Privacy Notice – British Educational suppliers Association (BESA)

This privacy notice sets out how the British Education Suppliers Association (“BESA) uses and protects your personal data.

Members of BESA, prospective members and members of the EdTech Exchange please refer to the separate Members Privacy Notice.

1. Important information and who we are

Privacy policy

This privacy policy is published by the British Education Suppliers Association (“BESA”), a company limited by guarantee and registered in England under company number 01097059.We are a membership organisation operating as a trade association. Our registered office is at 81 Rivington Street, London EC2A 3AY. The policy explains how we collect and uses your personal data whether received through your access to our website, when you provide your personal information to any representative of BESA, sign up to our newsletter or events organised or promoted by BESA make any general enquiry of BESA or the data is received from a third party that you have authorised to share your data with BESA (such as a third party events organiser).

Data Controller

BESA is the controller and responsible for your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified from the data itself or in combination with data a third party may already hold or have access to.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Transaction Data includes details about payments to and from you and other details of events you have registered for.

Technical Data may 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, device ID and other technology on the devices you use to access this website.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by providing your contact details (such as through a business card given to one of our representatives, completing online forms or by corresponding with us by post, phone, email or otherwise. This includes where you:

subscribe to our newsletters;

express interest in or register for an event promoted by BESA;

request marketing to be sent to you;

enter a competition, promotion or survey;

give us feedback or contact us;

video or photographic imagery taken at events we organise and that you attend; or

online recordings of webinars that we present in which you participate.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. Where you consent to your details being passed on to BESA through any representative of BESA or a third party.

Technical Data may be collected from analytics providers such as Google based outside the UK;

Contact and Transaction Data if you make a reservation to attend an event or receive any other benefit from BESA that data is collected from providers of payment services. Currently we subscribe to a Google provided facility – Google Tag Manager. More information about Google Tag Manager is available by following this link.

Other Ways we receive your personal data: Event organisers who you have agreed may share your personal data with BESA.

Consent to the use of cookies

For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: https://cookiefirst.com referred to as CookieFirst.

When you access our website, a connection is established with CookieFirst’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

Your consent status or the withdrawal of consent
Your anonymised IP address
Information about your Browser
Information about your Device
The date and time you have visited our website
The webpage url where you saved or updated your consent preferences
The approximate location of the user that saved their consent preference
A universally unique identifier (UUID) of the website visitor that clicked the cookie banner

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you (such as when you have registered to attend an event promoted by BESA).

Legitimate interests: We may use your personal data where it is necessary to conduct the business of the association and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the principal ways in which we may use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To register you in order for you to receive newsletters, details of events and other updates from BESA	(a) Identity (b) Contact	With your consent for so long as we hold that
To register you for events that we are promoting	(a) Identity (b) Contact (c) Transactional de) Marketing and Communications preferences (e) dietary and event access arrangements you require us to ensure are met	(a) Performance of a contract with you (b) Necessary for our legitimate interests (for example to recover any payments due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (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 manage our relationship with you)
To enable you to take advantage of the LendED platform	(a)Identity (b) Contact details (c) Marketing and Communications	(a) With your consent for so long as we have that
To enable you to participate in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Responses we ask for and which you provide (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how you use our website and to inform further developments we may choose to make to the website)
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	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise or to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how you make use of our website, to develop its content and to inform our marketing and operational strategies)
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications [and make personalised suggestions and recommendations to you about BESA services that may be of interest to you based on the information we hold about you]	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent, (having obtained your prior consent to receiving direct marketing communications). Our legitimate interests in relation to any personalised suggestions we may offer.
To carry out market research through your voluntary participation in surveys	Not applicable	Necessary for our legitimate interests (to study how interested parties use our website and to help us improve and develop our services and information we provide).

Direct marketing

During the registration process on our website when your personal data is collected, you may be asked to indicate your preferences for receiving direct marketing communications from BESA (including EdTech Exchange) by email.

Third-party marketing

We do not share your personal data with any third party for their own direct marketing purposes. In certain cases, we may ask for your consent to share data with a third party but will always make clear the identity of that third party.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting [include an appropriate email address].

If you opt out of receiving marketing communications, you may still receive service-related communications such as when we wish to check that your contact details are correct and in conjunction with any communication you initiate with BESA

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

In order to administer events that we organise or participate in where personal data is required to be shared with third parties for security reasons or to make your involvement in the event as good as possible (so including dietary requirements for example);

Third parties to whom we may choose to sell, transfer or merge parts of our operations. Alternatively, we may seek to acquire businesses or organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we authorise the transfer of your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place. To facilitate registrations for events that we provide we use third party specialist providers such as Eventbrite who may process your data on a basis that transfers the data internationally. Please refer to provider’s privacy policy when providing data to us through that means.

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.

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 where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

In order 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 you can ask us to delete your data: see below for further information.

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

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “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.

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.

Request erasure of your personal data in certain circumstances. 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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Section 4 for details of how to object to receiving direct marketing communications).

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 (see the table in Section 4 for details of when we rely on your consent as the legal basis for using your 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 or information to you. We will advise you if this is the case at the time you withdraw your consent.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or

You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at the email address identified belowor by writing to us at 81 Rivington Street, London, England, EC2A 3AY.

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.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: besa@besa.org.uk

Postal address: 81 Rivington Street, London, England, EC2A 3AY

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 18^th September 2024.

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, for example a new address or email address.

13. Third-party links

This 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 policy of every website you visit.