AGRC, the Association of Governance, Risk & Compliance, is committed to protect individuals’ personal data in line with the requirements of the General Data Protection Regulation (the GDPR), the Data Protection Act 2018 and other relevant legislation and regulation (collectively “the Data Protection Law”).

AGRC’s commitment applies to all individuals whose personal data it may process. This privacy notice will inform you as to how we look after your personal data we collect from you, both when you visit our website and where we carry out services for you. This privacy notice tells you about your privacy rights and how the Data Protection Law protects you.

“Personal Data” means any information relating to an identified or identifiable natural person.

AGRC – Who we are

The Association of Governance, Risk & Compliance (AGRC) is a non-profit global association that provides professional qualifications and a networking and business development community to professionals in the GRC world.

As the Controller, the AGRC determines the purpose and means of processing individuals’ personal data.

Personal data that we may collect:

The AGRC processes different personal data for different reasons. These may include:

Personal data for contact, service provision and other purposes:

These may include, name, position, participant’s telephone number, details of person authorising attendance (e.g. employer of the participant in a seminar), academic and professional qualifications, date of birth, professional membership number, etc.

Information necessary to make payments:

This may include bank account details and other relevant details.

Compliance with statutory obligation:

The AGRC may process personal data where obliged to do so under the law (e.g. employment records, company records, tax reporting obligations, AML Laws).

Information collected during the registration for an event or conference organised by the AGRC:

AGRC may organise different kind of events or conferences either for promoting and marketing its services to existing and potential clients, for networking purposes, or for finding potential members or professionals interested in its different products or services.

In this respect, the AGRC may process personal data (e.g. name, surname, contact details and if relevant details in regard to academic and/or professional qualifications (including, but not limited to, name of University, subject of study, year of study) for efficient organisation and management of an event or conference. This information may be used for future contact, only with your consent, in order to market the Entity’s services to you or in order to inform you for similar events. This information will be held by the AGRC until you choose to unsubscribe/withdraw your consent, in accordance with article 7(3) of the General Data Protection Regulation (Regulation EU 2016/679).

Photographs/pictures, presentations, audio and video recording of speakers and participants and live web streaming of the events or conferences may be taken. They may be reproduced in various media including the AGRC’s publications, the AGRC website, social networks, TV channels and the press, in connection with the event or conference as well as for promotional activities of the AGRC.

If you wish that your image or voice is not recorded and published, for compelling and legitimate grounds relating to your particular situation, please follow the procedure described below at paragraph 11 for making a request.

We do not 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 do we collect any information about criminal convictions and offences.

Time of collection of personal data

Personal data may be collected by the AGRC where you or an organisation with which you are related in any capacity (e.g. employee, officer, representative) (the “Client Entity”) contact the AGRC in relation to any services that it may provide. Your personal data may also come to our possession in case you express any interest to and/or become an employee of the AGRC. Your personal data may also be collected through our website when you express an interest for the services of the AGRC. Your personal data may also be processed if you sign up to participate in an event or conference organised by the AGRC. Your data may also be collected when an organisation engages the AGRC to provide services and you are engaged in the organisation in any capacity that is relevant (for example, director, representative, employee of such entity with which the AGRC deals in providing any services.)

Use of your personal data:

The AGRC will process personal data to
• Provide its services or enter into discussions for the provision of services to you or a Client Entity.
• Manage the day-to-day tasks relating to the business relationship with you or a Client Entity (e.g. communication, payments, invoicing, support).
• Analyse, market, and improve its services as well as develop new services that may be of interest to you or a Client Entity.
• For physical security and IT security purposes.
• For insurance coverage purposes.
• In compliance with its legal obligations including accounting and tax.
• To be able to identify the individuals acting for a Client Entity or engaged by a Client Entity in a task which requires that the AGRC communicates with such individuals.
• To defend or uphold its legal rights.
• To comply with any order of a responsible court or other authority.
• In relation to any services that may be offered to the AGRC by any person or other entity including for example legal services, tax services, public services.
• For research purposes regarding the effectiveness of website services, marketing, advertising, and sales efforts.
• To keep you or a Client Entity informed in relation to its services and products.
• For direct marketing purposes in promoting the AGRC legitimate interest. In such a case you may opt-out of direct marketing as provided further below.
• For recruitment, employment, payroll, and other related purposes of the AGRC.
• For organising an event or conference and providing relevant information to participants.
• For purposes that are similar or connected to the above or for any other purpose that you or a Client Entity will provide personal data to us.

Legal ground for personal data processing

The AGRC may process the personal data set out above on one or more of the following:

• You have provided your consent to the AGRC for the specific purpose of processing.
• The processing is necessary for the performance of a contract to which you or a Client Entity are party or in order to take steps at your or a Client Entity ‘s request prior to entering into a contract with the AGRC.
• Processing is necessary for compliance with a legal obligation to which the AGRC as the controller is subject.
• Processing is necessary in order to protect the vital interests of you or of another natural person.
• Processing is necessary for the purposes of the legitimate interests pursued by the AGRC as the controller or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child. Examples where the AGRC may process personal data on this ground, include product development, communications and marketing, insurance purposes, employment and recruitment purposes, IT purposes (e.g. data loss prevention, information, system, network and cyber-security, employment data processing, general operations, and due diligence (e.g. internal customer analysis, reporting and management information).

