1. About this privacy policy
This privacy policy explains how the All-Party Parliamentary Group for the Southeast and Gatwick Diamond Growth Gateway (“the APPG”, “we”, “us” or “our”) collects, uses and protects personal information.
It applies when you:
- visit our website;
- contact the APPG or its Secretariat;
- complete an enquiry, registration or participation form;
- attend or express an interest in an APPG event;
- subscribe to receive news or other communications;
- discuss partnership, sponsorship or involvement in the APPG’s programme; or
- otherwise provide personal information to us.
The APPG is an informal cross-party group of Parliamentarians. It is not a government department or an official body of the House of Commons or House of Lords.
2. Who is responsible for your information?
The organisation responsible for deciding how personal information covered by this policy is used is:
All-Party Parliamentary Group for the Southeast and Gatwick Diamond Growth Gateway
The APPG’s Secretariat is provided by:
Questions about this policy or the use of your personal information should be sent to the Secretariat using the contact details above.
Silverstone Communications
Telephone: 0203 196 6587
Email: hello@silverstonecommunications.co.uk
Address: Projects, Nile House, Nile Street,Brighton BN1 1HW
Depending on the circumstances, an organisation supporting an event, inquiry, project or campaign may be independently responsible for personal information it collects. Where this applies, you should also be given access to that organisation’s privacy information.
3. The information we collect
We may collect and use the following categories of personal information.
Information you provide to us
This may include:
- your name;
- job title and organisation;
- postal address;
- email address;
- telephone number;
- professional interests;
- details of an enquiry or message;
- your preferences about receiving communications;
- event registration and attendance information;
- accessibility, dietary or other event requirements;
- information supplied as part of a consultation, inquiry or policy submission;
- correspondence between you and the APPG or its Secretariat; and
- photographs, video recordings or quotations connected with APPG events and activities.
Please avoid including sensitive or confidential personal information in an enquiry unless it is relevant and necessary.
Information collected automatically
When you use our website, we or our service providers may collect technical information such as:
- your IP address;
- browser and device type;
- operating system;
- pages visited;
- referring website;
- approximate location;
- date and time of access; and
- information collected through cookies or similar technologies.
Further information is provided in the Cookies and website technologies section below.
Information obtained from other sources
We may receive professional contact information from:
- publicly available sources, including organisational websites and professional directories;
- Parliamentarians and their offices;
- APPG partners and stakeholders;
- event organisers;
- local authorities, universities, business organisations and public bodies;
- professional networking platforms; and
- people who recommend that we contact you because of your professional role or relevant expertise.
This will normally be limited to information connected with your professional or public role.
4. How we use personal information
We may use personal information to:
- respond to enquiries and correspondence;
- administer the APPG and support its programme of work;
- arrange meetings, roundtables, visits and other events;
- manage invitations, registrations and attendance;
- communicate with Parliamentarians, stakeholders, partners and interested organisations;
- consider partnership, sponsorship and participation opportunities;
- conduct consultations, calls for evidence and policy inquiries;
- prepare reports, briefings, publications and meeting records;
- provide news and updates where permitted;
- maintain appropriate records of the APPG’s activities;
- publish information about speakers, contributors, partners and events;
- promote the work of the APPG;
- improve the website and understand how it is used;
- maintain the security and integrity of our website and systems;
- comply with applicable legal, regulatory and Parliamentary requirements; and
- establish, exercise or defend legal rights.
We will not use your personal information for purposes that are incompatible with those described in this policy without first informing you where required.
5. Our lawful bases for using your information
UK data protection law requires us to identify a lawful basis for each use of personal information.
Depending on the circumstances, we may rely on:
Legitimate interests
We may process information where it is necessary for the legitimate interests of operating and supporting the APPG, including:
- engaging with organisations and individuals whose work is relevant to the APPG;
- organising events and policy discussions;
- responding to enquiries;
- maintaining stakeholder relationships;
- communicating about the APPG’s work;
- promoting regional economic and social priorities;
- maintaining appropriate administrative and security records; and
- improving the website and our communications.
We consider whether these interests are outweighed by your rights and interests before relying on this basis.
