Privacy Policy
WOB UK Ltd (“We”) are committed to protecting and respecting your privacy and complying with our obligations under the GDPR and the UK Data Protection Act 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are both the controller and processor of the personal data that you provide to us. This Privacy Policy (together with our Terms & Conditions and any other documents referred to in it) forms part of a data governance framework which sets out how WB Directors, registered as WOB UK Ltd of 27 Old Gloucester Street, London, WC1N 3AX, (”we”, “our”, “us”, “the Company”) will process any personal data we collect from you, or that you provide to us. This Policy refers to the data of our customers and other third parties. We have separate Privacy Notices for our employees and other workers, including contractors.
Our nominated representative for the purposes of processing personal data is Julia Fuller.
About this Privacy Notice
This privacy notice outlines the following:
- What personal data we collect, about whom; how and why we collect it
- The lawful basis for collecting personal data
- How we store personal data securely
- Your rights as a data subject in relation to your personal data
- Who we share personal data with
- How we use personal data for marketing, profiling and automated decision making
- Internal Training and Audit
- Changes to this policy
- Contact details
- Your right to complain
1. INFORMATION WE MAY COLLECT ABOUT YOU
1.1 Under the GDPR, we are transparent about our obligations as a Data Controller and Data Processor. The details of what personal data we collect, about whom, why we collect it, how we use it, the lawful basis, and where appropriate, the condition for processing can be found in the table below. The definition of lawful basis is documented in the Data Protection Privacy Policy. Where we rely on consent as a lawful basis, you have the right to withdraw your consent at any time and can do this by contacting us on contact@wbdirectors.co.uk
We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:
(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation);
(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
(d) Accurate and where necessary kept up to date (Accuracy);
(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).
1.2 We collect and process data about you as follows:
- Information that you provide by filling in forms on our site www.wbdirectors.co.uk (“our site”) and other online platforms managed by us. This includes information provided at the time of registering to use our site and to renew membership, to subscribe for our newsletter, to register to attend events, to purchase products and services, to building your online profile on our site, and to view or apply for vacancies including through our Bespoke NED Search Service;
- Details of transactions you carry out through our site and of the fulfillment of your request or order and to carry out our obligations arising from any contracts entered into between you and us including under our Terms and Conditions;
- We may ask you to complete surveys that we use for research purposes and service development, although these are optional. Any testimonials that you provide via these surveys may be used to create and publish relevant content on our website or anonymously in reports to our Partners. We will only attribute your testimonial or other input if you have given us explicit permission, within the survey or otherwise in writing.
- We will use your information to provide you with alerts for new products or services that we feel may interest you;
- We will use your information to notify you about changes to our services;
- If you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call or online meeting we have with you.
We use information held about you to perform your contract with us, where you have consented to such use, where we need to comply with legal or regulatory obligations or for our legitimate interests. We may therefore use your information for the following purposes:
Mandatory Membership Registration data (Lawful basis: Contract)–
We collect the data entered via our registration form for the purpose of creating your membership record using your email as your unique username. We use the data to ensure that you receive or have access to the products and services purchased from WOB UK Ltd. We use the data to send you direct marketing messages about further products and services that may be of interest to you, unless you opt-out. We may annotate your account in our database with information taken from publicly available sources such as LinkedIn to record relevant non-executive and executive appointments.
Optional Membership profile data (Lawful basis for processing special category data: Explicit consent)
We use this data entered by the member to support internal business decisions, for enhanced personalised on member communication and to monitor for and prevent unintentional bias in our services.
CVs and Covering Letters (Lawful basis: Consent)
We use this data to identify members who may be most interested in a Bespoke Vacancy. We only share with a third-party with your explicit permission/request.
CVs (Lawful basis: Contract)
We also hold CVs and share with our nominated CV Reviewer for the purpose of our 1-on-1 Board CV Reviews, where purchased by the member.
Surveys / feedback forms (Lawful basis: Legitimate interest)
We may use any information via these surveys on an anonymous basis on our website, in our marketing and in our internal or Partner reports. We will share information on a named basis only if you give permission within the survey or otherwise in writing. If you wish to provide entirely confidential feedback, please contact us separately.
