HMC is committed to ensuring that your privacy is protected.
This webpage sets out when and how we use your personal information that you or others provide to us. Your privacy is of the utmost importance to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of that information. This privacy notice describes what information we collect about you, how we use it, and the rights you have in relation to that collection and usage.
WHO WE ARE
THE HEADMASTERS’ AND HEADMISTRESSES’ CONFERENCE is a private limited company by guarantee incorporated and registered in England and Wales with the company number 00101760 whose registered address is 12 The Point, Rockingham Road, Market Harborough, LE16 7QU (“HMC”)
For the purposes of the General Data Protection Regulations, the Data Protection Act 2018 and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), HMC will be the ‘data controller’ for all personal information we determine the means and purpose of processing. We are registered with the Information Commissioner’s Office under registration number ZA422783.
We collect personal information when:
- you register your interest or become a member of HMC;
- you register for any of our events;
- you visit the website;
- we utilise publicly available resources;
- you register for our conferences or training events;
- you apply for a role with HMC.
- you register to receive any of our newsletters or any marketing materials.
HOW WE USE PERSONAL INFORMATION
We collect and use personal information in the following circumstances
When you register your interest or become a member:
We require personal details to fulfil your request for information or provide our membership services. This will always include your name, contact details (including e-mail, phone and address) as well as information regarding your professional role and experience.
When you return our annual survey, we will record personal information including, your name, contact details (and those of the Head’s PA) and academic details.
We may collect additional information you volunteer to us when calling our support staff regarding any elements of the membership service. We will only retain the personal information pertinent to delivering your services.
We will retain your Personal Data for the duration of your membership and will delete this data on termination of your membership, or honorary membership if applicable, or receipt of any objections you make under the terms detailed in “YOUR RIGHTS UNDER DATA PROTECTION LAW”, where we do not have an alternative legal ground or overriding reason to continue processing your Personal Data.
When you register for our events:
If you choose to register as a delegate at one of our events we will need to collect your name, email address, professional details such as your current place of employment and role.
We use this information to run the particular event that you have signed up to attend. We will hold your data for as long as you have consented to us doing so. This information is collected to enable us to adequately organise and run the event for which you have registered.
To maintain relationships with members, alumni and the HMC community:
We may use information we hold about you to provide you with information about our membership service as well as events, training and supplementary services that may be of interest to you. We will communicate with you by post, telephone or email. You are not under any obligation to provide us with your personal information for marketing purposes and if you have provided your consent to this, you may withdraw it at any time.
If we rely on the legitimate interest of our business as the legal grounds to process your information for marketing purposes, we will always notify you of this and your right to object to this processing. All of our marketing communications will always contain clear instructions on how to unsubscribe from future communications.
If you apply to work for HMC:
When you apply to join HMC, we will only request the information we require to progress your application and assess your suitability for employment, this will usually include your name, contact details, CV information and data required, where appropriate, to perform an adequate DBS. During the course of applying or undertaking employment with HMC, we may be required to process sensitive categories of personal information. We will only do so if under a legal obligation, using an exemption afforded under Article. 9 of the GDPR or with your explicit consent.
If you have chosen to use a recruiter or third party job advertising organisation, we may have received your information via this method. We will notify you without delay if this is the case.
In the usual course of our employment dealings, we will be required to provide and request references regarding HMC applicants and staff. This is conducted under the legitimate business interest of HMC or the requesting party.
Any CV received directly or indirectly from an applicant who is not successfully employed by us will be held for a period of six months, except where we have notified you we intend to keep it for longer (and you have not objected).
For all current staff and successful applicants, we process all information required to service the terms of your employment contract for the duration of your time working for HMC and retain employee information for a period of 7 years or longer if required to by legislation after your employment has terminated. For further information on how we manage staff data, please refer to our employee privacy notice.
To successfully administer the requirements of the organisation:
We will process personal information to ensure the adequate business operation of HMC. This may be to facilitate management activities, planning, forecasting, statistical analysis or internal record keeping. We are also required to provide sufficient information to enable the relevant authorities to monitor HMC’s performance and to intervene or assist with incidents as appropriate.
We may also use photographic images, on HMC website and (where appropriate) social media channels in accordance with the Members’ school's policy on taking, storing and using images of children.
If we are not under a legal or regulatory obligation to perform the actions stated above, we will do so under our legitimate interest to sustain and promote the organisation.