Provision of your personal data to third parties

• The AGRC may share information in the context of providing its services to you or any Client Entity with other third parties including for example, trainers at our courses, payment processors, database service providers, other specialist service providers where instructed by you or a Client Entity to do so, its own legal and/or other advisors, other service providers (e.g. online storage centres, cloud service providers and statistics monitoring).
• The AGRC may also share your information where obliged to do so by an applicable court order and/or where required to do so by an applicable law.

The safety of your personal data

The AGRC takes the appropriate measures (physical, organisational, and technical) to ensure the safety of your personal data. Your personal data may be stored electronically or in paper form.

Personal data that you or a Client Entity provide to us in relation to other individuals.

Where you or a Client Entity provides to the AGRC personal data of other individuals (e.g. officers, secretary, employees, other individuals that the Client Entity interacts with or persons related to you) you or the Client Entity (as the case may be) represent to the AGRC that you or the Client Entity are duly entitled to do this.

You or a Client Entity also represent and that the individual in question is aware of the AGRC’s data protection practices as stated in this policy which may be relevant to the individual, how the AGRC may be contacted as well as such information that you or a Client Entity are obliged to provide to such individual under applicable laws in relation to the AGRC.

How long we keep your personal data for

The AGRC stores personal data for no longer than is reasonably necessary for its processing purposes. Where AGRC stores personal data based on your consent, it will delete such personal data when you withdraw your consent and provided that it is not obliged under law to maintain such data. In case of recruitment activities, the AGRC will delete your personal data if you are not employed unless you expressly consent for to the storing of your personal data for potential future roles and/or other purposes. If you accept an offer of employment by the AGRC, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained. The AGRC may in any case, keep personal data as long as is necessary for the defending or making of legal claims as provided by applicable limitation laws in the UK.

Transfers of personal data to third countries

The AGRC may transfer personal data to third countries outside the EU/EEA where required for any of the purposes stated above including for storage purposes. In each such case, the AGRC will ensure that such transfers will comply with the General Data Protection Regulation (Regulation EU 2016/679) based on a Commission Adequacy decision, or appropriate safeguards (e.g. standard contractual clauses) or other grounds provided by the GDPR. You may contact the AGRC in order to be informed of the appropriate or suitable safeguards (as the case may be).

Your rights as a data subject

• Right of access – you have the right to request from us, the AGRC, acting as your controller, to provide you with a copy of the personal data that we hold about you in which case we shall do so.
• Right of rectification – you have a right to request from the AGRC acting as your controller to correct the personal data that it holds about you that is inaccurate or incomplete in which case the AGRC acting as your controller shall do so.
• Right to be forgotten – you have a right to request from the AGRC acting as your controller in certain circumstances to erase your personal data from its records. In case that these circumstances apply to your case and provided that no exception to this obligation applies (e.g. where we are obliged to store your personal data in compliance with a legal obligation under the UK or EU law), the AGRC acting as your controller will erase your personal data from its records.
• Right to restriction of processing – you have a right to request from the AGRC acting as your controller where certain conditions apply, to restrict the processing of your personal data. Where these conditions apply the AGRC will restrict the processing of your personal data.
• Right of portability – you have the right to request from the AGRC acting as your controller where certain conditions apply, to have the data it holds about you transferred to another organisation. Where these conditions apply the AGRC will transfer your personal data to another organisation.
• Right to object – you have the right to object on grounds relating to your particular situation, to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that the AGRC refuses your request for any rights of access, it will provide you with a reason as to why.

You can make a request or exercise these rights by sending an e-mail to the following e-mail address: info@agrc.org.

We may request you to provide us information for the purpose of verifying your identity and residency in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
We will answer your request or request additional information from you within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request about the extension and keep you updated.

The AGRC may charge you a reasonable fee when a request is manifestly unfounded, excessive, or repetitive, or we receive a request to provide further copies of the same data. In this case we will send you a fee request which you will have to accept prior to us processing your request. Alternatively, we may refuse to comply with your request in these circumstances.

Failure to provide personal information

If the AGRC requests you to provide to it personal data and you fail to do so, the AGRC may not be in a position to provide a service and/or enter into an agreement with you, in which case it will inform you accordingly.

Your right to make a complaint

The AGRC will endeavour to promptly respond to your requests and complaints. In the event that you are unsatisfied, with the way we have handled your personal data or any privacy query or request that you have raised with us, you may submit a complaint to the AGRC in writing at the following email address:

info@agrc.org

We will try to respond to all requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.

If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

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Changes to this Privacy Policy

This Privacy Policy is subject to change to reflect a change in the data protection practices or legal framework. In the case that this Policy will be amended the revised document will be posted on the AGRC’s website and such change will apply from the date that it is posted unless otherwise stated in the revised Privacy Policy.