V3.0 2023-05-18
Contents
- Introduction
- Who we are
- Collection of personal data
- Lawful basis for the processing of personal data
- Storage of personal data
- Security measures
- Your rights as a data subject
- Complaints
1. Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we explain how we collect, use and protect your personal data.
We also explain your rights with regard to your personal data and how you can exercise those rights.
2. Who we are
IBITGQ is the International Board for IT Governance Qualifications. IBITGQ is a personnel certification body that certifies individuals in IT governance.
IBITGQ is the data controller in respect of all personal data that it collects and processes.
Our registered office address is:
International Board for IT Governance Qualifications Corp.
108 West 13th Street
Wilmington
Delaware 19801
USA
Email: servicecentre@ibitgq.org.
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at servicecentre@ibitgq.org.
3. Collection of personal data
We collect personal data from you for one or more of the following purposes:
- To maintain records of any certifications that we might have awarded to you.
- To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
- To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances, it may be your entity, rather than yourself, that has provided us with your personal data.
- To meet our obligations as a personnel certification body.
- To ensure the security and safe operation of our websites and underlying business infrastructure.
- To manage any communication between you and us.
The table in section 4 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
Technical information
In addition, to ensure each visitor to our website can use and navigate the site effectively, we collect the following:
- Technical information, including the IP address used to connect your device to the Internet.
- Your login information, browser type and version, time zone setting, and browser plugin types and versions.
- Operating system and platform.
- Information about your visit, including the URL clickstream to, through and from our site.
From time to time we may use technologies, such as tracking pixels (also called 1x1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing to your needs so we can send you more relevant emails. It also helps us identify subscribers who are not engaged with our marketing emails so we can remove them from our send lists.
Our Cookie Policy describes in detail how we use cookies.
In section 7 below, we identify your rights in relation to the personal data we collect and describe how you can exercise those rights.
4. Lawful basis for processing personal data
The table below describes the personal data we collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:
The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden by the individual’s interests, rights or freedoms?
|
Purpose of collection
|
Information category
|
Data collected
|
Specific use
|
Lawful basis for processing
|
Data shared with?
|
Retention period
|
|
1. To provide you with information
|
Subject matter information
|
Name, company name, geographic location, email address, business sector.
|
To provide appropriate online or email information about products and services that you have requested.
|
Contractual fulfilment
|
Internally only.
|
Maximum eight years from the date the information is collected.
Six months if a marketing email is left unopened.
|
|
To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.
|
Legitimate interest
|
Internally only.
|
|
Telephone number.
|
Follow-up to ensure requested information meets needs and identify further requirements.
|
Legitimate interest
|
Internally only.
|
|
Personal contact information as provided through website forms or at trade shows, or via any other means.
|
General mailing list subscription.
|
Consent
|
Internally only.
|
|
2. Transactional information
|
Transaction details
|
Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery.
|
To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.
|
Contractual fulfilment
|
Internally only.
|
Maximum eight years from the date of the performance of the contract.
|
|
For accounting, accreditation and taxation purposes.
|
Statutory obligation
|
Internally and professional advisers
|
Six months from the date the data subject has input personal information but has not proceeded with a transaction.
|
|
Documentation should any contractual legal claim arise.
|
Legitimate interest
|
Internally and professional advisers
|
Eight years for VAT records from the performance of the contract.
|
|
Payment card data
|
PAN (primary account number), cardholder name, service code, expiration date.
|
To fulfil purchase requests using payment cards.
|
Contractual performance
|
Payment card companies, in line with the PCI DSS (Payment Card Industry Data Security Standard)
|
Only retained while authorisation is pending.
|
|
3. Fulfilment Information
|
Fulfilment data
|
Name, contact and identification details.
|
Exam attendance, exam results, complaints andcertifications.
|
Contractual performance
|
Internally and external examiners, proctors
|
Maximum six years from the date of the performance of the contract.
|
|
Name, address(es), email address, contact details.
|
Actual delivery of products or services, in physical or digital form, that you may have purchased from us.
|
Contractual performance
|
Internally and any third-party logistics or supplier organisationswith which we contract to fulfil these requirements
|
|
Name, address, date of birth, employer, copy of CV, contact title, phone, email, and other business-related information including certificates and CPD (continuing professional development) information.
|
To accredit ATO leaders and trainers that deliver IBITGQ courses and qualifications.
|
Contractual performance
|
Internally only
|
For the duration of the time the subject is in the role of ATO leader and/or trainer.
|
|
4. Security
|
Security information
|
Technical information, as described above, plus any other information that may be required for this purpose.
|
To protect our websites and infrastructure from cyber attack or other threats, and to report and deal with any illegal acts.
|
Legitimate interest
|
Internally, and forensic and other organisations with which we might contract for this purpose
|
Relevant statutes of limitation.
|
|
5. Communications
|
Contact information
|
Names, contact details, identification details.
|
To communicate with you about any issue that you raise with us or that follows from an interaction between us.
|
Legitimate interest
|
Internally and, as necessary, with professional advisers
|
Relevant statutes of limitation.
|
|
6. Product development
|
Survey data
|
Names, contact details, identification details.
|
To develop existing and new products that meet the expectations and requirements of our customers.
|
Consent
|
Internally and, where additional consent is given, for marketing purposes
|
If anonymised for statistical research, this data may be kept indefinitely. Where not anonymised, it will be retained for a maximum of one year.
|
5. Storage of personal data
IBITGQ Corp. is a US-domiciled organisation whose primary office is in United States of America.
- Our website is hosted in the UK and is accessed only by our UK and EU-based staff.
- All personal data that we process in relation to examinations is processed either in the UK or in the EU. No personal data is processed in the USA.
- Our customer relationship management, marketing and accounting systems are either UK-based or, in cases where this is not true, data transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulation or “EU GDPR”) and will if necessary be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA. The UK is currently considered by the EC to provide an acceptable level of data protection.
- We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are in the table in section 4 above.
- IBITGQ manages all personal data in line with our ISO/IEC 17024:2012 accreditation.
6. Security measures
We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our information security management system. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
7. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email servicecentre@ibitgq.org or use the information supplied in the ‘Contact us’ section above. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
-
The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.
-
The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing.
b) The categories of personal data concerned.
c) The recipients to whom the personal data has been disclosed.
d) The retention period or envisioned retention period for that personal data.
e) When personal data has been collected from a third party, the source of the personal data.
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or unreasonable expense (which you may have to meet), we will inform you.
-
The right to rectification
If you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
-
The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
-
The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested.
b) Processing of the personal data is unlawful.
c) We no longer need the personal data for processing, but the personal data is required for part of a legal process.
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
-
The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
-
The right to object
You have the right to object to our processing of your data under one of the following conditions:
a) Processing is based on legitimate interest.
b) Processing is for the purpose of direct marketing.
c) Processing is for the purposes of scientific or historical research.
d) Processing involves automated decision-making and profiling.
8. Complaints
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner. Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the EU.