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DATA PROTECTION & PRIVACY STATEMENT




 1. Home
 2. About us
 3. Data Protection and Privacy Statement

The Chartered Insurance Institute (this includes its Subsidiary Companies in the
UK, Dubai, Hong Kong and India and its Societies) ("CII", "we", "us") is
committed to protecting the privacy and security of those with whom we interact.
We recognise the need to respect and protect information that is collected or
disclosed to us (called "Personal Information" explained below).

This notice is intended to tell you how we use your Personal Information and
describes how we collect and use your Personal Information during and after your
relationship with us, in accordance with applicable Data Protection Laws.

1. WHO WE ARE
CII is a professional body for the insurance and financial planning profession.
Our mission is to improve public trust in our united profession by driving
confidence in the power of professional standards: competence, integrity and
care for the customer. 

CII is committed to handling data fairly and lawfully and takes its data
protection obligations seriously. CII ensures that it processes Personal
Information in compliance with applicable data protection laws, including,
without limitation, the General Data Protection Regulation 2016/679 ("GDPR").

2. WHAT IS PERSONAL INFORMATION AND WHAT PERSONAL INFORMATION DOES CII COLLECT
ABOUT YOU?
What is Personal Information?
For the purposes of this Data Protection Notice "Personal Information" consists
of any information that relates to you and/or information from which you can be
identified, directly or indirectly. For example, information which identifies
you may consist of your name, address, telephone number, photographs, location
data, an online identifier (e.g. cookies identifiers and your IP address) or to
one or more factors specific to your physical, physiological, genetic, mental,
economic, cultural or social identity. When we combine other information (i.e.
information that does not, on its own, identify you) with Personal Information,
we treat the combined information as Personal Information.

What Personal Information does CII collect?
We may collect, use, store and transfer different kinds of Personal Information
about members and customers, including prospective members and prospective
customers. We also collect information from our consultants and contractors,
including our agents and employees. The Personal Information we collect may
include as follows:

 * Name
 * Contact details
 * Date of birth
 * Membership history and details
 * Payment information and reasons for resignation
 * Financial / bank account information
 * Membership of local institutes
 * Examination results and qualifications
 * CPD details
 * Job role, position and company information
 * Employment information
 * Queries and complaints


We may also obtain Special Category Personal Data (as defined in the GDPR) such
as healthcare information (for example, medical conditions). 

We may also obtain criminal records information. We may also obtain bankruptcy
and insolvency information.

Provision of data
Our members are obliged to provide Personal Information to us. This is so we can
verify our members' identity; to verify members' accreditations, qualifications,
examinations; and to provide details of further training and special offers as
required. We do this in order to promote technical excellence and standards
within insurance and financial industries. Failure to provide information may
mean that we cannot perform your membership contract with us.

Our customers are obliged to provide Personal Information to us. This is so we
can verify customer data and so that our customers can purchase their chosen
products from us. Failure to provide this information may mean that we cannot
perform this contract and you would not have access to our products.

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
CII collects information through you, for example, when you make enquiries with
us or through an application for membership, or to sit an exam, or if you
contact our customer service team. 

Personal Information is also collected via your membership with your local
insurance institute.

Other information will be obtained during the course of your membership from you
or third parties, such as your employers, or members of the public, or
regulators, to enable us to carry out the purposes set out below. We also obtain
information through the use of technology, such as Cookies, when you use our
website, and to allow you to access restricted areas of the website without
entering your personal details each time. For more information about Cookies,
please see the terms and conditions.


4. HOW DO WE USE YOUR INFORMATION?
We may use the Personal Information we collect for the following purposes:

 * To administer and manage your membership with CII
 * Liaising with your local institute, for example, to update records
 * To maintain details of any accreditations and qualifications
 * To provide details of training courses and study materials
 * To maintain records of examination performance
 * To maintain CPD records
 * To provide access to our online library of insurance and financial planning
   publications, reports, magazines and documents
 * For details of market events and sector network information
 * To provide learning and development services and materials 
 * To provide market news, opinions and key industry developments
 * For member perks including lifestyle member service products, services and
   discounts
 * To enhance and improve the CII's service and qualifications
 * To provide customer service support and including training and quality
   purposes.
 * To maintain and review order histories and invoices
 * To fulfil our disciplinary and regulatory functions
 * For marketing purposes


The law allows us to use the Personal Information as set out above on the basis
that the processing is necessary for the performance of a contract with you, or
we are acting in our "legitimate interests", for example, for the purposes of
providing goods, services, and support as an effective professional association
for our members.

Where we collect Special Category Personal Data we will not use this except for
the purposes of processing your membership, for the performance of your
membership contract, and complying with our legal obligations for disciplinary
and regulatory reasons. As regards medical information, this is for the purposes
of considering requests for reasonable adjustments where applicable, to enhance
your membership, or to assist when you are sitting exams. This is so that we can
comply with Health and Safety legislation and for our own legitimate interests,
to safeguard our members' wellbeing.



