorded when you visit them.  A recording is only viewed when necessary (for example to prevent, detect or investigate crime) and CCTV footage is stored temporarily in accordance with relevant regulatory guidance.

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 we need it to enter into a contract with you or to perform a contract we have with you.
•    Where it is necessary for our legitimate interests as set out in the Glossary at the end of this policy (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 or regulatory obligation.
•    Where you have provided your consent to us to use your personal data in a certain way or for one or more purposes such as direct marketing by email.   
•    Where we need to protect your vital interests or those of a third party (e.g. in a medical emergency)

Purposes for which we use your personal data

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 on more than one lawful ground depending on the specific purpose for which we are using your data.  
 
We may also process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law. 

Marketing

We may use your personal data to provide you with information about our services and/or products, which we consider may be of interest to you.  Where we do this via email or other electronic means, we will not do so without your prior consent except for when you have previously purchased goods or services from us, in which case, you may receive marketing from us in respect of similar goods or services unless you have told us that you do not wish to receive such direct marketing.  

You can update your preferences of how and what we communicate to you at any time through our marketing preference centre https://apps.cipd.co.uk/myprofile and checking or unchecking relevant boxes to adjust your marketing preferences.

Opting out of direct marketing

You can opt out of receiving further direct marketing communications from the CIPD by clicking the unsubscribe button at the bottom of a relevant email or other electronic marketing message. Alternatively you can call the customer services team on +44 (0)20 8612 6208, or notify us via our Contact Us form http://www.cipd.org/en/about/contact at any time. It may take up to 21 days for the changes to come into effect.   

Third party marketing

We will never sell your personal data to third parties for the purposes of marketing and will get your consent before we share your personal data with any company outside the CIPD Group for marketing purposes.

Cookies

As noted above in the Automated technologies or interactions section, we may collect and use your personal information by using cookies on our Website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see CIPD Cookie policy.

We do not sell your personal data to other organisations. We may have to share your personal data with the parties set out below for the purposes set out in this privacy policy.

• Internal Third Parties as set out in the Glossary
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (where the data we hold may be part of those assets).

Alternatively, we may seek to acquire other  businesses or merge with them. If a change happens to our business, then we will take all reasonable steps to ensure that the new owners use your personal data in a lawful manner that reflects this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions and, where applicable law requires, under a written contract where the relevant service provider gives sufficient guarantees to implement appropriate technical and organisational measures to protect personal data.

We share your personal data within the CIPD Group. In general, the personal data that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). 

However sometimes your personal data may also be transferred either to another CIPD entity or service provider in a third country outside the UK or EEA. For more information on personal data and International Transfers, see section 8 below.

We take all reasonable technical and organisational measures to keep your personal data as secure as possible when we use, store and transmit it and that it is only accessed as needed by our staff and other verified persons who have the necessary authority to do so.

All of our people who have access to your personal data are obliged to respect the confidentiality of this information and we deliver regular training to make sure they are fully aware of their responsibilities in this regard.

Any payment transactions will on our Website be encrypted using SSL technology.
 
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.

Unfortunately, please be aware that no transmission of personal data on the internet can be guaranteed to be 100% secure so please always be careful, particularly when sending data over a public network or Wi-Fi service.

How long will we use your 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.
 
In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal data from our records seven years after the date it was collected unless different retention periods apply, for example we will keep member data for 15 years after membership expiry in order to comply with requests for verification of membership status that are made to us.

However, if before that date (i) your personal data is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove or anonymise your personal data from our records at the relevant time.   
 
Where we anonymise your personal data (so that it can no longer be associated with you) we may use this information for research or statistical purposes indefinitely without further notice to you.  
 
If you request to receive no further contact from us for marketing purposes, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

CIPD has offices in the United Kingdom, Republic of Ireland, United Arab Emirates and Singapore and this international presence means that certain personal data may be transferred within the CIPD Group due, for example, to our shared IT systems, datacentres and cross-border working practices.

In addition, when you use our Website, applications, services or our products some of these require us to use service providers who are located in countries outside of the UK or EEA and may involve processing your personal data in those territories.

Please note that the laws of some countries are not regarded as providing the same level of protection for personal data as you enjoy in the UK or EEA. This may mean that there are less legal requirements around security and fewer rights for individuals. Where your personal data is transferred, stored and/or otherwise processed outside the UK or EEA, we will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this policy.

As appropriate, we will also make sure that the data transfer is either (a) subject to a legally recognised mechanism (such as the European Commission Standard Contract Clauses or UK Information Commissioner International Data Transfer Agreement) to ensure that, when your personal data is transferred to a country, it is protected to legal standards that are equivalent to those you enjoy in the UK or EEA or (b) of a type which is permitted under UK or EEA data protection law (for example, you have given your explicit consent to the transfer or it is necessary for us to comply with a contract obligation we have to you).

