TPI Privacy Policy

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  • Privacy Policy


    The Property Institute (“TPI”) incorporates the Institute of Residential Property
    Management Limited (‘IRPM’) and the Association of Residential Managing Agents Limited (“ARMA”).


    TPI recognises that data protection is the cornerstone of its operations and is
    committed to processing information about individuals in ways that comply with its
    obligations under the General Data Protection Regulation (as retained from the EU law version)(“UK GDPR”) and the Data Protection Act 2018 (“DPA”).
    As a membership organisation and the leading professional body for the residential management sector, it is necessary for us to process information relating to individuals, including our individual members. Whenever we process the personal data of individuals, we will ensure that we are clear with those individuals about what we do (or may do) with their information.


    This privacy policy explains what personal data (or “information”) we hold about
    individuals and contains important information on who we are, how and why we
    collect, store, use and share personal information, individuals’ rights in relation to
    their personal information and on how to contact us and supervisory authorities in
    the event you have a complaint.


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

    Who we are
    TPI collects, uses and is responsible for certain personal information about
    individuals. When we do so we are regulated under the UK GDPR and the Data
    Protection Act 2018


    and we are responsible as the ‘controller’ of that personal information for the
    purposes of those laws.

    In this privacy policy, references to “we” or “us” mean TPI.


    We are a company registered in England and Wales with company number
    13753239 and the registered address 20 Eversley Road, Bexhill-on-Sea, East
    Sussex TN40 1HE.


    We operate the
    websites www.irpm.org.uk, www.irpmlearninghub.org.uk and www.arma.org.uk.
    We have a compliance officer who is responsible for overseeing questions in
    relation to this privacy policy. If you have any questions about this privacy policy,
    including any requests to exercise Your rights, please contact the compliance
    officer using the details set out below.

    Contacting our compliance officer
    If you have any questions about this privacy policy or our privacy practices,
    including a request to exercise any of your rights, please contact our Data
    Protection Officer in the following ways:


    • By post: The Property Inst. Limited
    o 3rd Floor, 2–4 St George's Road, Wimbledon, London SW19 4DP; or
    o Suite 4 & 5, 71 Gloucester Place, W1U 8JW
    • By email: [email protected]


    DATA PROTECTION PRINCIPLES
    We will comply with the data protection principles set down by the UK GDPR when gathering and using personal information.
    The personal information we collect and use in the performance of our role, we
    collect and process information relating to individuals.
    The information we collect (and how we handle that information) differs depending
    on who the individual is, and why we are collecting their information.

    Our services and website(s) are not intended for children and we do not knowingly collect any personal information relating to children.

    THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO OUR
    MEMBERS
    TPI will collect and use personal information relating to Professional Members,
    Member Firms, associates, partners and TPI Network Members. Members in this
    context includes all levels of hierarchy of membership, and those undertaking
    professional qualification via our training programmes and apprenticeships. It also
    includes any applicants for membership and/or training and apprenticeships.
    Our collection and use of this information is necessary for us to meet our key
    objectives, which include:

    • Raising standards in the residential property management sector
    • Providing individuals with independent accreditation of their professional
    skills
    • Providing a career development path for individuals
    • Aiding in the process of recruiting new entrants to the sector
    • Assisting practitioners in assessing job applicant capabilities
    • Providing opportunities for Continuing Professional Development
    • Improving the standing of the sector in the eyes of the public
    • Provide our members, associates, partners and TPI Network Members with
    services and information they expect to receive from their professional body
    • Improve and develop our services and performance as the leading
    professional body in the residential management sector
    • Develop and provide products and services, either on our own or in
    conjunction with third parties (for example the provision of training courses
    and other initiatives and member benefits)
    • Meet our regulatory obligations

    The information we collect Professional Members
    In relation to Professional Members we may collect the following types of
    information:


    • Name, date of birth, address(es) – work and home, email address(es),
    telephone number(s), employer (if provided), and other contact details
    • If provided: other qualifications, experience, number of units managed, how
    referred to TPI
    • Financial data, including bank account and payment card details and details
    of your payments to/from the TPI for courses, training, exams, events, and
    other products/services
    • Details of any enquiry you have made, or any report you have submitted to us
    • Exam results, CPD activities, notes of important communications between
    you and us
    • Profile data relating to your use of our website(s) including usernames and
    passwords, your interests, preferences, feedback and survey responses
    • Technical data including your internet protocol address, login data, browser
    type and version, time zone setting and location, browser plug-in types and
    versions, operating system and platform and other technology on the
    devices you may use to access the website(s)
    • Marketing and communications data including your preferences in receiving
    marketing from us and our third parties and your communication
    preferences


    In limited circumstances, we may collect limited special category data including
    details about your race or ethnicity, religion and health. We will only collect this
    information where you choose to provide it to us, and it will be used only to ensure we are able to make appropriate adjustments for you at events, courses or examinations that you may wish to attend and in an anonymised form as part of our use of aggregated data (please see below for further information).
    In addition to receiving information directly from our members, from time to time
    we also receive information about our members from third parties, for example,
    their employers.