Marketing communications
CII may use your Personal Information to send you marketing communications by
mail, telephone (including SMS text message) or email. This is necessary for the
purposes of the legitimate interests pursued by us, for example, to keep our
members updated about products that they might be interested in. For situations
where you are purchasing goods and services from us, this is for the performance
of the contract with you. For further information on this, see the 'Your
Choices' section of this Data Protection and Privacy Statement.

Combining Personal Information
We may combine the Personal Information that we collect from you (including
information received from our affiliates) to the extent permitted by applicable
law. 

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

5. TO WHOM DO WE DISCLOSE YOUR INFORMATION?
We will only use your Personal Information for our internal business purposes,
for example, as set out above. We disclose your information to your local
insurance institute: this is the organisation which you select and which you
became a member of when you join CII, and we do this for the performance of your
membership contract with us.

We do share your information with third parties, for example with employers
regarding your qualifications, accreditations, examinations and training. We do
this for the performance of your membership contract with us or where we have
another lawful basis for doing so.

We may share your information with third parties such as accountants, legal
teams, regulators and other professional bodies. We would do this for the
effective performance of your membership contract with us, and/or so that we can
comply with any legal obligations.

We may also share your information with third parties where we outsource certain
functions, including but not limited to, our payroll and logistics functions,
assessment service providers, membership retention and engagement functions and
other service products that we use. We would do this, for the effective
performance of your membership contract with us, and for our legitimate
interests, such as the effective financial and business management of CII.

We may also disclose Personal Information to establish, exercise or defend our
legal rights including providing information to others and/or in connection with
any ongoing or prospective legal proceedings. We may also disclose Personal
Information to any person who we reasonably believe may apply to a court or
other competent authority for disclosure of that Personal Information where, in
our reasonable opinion, such court or authority would be reasonably likely to
order disclosure of that Personal Information.

We never sell any of your Personal Information to third parties.

6. WHAT DO WE DO TO KEEP YOUR INFORMATION SECURE?
We have put in place appropriate physical and technical measures to safeguard
the Personal Information we collect in connection with our services. In
addition, we limit access to your Personal Information to those employees,
agents, contractors and other third parties who have a business need to know.
They will only process your Personal Information on our instructions and they
are subject to a duty of confidentiality. However, please note that although we
take appropriate steps to protect your Personal Information, no website,
product, device, online application or transmission of data, computer system or
wireless connection is completely secure and therefore we cannot guarantee the
security of your Personal Information.

7. INTERNATIONAL TRANSFER OF DATA
The Personal Information that we collect from you may be stored and processed in
your region, or transferred to, stored at or otherwise processed outside the
European Economic Area ("EEA"), or in any other country where CII or CII
Affiliates, subsidiaries or service providers maintain facilities, including
overseas local insurance institutes. For example, where members are based
outside the EEA, members' data may be handled at the Hong Kong office and the
India office.

By using or participating in any service and/or providing us with your Personal
Information, you acknowledge that we will collect, transfer, store and process
your information outside of the EEA. We will take all steps reasonably necessary
to ensure that your Personal Information is kept secure and treated in
accordance with this Data Protection Notice and the requirements of applicable
law wherever the data is located. Where we transfer your Personal Information
outside the EEA to other countries, we will ensure that appropriate transfer
agreements and mechanisms (such as the EU Model Clauses) are in place to help
ensure that our third-party service providers provide an adequate level of
protection to your Personal Information. We will only transfer your Personal
Information outside the EEA in accordance with applicable laws.

8. DATA RETENTION – HOW LONG WE WILL STORE/KEEP YOUR PERSONAL INFORMATION
CII retains Personal Information for as long as necessary to fulfil the purposes
for which your Personal Information has been collected as outlined in this Data
Protection and Privacy Statement unless a longer retention period is required by
law. When your Personal Information is no longer required for the purpose it was
collected or as required by applicable law, it will be deleted and/or returned
to you in accordance with applicable law.

9. ACCESSING YOUR PERSONAL INFORMATION AND OTHER RIGHTS YOU HAVE
CII will collect, store and process your Personal Information in accordance with
your rights under any applicable Data Protection Laws. Under certain
circumstances, you have the following rights in relation to your Personal
Information:

I. Subject Access - you have the right to request details of the Personal
Information which we hold about you and copies of such Personal Information.
II. Right to Withdraw Consent – where our use of your Personal Information is
based upon your consent, you have the right to withdraw such consent at any
time. In the event you wish to withdraw your consent to processing, please
contact us using the details provided in clause 16 below.
III. Data Portability – you may, in certain circumstances, request us to port
(i.e. transmit) your Personal Information directly to another organisation.
IV. Rectification – we want to ensure that the Personal Information about you
that we hold is accurate and up to date. If you think that any information we
have about you is incorrect or incomplete, please let us know. To the extent
required by applicable laws, we will rectify or update any incorrect or
inaccurate Personal Information about you.
V. Erasure ('right to be forgotten') - you have the right to have your Personal
Information 'erased' in certain specified situations.
VI. Restriction of processing – you have the right in certain specified
situations to require us to stop processing your Personal Information and to
only store such Personal Information. 
VII. Object to processing – You have the right to object to specific types of
processing of your Personal Information, such as, where we are processing your
Personal Information for the purposes of direct marketing.
VIII. Prevent automated decision-taking – in certain circumstances, you have the
right not to be subject to decisions being taken solely on the basis of
automated processing.