Non-member data (Lawful basis: Consent)
We will use your name and email address to ensure access to the Events and / or Services (including our newsletter) you have registered for. This may include sharing with partners / agents as required to fulfil our Contract with you (See also clause on events below). You can cancel services in line with our Terms or unsubscribe from regular communications.
Bursary Award Application Form (Lawful basis: Consent; Lawful basis for processing special category data: Explicit consent)
We will use your data to identify individuals we feel would benefit most from the award using age and ethnicity as part of our selection criteria. Email addresses are used to create full member accounts for the winners.
1.3 We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory and must be provided to us in order that we can fulfill your request, for example to create an account with us, and we shall make this clear to you at the point of collection of the personal data.
1.4 All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
1.5 By registering as a member you opt-in to receive our communications administering your membership, our news and events and board vacancies. You can amend your preferences to opt-out at any time via a link in the email footer. Lapsed members will receive a limited series of emails prompting them to renew, followed by an email confirming that they will continue to receive quarterly newsletters from us, giving information about relevant events, products and services. Newsletters carry an option to Opt-Out.
1.6 We collect some technical and usage information about you automatically when you visit our websites or use our services including, but not limited to:
- traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
- information about your computer, including where available your IP address, operating system and browser type.
This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g. by personalising the content you see). Some of this information is collected using cookies and similar tracking technologies.
1.7 We may also contact you to provide you with information about board positions and services which may be of interest to you, based on the data we hold on you e. We may contact you about these positions by post, email or telephone.
1.8 Discussions within WOB UK Ltd-led members’ forums in-person or virtual via platforms, including WhatsApp groups or online webinars or events via platforms including but not limited to Zoom, Teams or Google Meets, are held under the Chatham House Rule, meaning “participants are free to use the information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other participant, may be revealed.” By participating in or viewing / listening to the conversations, participants agree to abide by the Chatham House rule and must not distribute the content conversation though are free to share the fact of their own participation only as well as their personal reflections. Conversations within the group may be collated by WOB UK Ltd and anonymised along the principles of Chatham House rule. These documents will be primarily for our internal records and content development, and we may occasionally share these anonymised records on a confidential basis with individuals. We will never share named or identifiable contributions without the explicit consent of the contributor(s).
2. HOW WE STORE YOUR PERSONAL DATA
2.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your application, request or order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
2.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
2.3 To enhance security and prevent fraud, any payment details submitted to our site are held by a specialist third-party payment provider. This includes one-time and saved payment methods. We take all reasonable steps to ensure they are compliant with the required cyber security standards for holding financial information. Our current payment gateway is Braintree, further information about their privacy policy can be found here: https://www.braintreepayments.com/gb/legal/braintree-privacy-policy
2.4 Unfortunately, the transmission and storage of information on the internet is not completely secure. We will do our best to protect your personal data, however we cannot guarantee its security. Once we have received your information, we will use best-practice procedures and security features to try to prevent unauthorised access. We ensure these practices are up to date by maintaining our Cyber Essentials accreditation. If we do become aware of any breach of our security that may have compromised your personal data, we will use best efforts to notify you without delay.
2.5 We have appropriate physical and technical security measures in place to protect your personal information. We ensure that we have provisions in place to ensure that only authorised parties have access, that your data is kept secure, and that we have processes and procedures in place to prevent accidental loss, destruction, alteration, unauthorised access or disclosure of your personal data. We have incident and breach processes and procedures in place to deal with and respond to any suspected breaches of your personal data and will notify you and any relevant regulators where we are required to do so.
2.6 We have a Data Retention Policy and Retention Schedule in place to ensure that your data is only kept for as long as necessary, and in line with the purposes that it was collected.