    How we collect it
    We use different methods to collect information from and about you, including
    through:


    • Direct interactions: You may give us information by filling in forms or by
    corresponding with us by post, phone, email or otherwise. This includes
    personal information you provide when you:


    o apply for membership
    o apply for or purchase our products or services
    o create an account on our website(s)
    o subscribe to our services or publications
    o request marketing to be sent to you
    o enter a competition, promotion or survey
    o give us feedback or contact us


    • Automated technologies or interactions: As you interact with our website(s),
    we will automatically collect technical data about your device, browsing
    actions and patterns. We may collect this information by using cookies,
    server logs and other similar technologies. Please see our Cookie Policy for
    further details.


    • Third parties or publicly available sources: We will receive personal
    information about you from various third parties and public sources as set
    out below:


    o technical information from analytics providers such as Google, based
    outside the UK and outside the EU
    o contact details, financial and transactional data from providers of
    technical, payment and delivery services such as:


    ▪ DotDigital based outside the UK and outside the EU
    ▪ EventBrite based outside the UK and outside the EU
    ▪ SurveyMonkey based outside the UK and outside the EU
    ▪ Moodle based outside the UK and outside the EU


    o information from your employer or former employer relating to your
    employment status, qualifications and experience
    o information relating to your identity and contact details from publicly
    available sources such as Companies House and the Electoral
    Register based in the UK.

    Why we collect it

    The collection of this information is required from our members so that we can:


    • Provide our members with services they expect to receive from us, including
    newsletters, technical updates, details of our training and events
    • Improve and develop our services and performance as an organisation
    • Develop and provide products and services, including training and events
    • Meet our regulatory obligations.


    Member Firms, Associates, Partners and TPI Network Members


    TPI will collect personal information from its Members, Associates, Partners and TPI Network Members. This includes applicants for Members, Associates, Partners and TPI Network Members status.


    The information we collect

    We may collect the following types of information:


    • Name, address, email address, telephone number(s) and other contact
    details
    • Your company’s name, your position in the company, the company’s address
    and your company email address and telephone number
    • Information required to provide you with a service and details of our services
    that you have used (for example, attendance on our training courses)
    • Details of any enquiry you have made to TPI.


    Why we collect it


    The collection of this information is required to enable us to perform our role as a
    professional body, which helps us to:


    • Provide our Members, Associates, Partners and TPI Network Members with
    services and information they expect to receive from their professional body
    • Improve and develop our services and performance as the leading
    professional body in the residential management sector
    • Develop and provide products and services, either on our own or in
    conjunction with third parties (for example the provision of training courses
    and other initiatives and member benefits)
    • Meet our regulatory obligations


    We also collect personal information about individuals from their company directly.


    Who we share it with


    From time to time, we may share your personal information with the following
    categories of recipients:


    • Communication platforms and services (including
    Mailchimp https://mailchimp.com/legal/privacy/)
    • Survey platforms and services (including Survey
    Monkey https://www.surveymonkey.com/mp/gdpr/?ut_source=footer)
    • IT and software support (including
    Basecamp https://basecamp.com/about/policies)
    • Marketing platforms and services
    • Financial services, including Accountants
    • Member's employer (where the employer is paying the Member's fees and
    the Member is linked to the employer's account) in connection with the
    payment of the Member's membership or services fees, or to pass on details
    of a Member's CPD history, exam results, training attendances or details of a
    Member's membership status.
    • Adjudication Scheme, CEDR, TPI Board, TPI Consultants, TPI Committees
    and TPI legal helpline.
    • Auditors
    • Course tutors


    Some of those third party recipients may be based outside the United Kingdom —
    for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK’.


    In relation to Professional Members we will use limited personal information
    (including your name, employer, the city or location in which you are employed and your job title or seniority) as part of our publicly accessible directory of Members.
    The directory can be accessed through our website(s).


    We will share personal information with law enforcement or other authorities if
    required by applicable law.


    We will not share your personal information with any other third party.


    Where your personal information may be held


    Information may be held at our offices, and third party agencies, service providers, representatives and agents as described above.


    We have security measures in place to seek to ensure that there is appropriate
    security for information we hold.


    How long your personal information will be kept
    We will retain your personal information for no longer than is reasonably necessary
    for the purposes we collected it for, including for the purposes of satisfying any
    legal, regulatory, tax, accounting or reporting requirements.

    For Partners and TPI Network Members we will retain information until membership ceases.