10. ENFORCING YOUR RIGHTS

If you wish to enforce any of your rights under applicable Data Protection Laws,
then please contact us on our details in clause 16 below.

We will respond to your request without undue delay and no later than one month
from receipt of any such request, unless a longer period is permitted by
applicable Data Protection Laws, and we may charge a reasonable fee for dealing
with your request which we will notify to you. Please note that we will only
charge a fee where we are permitted to do so by applicable Data Protection Laws.

Complaints
If you are concerned that we have not complied with your legal rights under
applicable Data Protection Laws, you may contact the Information Commissioner's
Office (ico.org.uk) which is the data protection regulator in the UK which is
where CII is located. Alternatively, if you are based outside the UK, you may
contact your local data protection supervisory authority.

11. THIRD-PARTY LINKS AND PRODUCTS ON OUR SERVICES
Our websites, applications and products may contain links to other third-party
websites that are not operated by CII, and our websites may contain applications
that you can download from third parties. These linked sites and applications
are not under CII's control and as such, we are not responsible for the privacy
practices or the content of any linked websites and online applications. If you
choose to use any third-party websites or applications, any Personal Information
collected by the third party’s website or application will be controlled by the
Data Protection Notice of that third party. We strongly recommend that you take
the time to review the privacy policies of any third parties to which you
provide Personal Information.

12. COOKIES
What are cookies?
CII as well as certain other third parties that provide content, advertising, or
other functionality on our Services, may use cookies and other technologies,
including web beacons, action tags, pixel tags. Cookies are small text files
that can be read by a web server in the domain that put the cookie on your hard
drive. Cookies are assigned to and stored in a user's internet browser on a
temporary (for the duration of the online session only) or persistent basis
(cookie stays on the computer after the internet browser or device has been
closed). Cookies collect and store information about a user’s preferences,
product usage, content viewed, and registration information which allows for CII
to provide users an enhanced and customised experience when engaging with our
Products. We may use cookies to store your preferences and settings, help you
with signing in, provide targeted ads, and analyse site operations.

Further information on cookies
For further information on what cookies are, how CII and other third parties use
them, and for details of how cookies can be disabled, please see our Cookie
Policy.


13. YOUR CHOICES (E.G. MARKETING RELATED EMAILS OR OTHERWISE)
CII may use your Personal Information (such as your contact details (e.g. name,
address, email address, telephone number)) to send you marketing-related
correspondence related to our goods and services, in accordance with your email
and contact preferences. When we process your Personal Information for marketing
purposes, we do so on the basis that it is in our legitimate interests to do so,
or in the case of our email notification service, that it is necessary to
perform our contract with you.

We do not share Personal Information with third parties for the third parties’
marketing purposes.

We may also use your Personal Information to personalise and to target more
effectively our marketing communications to ensure, to the extent possible, that
any marketing-related correspondence is relevant to you.

To opt out of receiving marketing-related correspondence from CII, update your
preferences at cii.co.uk/preferences by clicking "Unsubscribe" in the email or
text message (SMS) you receive from us or by contacting Customer
Service customer.serv@cii.co.uk

14. DATA PROTECTION OFFICER
The CII has appointed ProDPO as its external Data Protection Officer to advise
and guide the CII to ensure continued compliance with Data Protection Laws. The
DPO is not employed by the CII. For more information please see prodpo.com

15. CHANGES TO THIS DATA PROTECTION NOTICE
It is also important that you check back often for updates to the Data
Protection and Privacy Statement, as we may change this Data Protection and
Privacy Statement from time to time. The “Date last updated” legend at the
bottom of this page states when the Data Protection and Privacy Statement was
last updated and any changes will become effective upon our posting of the
revised Data Protection and Privacy Statement. 

We will provide notice to you if these changes are material and, where required
by applicable law, we will obtain your consent. We will provide this notice by
email or by posting a notice of the changes on our website.

16. CONTACT US / FURTHER INFORMATION
If you have any queries at all in relation to your data and how we protect your
data rights, please contact us:
Contact: Liam Russell
Position: Legal Director
Address: Chartered Insurance Institute, 3rd Floor, 20 Fenchurch Street, London,
EC3M 3BY
Email: legal@cii.co.uk

DOCUMENT HISTORY

Document version: 3

Date last updated: 5 February 2019




 

The Personal Finance Society is part of the Chartered Insurance Institute group.



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