Privacy Notice

 

1. INTRODUCTION

1.1. This privacy notice (Privacy Notice) sets out the ways in which we, International Water Association (IWA, we, us, our), collect and use your personal data (your personal information) in connection with our business, including via our website http://www.iwa-network.org/. It also explains what rights you have to access or change your personal data.

1.2. Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 13. If you are under the age of 13 please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 13.

 

2. ABOUT US

2.1. We are a UK registered company limited by guarantee (company number 03597005) and a registered Charity (Charity number 1076690) in England and Wales with our registered address as set out below.

  • You can contact us as follows:

FAO: Keith Robertson, Chief Operating Officer

Address: Alliance House, 12 Caxton Street, London, SW1H 0QS, UK

Email: dataprotection@iwahq.org

Phone number: +31 (0)70 218 31 00

 

3. INFORMATION WE MAY COLLECT ABOUT YOU

3.1. Information that you provide to us.

3.1.1. We will collect any information that you provide to us when you:

  • become a member of IWA;
  • subscribe to a webinar;
  • participate or apply to participate in one of our projects, such as Basis of the Future;
  • make an enquiry, provide feedback or make a complaint over the phone, by email or on our website;
  • submit correspondence to us by post, email or via our website;
  • update your profile and other membership details;
  • subscribe to our newsletter and mailing lists;
  • fill in a form, conduct a search, post content on the website, respond to surveys, participate in promotions or use any other features of the website;
  • submit reviews and comments on the website;
  • contact other users on the website;
  • register to and/or attend our events;
  • submit a CV;
  • submit an application to a job vacancy;
  • attend an interview or assessment; and
  • ‘follow’, ‘like’, post to or interact with our social media accounts, including Facebook, LinkedIn, Twitter, and Vimeo.

3.1.2. The information you provide to us will include (depending on the circumstances):

  • Identity and contact data: title, names, addresses, email addresses and phone numbers;
  • Account profile data: if you’re registering your membership or apply to participate in one of our programmes or projects you may also provide language preferences, name, password, phone number, address, email, nationality, job title, phone, year of birth, other affiliations, whether you are a student or retired, journal subscription preferences;
  • Financial data: If you are using the website to purchase membership or services, you will also provide payment details, which may include billing addresses, credit/debit card details and bank account details;
  • Employment and background data: If you are submitting a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your social security number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us; and
  • Sensitive information: If you are submitting a job application, you may provide information about your race or ethnicity, religious beliefs, sexual orientation, health and whether or not you have any disability.

 

3.2. Information we collect about you:

  • Programme and project participation data: If you participate in one of our programmes, we collect data about your contribution to the IWA, the programme and the project;
  • Information contained in correspondence: We will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our website or by email or telephone, we may keep a record of that correspondence;
  • Information transmitted on the website: We will collect information that you upload or post to your website account and/or any correspondence or interactions that you may have with other website users;
  • Transactional data: We will collect information related to your transactions on the website, including the date and time, the amounts charged and other related transaction details;
  • Website usage data: We will collect information about your interactions with the website, including information such as login data, IP address, page views, searches, requests, orders, pre-approvals, confirmations, agreements between you and other website users and other actions on the website;
  • Technical data: We will also collect certain information about how you use our website and the device that you use to access our website, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the COOKIES section below.

3.3. Information we receive from third parties

3.3.1. In certain circumstances, we will receive information about you from third parties. For example:

  • Website users: we may receive personal information from other website users, who may be based inside or outside the EU, for example information that is posted or uploaded by other users (e.g. reviews), information relating to transactions and/or correspondence between website users;
  • Partners: we receive information about you from our event partners and Governing Members, a full list of which is available here;
  • Employers, recruitment agencies and referees: if you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application;
  • Service providers: we may collect personal information from our website developer, website analytics provider, IT support provider, membership platform provider and payment services provider (who may be based outside the EU);
  • Website security: we will collect information from our website security service partners who are based in the EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful;
  • Social media plugins: we currently use social media plugins from the following service providers who are based both inside and outside the EU: Facebook, LinkedIn, Twitter, and Vimeo. By providing your social media account details you are authorising that third-party provider to share with us certain information about you; and
  • Publicly available sources: we currently use publicly available sources such as Companies House, for instance to carry out identity and compliance checks; and

3.3.2. We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.

 

4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

4.1. We will use your information for the purposes listed below either on the basis of:

  • performance of your contract with us and the provision of our services to you;
  • your consent (where we request it);
  • where we need to comply with a legal or regulatory obligation; or
  • our legitimate interests or those of a third party (see paragraph 4.3 below).

