It is important that you read this privacy notice carefully. If you have any questions you can contact us on the details given below.

1.  IMPORTANT INFORMATION AND WHO WE ARE

IMPRESS is an independent regulator of the press. We are a regulator designed for the future of media, building on the core principles of the past, protecting journalism, while innovating to deal with the challenges of a digital age.

Our main activities are to:

• Award a ‘Trust in Journalism’ mark to publishers that meet our standards for membership.
• Maintain a progressive Standards Code and assess any breaches of this code by our members.
• Provide an arbitration scheme which is free to all parties and protects publishers against the risk of court costs and exemplary damages.
• Support the development of news publishers, through partnerships and collaboration.

IMPRESS is the data controller and responsible for your personal data.

We have appointed a Data Privacy Officer to co-ordinate our data protection efforts within the organisation. If you have any questions about this privacy notice or our data protection practices please contact the Data Privacy Officer using the following contact details:

CONTACT DETAILS

Our full details are:

Organisation: IMPRESS, the Independent Monitor of the Press, which is a Community Interest Company (registered number 9655520)

Name: Lexie Kirkconnell-Kawana

Email address: info@impressreg.org.uk

Phone: +44 (0)20 3325 4288

2.  THE DATA WE COLLECT ABOUT YOU

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

There are different types of personal data about you which we might collect use, store or transfer. In addition to

these specific categories of data, we might in relation to any interaction collect a range of other “descriptive experiential and activity” data about data subjects, for the purposes outlined below. We have grouped these together as follows, and provided some illustrations of the type of personal data which might fall into each grouping:

• Identity Data could include your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth or gender
• Contact Data could include your home or office address, email address, telephone numbers or another unique identifier for use with electronic communications
• Financial Data could include bank account and payment card details
• Transaction Data could include details about payments to and from you and other details of services you have purchased from us.
• Technical Data could include your 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 information about other technology on the devices you use to access this website
• Profile Data could include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
• Usage Data could include information about how you came to and leave our website, and how you use our website, products and services
• Communications Data could include what information you want to receive from us and how you would prefer it to be delivered.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly link to you as an identifiable individual. 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 be linked directly or indirectly to you, we treat the combined data as personal data which will only be used in accordance with this privacy notice.

We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor will we usually collect any information about criminal convictions. If we need such information we will ensure that we have a lawful basis for our processing of it.

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, and you fail to provide that data when requested, we may not be able to carry out our regulatory functions, perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services), or proceed with some other activity. In this case, we will inform you of the consequences at the time, but these may include being unable to complete some regulatory or contractual activity that you have asked us to undertake.

3. HOW WE COLLECT YOUR PERSONAL DATA

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 or a publisher you work for:
  • ask for information about our services or subscribe for them;
  • agree to be regulated under the IMPRESS Code or request assessment for the Trust in Journalism mark;
  • submit a complaint or participate in our complaints process;
  • respond to a consultation that we are running;
  • request communications to be sent to you; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Generated Data. We may generate Transaction, Usage, Marketing and Communications Data about you, by way of records of the direct and automated interactions that you have with us or our website.
• Third parties. We will receive personal data about you from various third parties as set out below:
• analytics providers [such as Google Analytics based outside the EU];
• content management system providers;
• advertising networks [such as Twitter based outside the EU];
• other regulators and enforcement agencies, including statutory and self-regulatory bodies based in the UK;
• individuals (third party members of the public or directly affected parties), and representative groups and organisations party to a regulatory service; and

(c)  search information providers [such as Google based outside the EU].

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the purpose for which we collected it which include the following:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To identify relevant publishers who may benefit from joining us, or to process membership applications from publishers to join IMPRESS in accordance with our Regulatory Scheme	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to identify prospective publisher members and ensure prospective members are aware of our services)
To deliver our services as an independent press regulator: (a) Carry out an assessment of compliance with our standards (b) To administer conferences, seminars and other events that we organise (c) Manage payments, fees and charges (d) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to carry out our regulatory functions; to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Consulting with you about your needs and expectations (c) Asking you to leave a review or take a survey (d) Inviting you to events or notifying you about activities that we are running	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how publishers use our services)
To undertake investigations of complaints, to assess compliance, to issue requests or advisory notices to the press, and to publish our findings or to undertake other functions in connection with our Regulatory Scheme	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to study how publishers and complainants use our services; to develop our services to make them more beneficial to our users)
To resolve legal disputes between individuals and organisations and news publishers that we regulate in accordance with our Arbitration Scheme	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to study how publishers and complainants use our Arbitration Scheme; to develop the scheme to make it more beneficial to our users)
To satisfy external auditors that we are meeting legal and regulatory requirements and standards	(a) Identity (b) Contact (c) Usage (d) Technical	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (being able to demonstrate our continuing adherence to the regulatory codes that apply to us is essential to our role as a trusted independent regulator journalism)
To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, to prevent fraud and in the context of any reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content, information about our services, seminars, conferences and other events and activities to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how publishers and members of the public use our website and services, to develop them, to grow our organisation and to inform our strategy for future engagement with users and other stakeholders)
To use data analytics to improve our website, services, engagement, user relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our organisation and to inform our engagement strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our services and ensure that our organisation serves the needs of its users)

5. HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties, including:
  • administrators of our arbitration scheme;
  • contractors we have appointed to ensure that events that we organise are run smoothly and safely and that your personal needs are met;
  • experts who are appointed by us to investigate your complaint; or
  • external professionals appointed to provide advice and recommendations on areas connected with their expertise;
• External Third Parties, which might include:
  • credit reference agencies such as Experian (if we need to carry out credit checks);
  • our regulated publications (where you make a complaint which requires us to share your personal data as part of the investigation);
  • companies or individuals who have made a complaint about one of our regulated publications;
  • the Chartered Institute of Arbitrators and any arbitrators appointed by them in connection with a request for arbitration;
  • the Press Recognition Panel (PRP), our oversight auditor, if they sample your case for audit;
  • providers of our IT infrastructure, such as Microsoft, Google or Amazon; or
  • governmental or other investigatory bodies (where required by law).
• Third parties to whom we may choose to sell, transfer or merge parts of our organisation or its assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then any new controller may use your personal data in the same way as set out in this privacy policy.

We will only share personal data with a third party to the minimum extent necessary for the lawful purposes in question, and 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, to the minimum extent necessary and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

Except to the limited extent indicated above, we do not currently intend to transfer, store and process your personal data outside the United Kingdom or the European Economic Area. It may be, from time to time, that it is necessary for us to make a transfer of your personal data to a country (a “third country”) which is neither within the EEA nor a country in relation to which the EU Commission has made a finding of adequacy in connection with its data protection regime. In those circumstances (including the limited circumstances identified above) we ensure that adequate safeguards are in place which will be appropriately documented in a formal agreement using appropriate safeguards which may include the model clauses approved by the EU Commission.

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The data security measures that we have in place include:

• Storing data in our password-protected CRM, which is hosted on highly secure UK-based servers;
• Retaining ongoing support from industry-leading IT companies for both our CRM and our office servers, ensuring that our data security is always monitored and up to date;
• Keeping two forms of backup: a backup in the office, and a Disaster Recovery backup that takes a backup of the main and exchange server every hour and automatically sends these to a data centre that is owned and operated by our external IT company;
• Encrypting our server and backups of our server. The server is protected by hardware firewall and an advanced comprehensive gateway security suite;
• Only allowing staff to access the server when in the office, or through a 2-factor authentication VPN connection when outside the office;
• Utilising a secure digital board portal solution for sharing of confidential board data rather than distributing it by email, post or other channels.

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, in a timely manner, where we are legally required to do so. We will endeavour to work with you and them to minimise the impact of the breach.

8.  DATA RETENTION

We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). These rights include 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 to check that we are lawfully processing it.You can make a data subject access request by e-mailing us at info@impressreg.org.uk with the subject line “Data Subject Access Request” or make a request over the phone.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Subject Rectification Request”, or by telephoning us, using the contact details given above.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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 request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Subject Erasure Request”, or by telephoning us, using the contact details given above.
• Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Use Objection”, or by telephoning us, using the contact details given above.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Use Objection”, or by telephoning us, using the contact details given 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 services to you. We will advise you if this is the case at the time you withdraw your consent.You can exercise this right by emailing us at info@impressreg.org.uk with the subject line “Data Use Objection”, or by telephoning us, using the contact details given above.

NO FEE USUALLY REQUIRED: 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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU: We may 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 speed up our response.

TIME LIMIT TO RESPOND: We try to respond to all legitimate requests within one month. Occasionally it could 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.

This privacy notice was last updated on 12 October 2020. The notice may be updated from time to time and an updated version will be published to our website at https://www.impressorg.com/about-us/governance/organisational-policies/privacy-notice/. Make sure to check back from time to time to see the current version of this notice, although important changes will be brought to your attention as and when necessary.