Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms
It would be helpful to start by explaining some key terms used in this document:

We, us, our	NORFOLK BENEVOLENT MEDICAL SOCIETY (NBMS)
Personal data	Any information relating to an identified or identifiable individual

Personal data we will collect

Personal data we may collect depending on why you have contacted us

Your name, address and telephone number Information to enable us to check and verify your identity, eg your date of birth or passport details Electronic contact details, eg your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you

Details of your spouse/partner and dependants or other family members, eg if you are requesting a benefit for your family Your bank and/or building society details Your nationality and information from related documents, such as your passport or other identification, Your connections to other organisations eg your employer Details of your subscriptions/donations Details of your grant applications Records of your interactions with NBMS for example; attendance at events Recording and processing of donations To undertake statistical analysis To ensure you receive information of relevance and interest to yourself and to update you on our work. You will always have the ability to decline future contact To assess your eligibility for a grant, follow up and report on grants awarded

This personal data is required from you to enable us to consider you for benefit eligibility. If you do not provide personal data we ask for, it may delay or prevent us from considering your application.

How your personal data is collected

We collect most of this information from you, direct or via our secure online website.

However, we may also collect information:

• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
  • sanctions screening providers;
  • credit reference agencies;
  • client due diligence providers;
    from a third party with your consent, eg:
  • your bank or building society, another financial institution or advisor;
  • consultants and other professionals we may engage in relation to your matter;
  • your employer and/or trade union, professional body or pension administrators;
  • your doctors, medical and occupational health professionals;
• via our website
• via our information technology systems, eg:
• case management, document management and time recording systems;
• door entry systems and reception logs;
• automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems;

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:

• to comply with our legal and regulatory obligations;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for	Our reasons
To consider your eligibility for benefits	To consider your eligibility for benefits
Conducting checks to identify you and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, eg in relation to our financial performance, persons receiving benefits, award type or other measures	For our legitimate interests or those of a third party
Updating and enhancing client records	For our legitimate interests or those of a third party, eg making sure that we can keep in touch with you about existing and new events
Marketing our services and those of selected third parties to: current or new members; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, ie to promote us to existing and former members
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party and to ensure our clients are likely to be able to pay for our services.
External audits and quality checks and the audit of our accounts	For our legitimate interests or a those of a third party, To comply with our legal and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about new NBMS developments that might be of interest to you and/or information about us.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us by
• emailing administrator@nbms.org.uk
• We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

• professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions, eg Companies House;
• credit reference agencies;
• our insurers and brokers;
• external auditors, eg in relation to ISO, CQS, or Lexcel accreditation and the audit of our accounts;
• our bank;
• external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide
services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as the UEA. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal data is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy.

Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data (the right of access)
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write for the attention of The Administrator
  email: administrator
  telephone: 01603 275813
  address: The Administrator, NMBS, 13 The Close, Norwich NR1 4DS.
• let us have enough information to identify you
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 24 May 2018 and updated on 13 July, 2018.
We may change this privacy notice from time to time.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Norfolk Medical Benevolent Society
c/o Hansells Solicitors, Cambridge House, 26 Tombland, Norwich, NR3 1RE

administrator@nbms.org.uk

01603 275813

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).