3. DATA SUBJECT’S RIGHTS AND REQUESTS
3.1 You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found at: https://ico.org.uk/your-data-matters/
- The right of access: You have the right to request copies of the data we hold about you;
- The right rectification: You have the right to request that we complete any information about you that you think is incomplete. You also have the right to request that we rectify any inaccurate information that we hold about you;
- The right erasure: Also referred to as the “right to be forgotten”, you have the right to ask us, in certain circumstances, to erase your data;
- The right to be informed: You have the right to be informed when we collect your personal data either directly from you or indirectly from another source;
- The right to object to us processing your personal data: You have the right to object to us processing your personal data in certain circumstances. For example – for the purposes of direct marketing;
- The right to restrict us processing your personal data: You have the right to restrict us processing your data in certain circumstances. This means that we may still be able to hold the data, but not process it;
We will always verify the identity of an individual requesting data under any of the rights listed above. Whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws. Therefore, if you are a registered user of our website, we shall retain your personal data for six years, except where we are required to retain your personal data for longer to comply with legal, regulatory, tax, accounting or reporting requirements. If you have otherwise contacted us with a question or comment, we shall retain your personal data for 12 months following such contact to respond to any further queries you might have.
3.2 You can exercise these rights or any others you may have under applicable laws by contacting us at contact@wbdirectors.co.uk. We aim to address your request within one month of receipt and at no cost, although we reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
3.3 If you believe that we have breached applicable laws, or this privacy policy, then you have the right to make a complaint to the Information Commissioner at https://ico.org.uk/concerns/ If you are outside of the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
4. DISCLOSURE OF YOUR INFORMATION
4.1 We may disclose your personal information to any member company of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.2 With your agreement, we may disclose your personal information to another member or user of the site.
4.3 We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If WOB UK Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of WOB UK Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4.4 We may disclose your personal information to our partners in the following circumstances:
- Bespoke NED Search: As part of our Bespoke NED Search service, we will provide members’ contact details and supporting information to an organisation seeking candidates (or their agent). This information will only be shared if you agree or request that we do so, in relation to that specific vacancy;
- Corporate Partners: We will routinely share information about members registered with eligible email domains with our Corporate Partner who owns the domain(s). This includes but is not limited to your name and personal data; use of specific and general WOB UK Ltd’s Services; anonymised feedback or commentary on WOB UK Ltd’s services and events and updates on your board career provided to us;
- We may circulate delegate lists to others registered to attend, speakers and venue hosts. This may include your name, job title and company, but we will never pass on contact details without your additional, explicit permission;
- We will only share your email address with third parties, such as our event hosts, presenters and service providers if: (a) they have a need to know the information for the purposes of providing the contracted services; (b) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
- We prohibit our delivery partners from using or disclosing your personal information except for their service to us or as required or authorised by or under law. Whilst we cannot be responsible for the actions of these organisations, we do ask them to comply with all applicable data protection legislation in relation to use of your personal data. Please contact us immediately if you believe your data is being misused by our partner.
5. MARKETING, PROFILING AND AUTOMATED DECISION MAKING
5.1 We send you marketing information because you have consented to receive it, or because we believe it is in our legitimate business interests to send marketing communications to you. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by following the unsubscribe link on any marketing email you receive; or by contacting us at contact@wbdirectors.co.uk which we will action in a reasonable time frame.
5.2 We will use profiling to evaluate your use of our site and tailor our communications to you, including last login date, events attended, profile information, purchases made and vacancies viewed. We may also use this data to identify whether you may be a suitable candidate for a vacancy.
5.3 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6. TRAINING AND AUDIT
6.1 WOB UK Ltd staff and contractors undergo mandatory annual data privacy related training.
6.2 We regularly review all the systems and processes under our control to ensure they comply with our data governance framework and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.
7. CHANGES TO OUR PRIVACY POLICY
7.1 We reserve the right to make changes to this Privacy Policy at any time. We last revised this Privacy Standard in November 2024. On subsequent revisions of this Policy, the changes made will be listed below and, where appropriate, notified to you by email.
8. CONTACT
8.1 Our aim is always to protect confidentiality whilst enabling effective delivery of our Services. If you do not want us to use your data in this way you should contact us before entering personal data on our website.
8.2 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to contact@wbdirectors.co.uk, by phone to 020 3925 4080 or by post to 27 Old Gloucester Street, London, WC1N 3AX (please note this is a postal address only and response times will be delayed)
9. YOUR RIGHT TO COMPLAIN
9.1 If you are unhappy with how WOB UK Ltd uses your personal data, we would ask you to contact us in the first instance. Our members are our priority and we always seek to treat people fairly. You also have the right to complain the ICO:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Last updated: November 2024