Consent
We may rely on your consent where you:
- choose to receive certain electronic communications;
- accept non-essential website cookies;
- agree to the use of a photograph, quotation or recording where consent is appropriate; or
- voluntarily provide particular information for a stated purpose.
You may withdraw your consent at any time. Withdrawing consent will not affect processing that took place before it was withdrawn.
Contract
We may process information where it is necessary to enter into or fulfil an agreement with you or your organisation, such as an event, partnership, sponsorship or supplier arrangement.
Legal obligation
We may process information where necessary to meet a legal, regulatory, financial, safeguarding or Parliamentary obligation.
Public task
In limited circumstances, Parliamentarians or other public bodies involved in the APPG may process information where this is necessary for a task carried out in the public interest or in the exercise of official authority.
6. Special-category and sensitive information
Some information receives additional protection under data protection law. This can include information about health, ethnicity, religion, political opinions or trade-union membership.
The APPG is a political forum, and some people’s political affiliations or opinions may be apparent from their public or professional roles. We will only process special-category information where this is necessary and where an additional lawful condition applies.
For example, we may use information about accessibility or dietary requirements to make suitable arrangements for an event. We will restrict access to this information and retain it only for as long as it is required.
Contributions to APPG discussions, inquiries or consultations may also reveal political opinions or other sensitive information. You should only provide information that is relevant to the matter being considered.
7. Events, photography and recordings
APPG events may be photographed, filmed or recorded.
Where appropriate, we will tell attendees in advance or display notices at the event. Photographs, recordings and attributed comments may be used in:
- APPG reports and publications;
- news articles;
- the APPG website;
- social-media channels;
- presentations; and
- communications promoting the APPG’s work.
Where we rely on legitimate interests, you may object to the use of an identifiable image or recording by contacting the Secretariat. We will consider your request, although removal may not always be possible where material has already been published, distributed or forms part of an official record.
8. Consultations, inquiries and submissions
When you respond to a consultation, inquiry or call for evidence, we may collect your name, role, organisation, contact details and submission.
Unless we state otherwise at the point of collection:
- submissions may be reviewed by the APPG, its Secretariat, relevant Parliamentarians and advisers;
- evidence may be quoted, summarised or referred to in APPG reports and briefings;
- your name, job title and organisation may be published alongside your contribution; and
- contact details will not normally be published.
Please clearly identify any information that you consider confidential. Marking information as confidential does not guarantee that it can be kept confidential in every circumstance, particularly where disclosure is required by law or Parliamentary rules.
We may contact you to clarify your submission or discuss the matters it raises.
9. Who we share information with
We may share personal information where necessary with:
- APPG officers and members;
- the APPG Secretariat;
- employees, contractors and professional advisers supporting the APPG;
- event venues, organisers and delivery partners;
- organisations participating in or supporting a relevant APPG project;
- website, hosting, email, form, database and IT service providers;
- photography, video, design, printing and communications suppliers;
- Parliament, government departments, local authorities or public bodies where appropriate;
- regulators, law-enforcement bodies, courts or other authorities where disclosure is legally required; and
- other parties where you have asked or authorised us to share the information.
Service providers acting on our behalf are expected to use personal information only for the services they provide and to protect it appropriately.
We do not sell personal information.
We will not provide your personal information to political parties for their separate campaigning or marketing purposes unless you have specifically agreed to this or another lawful basis clearly applies.
10. Email communications
We may send you communications relating to:
- an enquiry you have made;
- an event for which you have registered;
- a consultation or project in which you are participating;
- your organisation’s involvement with the APPG;
- a subject relevant to your professional responsibilities; or
- APPG news and future activities.
Where consent is required for electronic marketing, we will ask for it.
You can unsubscribe from optional communications by using the unsubscribe link in the email, where provided, or by contacting the Secretariat.
Administrative communications about an event, enquiry, agreement or active relationship may still be sent where necessary.
11. Cookies and website technologies
Cookies are small files placed on your device when you visit a website.
Our website may use:
Strictly necessary cookies
These are required for the website to operate, maintain security, remember privacy choices or provide a service you have requested.
Analytics cookies
These help us understand how visitors use the website, such as which pages are visited and whether users encounter technical problems.