4.2. We use your information for the following purposes:

  • To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
  • To register your account: when you sign up as a member, we will use the details provided on your account registration form (on the basis of performing our contract with you);
  • To enable you to communicate with other website users: certain parts of the website enable you to communicate with each other. We will use the information you have provided (such as your name and contact details) to enable you to communicate with each other (on the basis of our contract with you);
  • To process and facilitate transactions with us: we will use your information to process transactions and payments, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
  • Relationship management: to manage our relationship with you, which will include notifying you about changes to our terms of use or privacy notice, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
  • To conduct business with you or your employer: we use your information to contact you and manage and facilitate our business relationship with you and your employer;
  • User and customer support: to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with enquiries or complaints about the website and share your information with our website developer, IT support provider, membership platform provider, and payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users and to comply with our legal obligations);
  • Surveys: to enable you to take part in surveys (on the basis of our legitimate interest in studying how our website and services are used, to develop them and grow our business);
  • Recruitment: to process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
  • Marketing: to keep in contact with you about our news, events, new website features products or services that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
  • Advertising: to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (on the basis of our legitimate interests in studying how our website/services are used, to develop them, to grow our business and to inform our marketing strategy);
  • Social media interactions: to interact with users on social media platforms including Facebook, LinkedIn, Twitter, and Vimeo for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
  • Analytics: to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);
  • Research: to carry out aggregated and anonymised research about general engagement with our website and services (on the basis of our legitimate interest in providing the right kinds of products and services to our website users);
  • Fraud and unlawful activity detection: to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
  • Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).

4.3. As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, as set out above. Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 9 below.

4.4. Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 9 below.

 

5. WHO WE MIGHT SHARE YOUR INFORMATION WITH

5.1. In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:

5.1.1. Website users: other website users who you use the website to communicate with, who may be based both inside and outside the EU;

5.1.2. Partners and collaborators: event partners and governing members based both inside and outside the EU;

5.1.3. Our service providers: service providers we work with to deliver our business, who are acting as processors and provide us with:

  • website development and hosting services based in the UK and the EU;
  • IT, system administration and security services based in the UK and the EU;
  • marketing and advertising services, analytics providers based in Ireland and the US;
  • social media plugin services including Facebook, LinkedIn, Twitter, and Vimeo based in the EU and the US;
  • payment services based in the UK and/or the EU;
  • banking services based in the UK and the EU;
  • legal, accountancy, auditing and insurance services and other professional advisers based in the UK and the EU;
  • recruitment service providers based in the UK and the EU; and
  • travel and event management providers based in the UK and/or the EU.

5.1.4. Corporate affiliates: the International Water Association Publishing based in the UK;

5.1.5. Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based in the UK and the EU who require reporting of processing activities in certain circumstances;

5.1.6. Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;

5.1.7. Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and

5.1.8. Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the UK and the EU where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

5.2. We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.

6. COOKIES

6.1. For information about the cookies on our website, please see our cookies policy here.

 

7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR

7.1. We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:

  • ensuring the physical security of our offices;
  • ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
  • delivering data protection training to our employees; and
  • limiting access to your personal information to those in our company who need to use it in the course of their work.

7.2. We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,

  • we archive our email and paper correspondence regularly and destroy information older than 7 years;
  • we retain information relating to orders, refunds and website user queries for approximately 3 years;
  • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently.

8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

8.1. Our headquarters are located in the UK and our global operations is based in the Netherlands. We also have offices in China, Africa and India.

8.2. Many of our external third parties are based outside the European Economic Area (EEA) (including the UK) so their processing of your personal data will involve a transfer of data outside the EEA.

8.3. Whenever we transfer your personal data out of the EEA, where necessary, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:

8.4. Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU

9.1. You have certain rights in respect of the information that we hold about you, including:

  • the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
  • the right to ask us not to process your personal data for marketing purposes;
  • the right to request access to the information that we hold about you;
  • the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
  • the right to withdraw your consent for our use of your information in reliance of your consent (refer to section 2 above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
  • the right to object to our using your information on the basis of our legitimate interests (refer to section 2 above to see when we are relying on our legitimate interests) (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;
  • the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
  • in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
  • the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.

Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your account even when you have requested not to receive marketing communications.

9.2. How to exercise your rights

9.2.1. You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing, by clicking on the unsubscribe link on our marketing emails [or by updating your marketing preferences via your account with us.

9.2.2. You may contact us via the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.

9.3. What we need from you to process your requests

9.3.1. We may need to request specific information from you to help us confirm your identity and to enable you 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 speed up our response.

9.3.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. SHARING DATA DIRECTLY WITH THIRD PARTIES

10.1. You might end up providing personal information directly to third parties as a consequence of your interactions with our website and other services offered by us. For example, your name and other personal information will be shared with other website users when you correspond with them via the website, or you may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.

10.2. Please be responsible with personal information of others when using our website and the services available on it. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when takes place outside of the website or our services.

 

11. THIRD-PARTY LINKS

The 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

12.1. We may make changes to this Privacy Notice from time to time. We will post any changes to our site or notify you of any material changes by e-mail.

12.2. 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 by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.

 

This Privacy Notice was updated on [19] March 2019.