Last updated: 9 August 2018

The Global Steering Group for Impact Investment (GSG) respects your privacy and is committed to protecting your personal information.

This privacy notice will inform you how we collect and look after your personal information in accordance with the EU General Data Protection Regulation (the GDPR) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE

This privacy notice tells you what to expect when GSG collects and processes your personal information.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

GSG is the controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).

Contact details

If you want to request information about our privacy policy you can email us at realimpact@gsgii.org or send us a letter at:
32 Hampstead High Street
London NW3 1QD
United Kingdom

Changes to this privacy notice

This Privacy Policy may be updated from time to time. The “Last Updated” section at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes that we make to this Privacy Policy will be effective from the date specified at the top of the revised privacy policy. Your use of our services following any such changes indicates that you have accepted them.

Duty to inform us of changes

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.

Third party links

This website includes links to third-party websites. 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 notice of every website you visit.

If you contact us via social media, the personal information you provide will remain on that platform and that platform will be the data controller. We encourage you to read the privacy notice of the relevant platform.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Under the GDPR, we must have a legal basis for processing your personal information. In the situations described in the next section, we process your personal information for one of the legal bases set out below.

  • Legitimate interests*. We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. It is in our interests to ensure that our processes and systems operate effectively and to process information to help us achieve our mission to improve the lives of people in the UK by connecting investment to charities and social enterprises that are creating social change.
  • Consent**. We may process your information where you give us your consent to do so. You have the right to withdraw this consent at any time by contacting us at realimpact@gsgii.org

THE SITUATIONS WHERE WE COLLECT DATA ABOUT YOU, WHAT DATA WE COLLECT AND WHY WE COLLECT IT

  1. Visitors to the GSG website

When someone visits our website, we use a third party service provider, Google Analytics, to collect anonymised, aggregated data about visitors’ use of the website such as where the visitor came from, the browser types and versions, time zone setting and location, and operating system used. We do this to find out things such as the number of visitors to the various parts of the site and to enable us to make the content useful. Further information about how Google uses this information and how you can control the information sent to Google can be found here.

We do not make any attempt to find out the identities of the individuals visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

  1. Mailing lists

We have a mailing list for the GSG newsletter and for periodic announcements about events or initiatives. We collect your contact details to sign you up to the mailing list. Once you have signed up we will send you newsletters and information on relevant GSG initiatives. We may also use information you provide us with on your areas of interest to help us send you material which is most relevant to you.

You can opt out of the mailing list by following the “unsubscribe” link at the bottom of each email we send you.

We use a third party service provider, MailChimp, to deliver our newsletters. For more information, please see Mailchimp’s privacy policy and cookie statement.

  1. Job applicants

If you apply for a job at GSG, we will ask for certain information in order to progress your application, assess your suitability for the role you have applied for and fulfil legal or regulatory requirements. The information will only be shared with the relevant hiring manager(s).

We do encourage speculative applications. If you send us a speculative application, or apply for an open position, we will ask for your contact details to contact you about your application. We will also ask for your CV and a covering letter to assess your suitability for the role. If you apply to us for a job through a recruitment agency we will receive your contact details, CV and covering letter from them.

If you are shortlisted for a role, we will ask for you to provide proof of your identify so we can check that you have the right to work in the UK. As part of the assessment process you may be asked to attend an interview, where we might take interview notes, and to complete tests.

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. We process this information to seek assurance as to your trustworthiness, integrity and reliability. You will therefore be asked to provide proof of your qualifications and referee contact details. In order to set up your employee record you will also be asked to provide bank details and emergency contact details. You may also be asked to declare any business or other interests you have.

You will be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

[Given the nature of our business, for certain roles, we require a candidate who is made a conditional offer of employment to complete a fitness and propriety questionnaire and to disclose their criminal record history before starting employment and annually during employment. In some cases, we are required to carry out these checks (for example, for regulated roles); in all cases we carry out the checks in accordance with applicable law. If we need to conduct these checks, you will be provided with further information prior to us doing so. ]

  1. Interactions with GSG employees*

If you meet an employee of GSG, for example, at an event, and give them your contact details they will keep this information in order to contact you in the future about topics which might be of interest to you. They will also share this information with other staff members at GSG and occasionally, they will pass it on to third parties who they think you would be interested to hear from. Similarly, we will sometimes receive your contact details from a third party who thinks you would be interested in hearing from us.

  1. Third party data processors

We use third party service providers for parts of our website, IT systems and when we communicate digitally with you. Sometimes they will process the personal information which you provide us with.

TRANSFERRING DATA TO OTHER COUNTRIES

We, or our third party providers, may transfer the personal information we collect about you to countries outside the EU, on the basis that anyone to whom we pass it protects it in accordance with applicable laws. We are in the process of ensuring that, in the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), your personal information receives an adequate level of protection in a way that is consistent with and which respects the EU and UK laws. Please contact us at realimpact@gsgii.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at realimpact@gsgii.org.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at realimpact@gsgii.org.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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.

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.

YOUR RIGHTS

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

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 may 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 may 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.

COMPLAINTS OR QUERIES

If you have any questions about this Privacy Notice, or want to submit a written complaint about how we handle your personal information, please contact us via realimpact@gsgii.org. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.