Embedded and third-party content
Pages may contain forms, maps, videos, social-media features or other content supplied by third parties. These providers may collect information about your device or place cookies when the content is loaded.
Non-essential cookies and similar technologies will only be used where the required permission has been obtained.
You can manage your choices through the website’s cookie-control facility and through your browser settings. Blocking some technologies may affect how parts of the website work.
For full accuracy, the website should also provide a separate cookie notice listing the specific cookies and services currently in use.
12. Links to other websites
Our website may link to websites operated by Parliament, partner organisations, public bodies, social-media platforms and other third parties.
We are not responsible for how those organisations collect or use personal information. You should read their own privacy policies before providing information to them.
13. International transfers
Some of our website, email, analytics, form or IT providers may process information outside the United Kingdom.
Where personal information is transferred internationally, we will seek to ensure that an appropriate legal safeguard is in place. This may include:
- transfer to a country recognised as providing an adequate level of protection;
- use of approved contractual protections;
- use of the UK International Data Transfer Agreement or UK Addendum; or
- another lawful transfer mechanism.
You may contact the Secretariat for further information about the safeguards relevant to your information.
14. How long we retain information
We retain personal information only for as long as it is reasonably needed for the purpose for which it was collected, including legal, administrative, reporting and archival requirements.
Typical retention periods may include:
- General enquiries: normally up to two years after the enquiry is resolved.
- Event registrations: normally up to two years after the event, unless the information forms part of an ongoing stakeholder relationship.
- Accessibility and dietary information: deleted as soon as reasonably practicable after the relevant event.
- Mailing-list information: until you unsubscribe, withdraw consent or the information is found to be no longer current.
- Partnership and contractual records: normally for the duration of the relationship and up to six years afterwards.
- Consultation and inquiry submissions: retained for as long as needed to support the relevant work, publication and public record.
- Meeting records, reports, photographs and published material: potentially retained indefinitely where they form part of the historical or public record of the APPG.
- Technical and security records: retained for a period appropriate to security, troubleshooting and fraud prevention.
We may retain limited information after an objection or unsubscribe request to ensure that your preference continues to be respected.
15. How we protect information
We take reasonable organisational and technical steps to protect personal information against:
- unauthorised access;
- loss or destruction;
- misuse;
- alteration; and
- inappropriate disclosure.
These measures may include access controls, secure systems, staff and contractor confidentiality requirements, backups and supplier due diligence.
No internet-based system is completely secure. You should avoid sending highly sensitive information through an ordinary website form or unencrypted email unless this is necessary.
16. Your data-protection rights
Depending on the circumstances and the lawful basis being used, you may have the right to:
- ask whether we hold personal information about you;
- obtain a copy of your personal information;
- have inaccurate or incomplete information corrected;
- ask us to delete your information;
- ask us to restrict how your information is used;
- object to the use of your information;
- receive certain information in a portable format;
- withdraw consent at any time; and
- complain to the Information Commissioner’s Office.
These rights are not absolute, and exemptions may apply.
Your right to object
You have the right to object at any time to the use of your personal information for direct marketing.
You may also object where we rely on legitimate interests. Where you do so, we will stop the relevant processing unless we can demonstrate compelling legitimate grounds to continue or the information is needed for legal claims.
To exercise a right, contact the Secretariat using the details in this policy. We may need to ask for information to confirm your identity.
We will normally respond within one month, although the law permits additional time for particularly complex requests.
17. Automated decision-making
We do not currently make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.
18. Children’s information
The website and APPG’s general activities are not directed at children.
Where an APPG activity involves young people, appropriate information and safeguards will be provided for that particular activity. Where necessary, permission will be obtained from a parent, guardian, school or responsible organisation.
19. Complaints
Please contact the Secretariat first if you have concerns about how your personal information has been handled. We will try to investigate and resolve the matter.
You also have the right to complain to the UK data-protection regulator:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk
20. Changes to this privacy policy
We may update this policy when our activities, website, suppliers or legal obligations change.
The latest version will be published on the website with the date it was last updated. Where a change materially affects how we use information already collected, we will take reasonable steps to bring it to the attention of the people affected.