By using our Websites you acknowledge that the personal data you submit may be transferred outside the UK or EEA in the circumstances set out in this privacy notice.

If you do not want your personal data to be transferred outside the UK or EEA, you should not use our Website or our applications, products or services.  

Your legal rights if you are located in the UK or EEA

We want to ensure that you remain in control of your personal data.  You can contact our customer services team at any time by email (dataprotection@cipd.co.uk) or telephone (+44 (0)208 612 6208) if you wish to exercise any of your rights, such as the right to opt-out of direct marketing as referred to above in the paragraph headed OPTING OUT OF DIRECT MARKETING. Please provide your full name, membership number (if applicable), contact telephone number and email address.  

Under UK and EEA data protection law, 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 certain other information about how we collect, process and share it, subject to certain legal exceptions that may apply.
 
To assist us in processing your request, please describe, in as much detail as possible, the personal information you wish to have access to and if appropriate, any dates relevant to the information sought.
 
Request correction of the personal data that we hold about you. If you believe our records of your personal data are inaccurate you can ask us to update these records, though we may need to verify the accuracy of the new data you provide to us.
 
If you have an online account with us, you can update your personal data and marketing preferences by making amendments in the ‘My Profile’ section of our Website.
 
Request erasure of your personal data. You can ask us to delete personal data where there is no good reason for us continuing to process it, 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 erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request or as soon as possible thereafter. We may also anonymise your data rather than delete it.
 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you are of the view that such processing impacts your fundamental rights and freedoms. There are some exemptions to this right - for example, if we have compelling legitimate grounds to continue to process your information.
 
Request restriction of processing of your personal data. You can 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 compelling legitimate grounds to use it as referred to above.
 
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.

What we will need from you

We will 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 help speed up our response.

Time limit to respond

We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex. In some cases, we also have a right to refuse (or charge a fee in respect of) any excessive or manifestly unfounded requests. In these cases, we will notify you accordingly.

THIRD-PARTY LINKS

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or practices. To the fullest extent legally permitted, we are not liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by those websites. When you leave our Website, we encourage you to read the privacy policy and terms and conditions of every website you visit to see how each third party will process your information.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 25 November 2022 and is kept under regular review.
 
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.

Contact details

United Kingdom

1. The Chartered Institute of Personnel and Development

2. CIPD Enterprises Ltd
 
dataprotection@cipd.co.uk  
 
151 The Broadway, London, SW19 1JQ
 
+44 (0)208 612 6200
 
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority if you think your data protection rights have been breached by us (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Republic of Ireland
CIPD Ireland
 
dataprotection@cipd.co.uk  
 
A3, The Locks, Charlotte Quay Dock, Dublin 4, Ireland
 
+353 1 678 0090

You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority if you think your data protection rights have been breached by us (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your query or concern in the first instance so please contact us.

Singapore

CIPD Asia Ltd
 
dataprotection@cipd.co.uk
 
 7 Temasek Boulevard
#04-02 Suntec Tower One
Singapore 038987
 
 (65) 6338 4528

You have the right to make a complaint at any time to the Personal Data Protection Commission (PDPC), Singapore’s responsible authority, if you think your data protection rights have been breached by us (https://www.pdpc.gov.sg/). We would, however, appreciate the chance to deal with your query or concern in the first instance so please contact us.

United Arab Emirates

CIPD Middle East FZ-LLC
 
dataprotection@cipd.co.uk
 
Office 3, Ground Floor, Block 2B
Dubai Knowledge Park
Dubai, UAE
PO Box 503231
 
+971 (0)4 275 6900

You have the right to make a complaint at any time to the Dubai International Finance Centre (DIFC) Commissioner of Data Protection, the responsible supervisory authority in DIFC if you think your data protection rights have been breached by us (https://www.difc.ae/). We would, however, appreciate the chance to deal with your query or concern in the first instance so please contact us.

Lawful basis

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to
 
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
 
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
 
Consent means consent, which is freely given, specific, informed and unambiguous.

Third parties

Internal third parties

Other companies in the CIPD Group acting as joint controllers or processors and who are based in the United Kingdom, Ireland, Singapore and United Arab Emirates and provide IT and system administration services and undertake leadership reporting.

External third parties

•    Service providers acting as processors to provide elements of services for us for example, to process payment information when purchasing services through our Website. We have contracts in place with our data processors which means that they will hold your data securely and cannot do anything with your personal data unless we have instructed them to do it.
•    Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
•    Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and Ireland who provide consultancy, banking, legal, insurance and accounting services.
•    HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, Ireland, Singapore and United Arab Emirates who require reporting of processing activities in certain circumstances.
•    Where we partner with other organisations we may also share information with them (for example if you register to attend an event jointly held by us and another organisation). We will only share information where necessary and we will make sure to notify you first.