POIS, part of Foresters Friendly Society, is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you whilst we are sending marketing communications to you and after this period, in accordance with the General Data Protection Regulation (GDPR).
Who we are
The data controller with conduct of your personal information is Foresters Friendly Society Limited of Foresters House, 29-33 Shirley Road, Southampton, SO15 3EW.
Foresters Friendly Society is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
The Society’s data protection officer is Chris Davidson of Foresters House, 29-33 Shirley Road, Southampton, SO15 3EW.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
‘Personal data’, or ‘personal information’, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are ‘special categories’ of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth and age.
We do not collect, store and use “special categories” of more sensitive personal information.
How is your personal information collected?
We typically collect personal information about you:
- Through the application process;
- Through an enquiry submission on our website;
- Through an email or telephone enquiry;
- From any other way that you ask us to send marketing information to you.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- In response to a direct request to send marketing material and we therefore need to perform that contract obligation that we have entered into with you.
- To send you your copy of the Society’s Miscellany magazine.
- Where we need to comply with any other legal obligation.
- Where it is necessary for our legitimate interests to send you marketing materials and your interests and fundamental rights do not override those interests, i.e., you have not opted out of receiving marketing communications.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to fulfil your request to receive marketing information.
Change of purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing your personal data
We may have to share your data with third parties, including but not limited to the following:
- Introducers – individuals registered with the Society who introduce potential applicants to the Society’s products and are compensated by the Society for any resulting sales;
- IFAs – independent financial advisers registered with the Society who introduce potential applicants to the Society’s products and are compensated by the Society for any resulting sales;
- Marketing agencies for the purpose of analysis of customer behaviour so that we can send you targeted marketing and monitor our service
- Hubspot and Mailchimp – marketing automation platforms which store and use data to facilitate digital marketing initiatives
- Survey Monkey – the legal entity that sends out email marketing on our behalf;
- Distributors of the Miscellany magazine;
- and other entities in the Society’s group where we have a legitimate interest in doing so, that does not override your rights and freedoms.
How secure is my information with third-party service providers and other entities in our group?
We require all the third parties listed above to respect the security of your data and to treat it in accordance with the law on data protection.
All the third parties listed above are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes unless, you have asked us to or where they already have a business relationship with you (e.g. your IFA). We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other unconnected third parties?
We may, where legally required to do so or where we have a legitimate interest in doing so which does not outweigh your rights and freedoms, share your personal information with other unconnected third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We do not anticipate transferring your information outside of the EU.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. Unless we have explained otherwise, they will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information 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 respect of our marketing practices, we will retain your personal data until such time as you tell us that you no longer wish to receive marketing communications PLUS an appropriate period that we may reasonably determine when we consider the amount, nature, and 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure and restriction
Your duty to inform us of changes
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 working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there original purpose for processing has expired and there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party where we are processing your personal data by electronic means.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer in writing.
No fee usually required
After 25th May 2018, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity, or authority to act on behalf of a third party and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to stop direct marketing activities
You have the right to ask that we stop sending you direct marketing at any time.
If you want us to remove you from our marketing databased, please either:
- Click on the unsubscribe link in the email that you no longer wish to receive; or
- Call us on 0800 622 417 and ask that we remove you from our marketing database; or
- Email firstname.lastname@example.org
Once we have received notification that you no longer want to receive marketing communications from us, we will no longer process your personal information for this purpose.
Data protection officer
We have appointed a data protection officer (DPO), currently Mr Chris Davidson, to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO on 02380 216 857.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.