    To determine the appropriate retention period for personal data, we consider the
    amount, nature and sensitivity of the personal information, the potential risk of
    harm from unauthorised use or disclosure of your personal information, the
    purposes for which we process your personal data and whether we can achieve
    those purposes through other means, and the applicable legal, regulatory, tax,
    accounting or other requirements.


    Details of retention periods for different aspects of your personal data are available on request from us by contacting us.


    Our lawful basis
    We will only use your personal information when the law allows us to. Most
    commonly, we will use your personal data in the following circumstances:


    • Our use of your personal data is necessary for us to carry out a contract that
    we have with you, as our member.
    • Where it is necessary for our legitimate interests (or those of a third party)
    and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal obligation


    Generally, we do not rely on consent as a lawful basis for processing your personal information but there are certain circumstances where we will seek your consent to the processing of your personal information, such as where we carry out direct marketing activities. We have set out below, in a table format, a description of the ways we plan to use your personal information and which lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


    Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific lawful basis we are relying on to process your personal information where more than one ground has been set out in the table below.

    THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO ATTENDEES AT OUR EVENTS AND PARTICIPANTS IN EXAMINATIONS OR COURSES
    TPI will collect personal information from individuals who attend TPI hosted events, including our annual seminar, conference, awards and regional roadshows.


    The information we collect
    We may collect the following types of information:


    • Name, address, email address, telephone number(s) and other contact
    details
    • Your company’s name, your position in the company, the company’s address
    and your company email address and telephone number
    • Information required to provide you with a service and details of our services
    that you have used (for example, attendance at our event)
    • Details of other qualifications, experience, number of units managed, how
    you were referred to TPI
    • Financial data, including bank account and payment card details and details
    of your payments to/from the TPI for courses, training, exams, events, and
    other products/services
    • Details of any enquiry you have made, or any report you have submitted to us
    • Exam or course entries, results, CPD activities, notes of important
    communications between you and us
    • Profile data relating to your use of parts of our website(s) relating to virtual
    events, courses and examinations including usernames and passwords,
    preferences, feedback and survey responses
    • Technical data including your internet protocol address, login data, browser
    type and version, time zone setting and location, browser plug-in types and
    versions, operating system and platform and other technology on the
    devices you may use to access the website(s)
    • Marketing and communications data including your preferences in receiving
    marketing from us and our third parties and your communication
    preferences


    In limited circumstances, we may collect limited special category data including
    details about your race or ethnicity, religion and health. We will only collect this
    information where you choose to provide it to us, and it will be used only to ensure we are able to make appropriate adjustments for you at events, courses or examinations that you may wish to attend and in an anonymised form as part of our use of aggregated data (please see below for further information).


    How we collect it


    We use different methods to collect information from and about you, including
    through:


    • Direct interactions: You may give us information by filling in forms or by
    corresponding with us by post, phone, email or otherwise. This includes
    personal information you provide when you:


    o book attendance at an event, course or examination
    o attend or participate in an event, course or examination
    o apply for or purchase our products or services
    o subscribe to our services or publications
    o request marketing to be sent to you
    o enter a competition, promotion or survey
    o give us feedback or contact us


    • From your employer directly
    • Automated technologies or interactions: If you interact with our website(s) as part of booking or attending any event, course or examination, we will
    automatically collect technical data about your device, browsing actions
    and patterns. We may collect this information by using cookies, server logs
    and other similar technologies. Please see our Cookie Policy for further
    details.
    • Third parties or publicly available sources: We will receive personal
    information about you from various third parties and public sources as set
    out below:


    o technical information from analytics providers such as Google, based
    outside the UK and outside the EU
    o contact details, financial and transactional data from providers of
    technical, payment and delivery services such as


    ▪ DotDigital based outside the UK and outside the EU
    ▪ EventBrite based outside the UK and outside the EU
    ▪ SurveyMonkey based outside the UK and outside the EU
    ▪ Moodle based outside the UK and outside the EU


    o information from your employer or former employer relating to your
    employment status, qualifications and experience
    o information relating to your identity and contact details from publicly
    available sources such as Companies House and the Electoral
    Register based in the UK.


    Why we collect it


    The collection of this information is required so that we can host the events,
    courses and examinations, and it helps us to:


    • Provide the events, courses and examinations
    • Improve and develop our services and performance
    • Develop and provide products and services, either on our own or in
    conjunction with third parties
    • Meet our regulatory obligations


    We also collect personal information about individuals from their company directly.