All personal information used in this manner will be retained under the HMC retention schedule guidance.
When you visit our website:
We may also collect technical information about you when you visit the website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
The collected information is used to provide an overview of how people are accessing and using the Website. It is not used for any additional purpose, such as to profile those who access the Website.
We monitor usage of the website under our legitimate interest to analyse our service offering and ensure adequate security for the website.
If you fail to provide us with Personal Information:
You always reserve the right to withhold your Personal Information, but this may affect how we provide our services.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you 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. In this case, we may have to cancel our agreement but we will notify you if this is the case at the time.
LEGAL BASIS OF PROCESSING
We will only process your information for as long as we have a relevant legal basis to do so. Unless stated above in “WHAT TYPES OF PERSONAL DATA WE COLLECT” this is in order to provide you with the contractual services you have requested from HMC or if you have provided us with adequate consent to process your information for other purposes.
If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object. You always have the right to object to us processing your personal information under this basis (please see “YOUR RIGHTS UNDER DATA PROTECTION LAW” below).
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our privacy officer on [email protected]
PROTECTING YOUR INFORMATION
We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.
All the Personal Data collected by us and stored electronically is held on a secure server in the EEA only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Transfer of data outside of the EU
We shall not transfer any Personal Data to any country outside of the European Economic Area unless we ensure that such Personal Data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.
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.
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 requirements.
If you have any specific queries about how our retention policy is applied or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact our Privacy Officer (details below).
HMC has appointed a Chief Operating Officer (please see “QUERIES REGARDING THIS PRIVACY NOTICE” for full contact details), who will deal with all requests and enquiries concerning HMC’s uses of your personal data and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.
SHARING YOUR INFORMATION WITH OTHERS
Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government authorities, regulatory bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways:
- we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
- we may utilise professional advisers (such as legal counsel, accountants and insurers) to ensure the compliance and sustainability of our operations;
- analytics and search engine providers that assist us in the improvement and optimisation of the website.
YOUR RIGHTS UNDER DATA PROTECTION LAW
You can exercise the following rights to your data by contacting us at [email protected] We will only take instructions from you or your legal representative and we will protect your privacy when you contact us by asking specific and relevant questions to make sure we are speaking to you or your legal representative and not to an unauthorised person.
Right to object
You have the right to object to us handling your personal information when:
- we are handling your personal information based on our legitimate interests. If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue; and
- we are processing for marketing purposes. If you ask us to stop handling your personal information on this basis, we will stop.
Right of access
You are entitled to receive confirmation as to whether your Personal Data is being processed by us, as well as various other information relating to our use of your Personal Data. You also have the right to a copy of the Personal Data which we are handling regarding you.
Right to rectification
You have the right to require us to rectify any inaccurate Personal Data we hold about you. You also have the right to have incomplete Personal Data we hold about you completed, by providing a supplementary statement to us.
Right to restriction
You can restrict our processing of your Personal Data where:
- you think we hold inaccurate Personal Data about you;
- our handling of your Personal Data breaks the law, but you do not want us to delete it;
- we no longer need to process your Personal Data, but you want us to keep it for legal reasons; or
- we are handling your Personal Data because we have a legitimate interest and are in the process of objecting to this use of your Personal Data.
Where you exercise your right to restrict us from using your Personal Data, we will then only process your Personal Data when you agree, except for storage purposes and to handle legal claims.
Right to data portability
You have the right to receive the Personal Data we hold about you in a structured, standard machine readable format and to send this to another controller in certain circumstances.
Right to erasure
You have the right to require us to erase your Personal Data which we are handling in the following circumstances:
- we no longer need to use your Personal Data for the reasons we told you we collected it for;
- where we needed your consent to use your Personal Data and you have withdrawn your consent;
- you object to our use of your Personal Data and we have no compelling reason to carry on handling your Personal Data;
- our handling of your Personal Data has broken the law; or
- we must erase your Personal Data to comply with a law we are subject to.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected] Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Right to complain
CHANGES TO THIS PRIVACY NOTICE
We may change this Privacy notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the 'Last updated' section below. We will endeavour to notify all of our current members of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
QUERIES REGARDING THIS PRIVACY NOTICE
Any comments or queries on this policy should be directed to Tel: 01858 469 059 or email: [email protected]