    Who we share it with


    From time to time, TPI may share your personal information with the following
    categories of recipients:


    • Website and IT support (including
    Basecamp https://basecamp.com/about/policies)
    • Marketing platforms and services (including
    Mailchimp https://mailchimp.com/legal/privacy/)
    • Survey platforms and services (including Survey
    Monkey https://www.surveymonkey.com/mp/gdpr/?ut_source=footer)
    • Event sponsors
    • TPI Board and Committees
    • Third parties responsible for providing services at our events
    • Providers of training courses or examinations, including independent
    examination moderators
    • Member's employer (where the employer is paying the Member's fees and
    the Member is linked to the employer's account) in connection with the
    payment of the Member's membership or services fees, or to pass on details
    of a Member's CPD history, exam results, training attendances or details of a
    Member's Some of those third party recipients may be based outside the
    United Kingdom — for further information including on how we safeguard
    your personal data when this occurs, see ‘Transfer of your information out of
    the UK.


    We will share personal information with law enforcement or other authorities if
    required by applicable law.


    We will not share your personal information with any other third party.


    Photography and video recordings at our events


    A photographer may be present at TPI events and photographs may be used for
    future marketing. If you would prefer your image not to be used please notify an TPI member of staff on the day of the event.


    Where your personal information may be held

    Information may be held at our offices, and third party agencies, service providers, representatives and agents as described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold.


    How long your personal information will be kept
    We will retain your personal information for no longer than is reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the
    amount, nature and sensitivity of the personal information, the potential risk of
    harm from unauthorised use or disclosure of your personal information, the
    purposes for which we process your personal data and whether we can achieve
    those purposes through other means, and the applicable legal, regulatory, tax,
    accounting or other requirements.

    Details of retention periods for different aspects of your personal data are available on request from us by contacting us.


    Our lawful basis
    We will only use your personal information when the law allows us to. Most
    commonly, we will use your personal data in the following circumstances:


    • Our use of your personal data is necessary for us to carry out a contract that
    we have with you, as an attendee or participant in an event, course or
    examination.
    • Where it is necessary for our legitimate interests (or those of a third party)
    and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal obligation


    It is necessary for us to process the personal information so that we can host those events. Our processing activities are a targeted and proportionate way of
    achieving this. Attendees reasonably expect that we will process their personal
    information in this manner.


    Generally, we do not rely on consent as a lawful basis for processing your personal information but there are certain circumstances where we will seek your consent to the processing of your personal information, such as where we carry out direct marketing activities.
    We have set out below, in a table format, a description of the ways we plan to use
    your personal information and which lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific lawful basis we are relying on to process your personal information where more than one ground has been set out in the table below.

    THE PERSONAL INFORMATION WE COLECT AND USE RELATING TO RMC/RTM DIRECTORS PORTAL
    TPI will collect personal information from RMC/RTM Directors who have signed up to use our Directors portal. This includes applicants for RMC/RTM Directors
    membership category status.


    The information we collect
    We may collect the following types of information:
    • Name, address, email address, telephone number(s) and other contact
    details
    • Your company’s name, your position in the company, the company’s address
    and your company email address and telephone number
    • Information required to provide you with a service and details of our services
    that you have used (for example, attendance on our training courses)
    • Details of any enquiry you have made to TPI


    Why we collect it
    The collection of this information is required to enable us to perform our role as a
    professional body, which helps us to:


    • Provide RMC/RTM Directors with services and information they expect to
    receive as part of this membership category
    • Improve and develop our services and performance as the leading
    professional body in the residential management sector
    • Develop and provide products and services, either on our own or in
    conjunction with third parties (for example the provision of training courses
    and other initiatives and member benefits)


    We also collect personal information about individuals from their company directly
    and/or may be provided this information by member organisations where their
    RMC/RTM Directors have given agreed to be signed up to the Directors portal to
    enable us to contact them and arrange this.


    Who we share it with
    From time to time, TPI may share your personal information with the following
    categories of recipients:


    • Adjudication Scheme, CEDR, TPI Board, TPI Consultants, and TPI
    Committees.
    • Auditors
    • Course tutors
    • Accountants
    • Website and IT support (including
    Basecamp https://basecamp.com/about/policies)
    • Marketing platforms and services (including
    Mailchimp https://mailchimp.com/legal/privacy/)
    • Survey platforms and services (including Survey
    Monkey https://www.surveymonkey.com/mp/gdpr/?ut_source=footer)


    Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.


    We will share personal information with law enforcement or other authorities if
    required by applicable law.


    We will not share your personal information with any other third party.

    Where your personal information may be held


    Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.


    We have security measures in place to seek to ensure that there is appropriate
    security for information we hold.


    How long your personal information will be kept
    We will retain information relating to RMC/RTM Directors until membership ceases.


    Our lawful basis
    We rely on legitimate interests as our lawful basis for processing the personal
    information relating to RMC/RTM Directors membership category.


    It is necessary for us to process the personal information we have described so that we can perform our role as a professional body. Our processing activities are a targeted and proportionate way of achieving this. RMC/RTM Directors reasonably expect that we will process their personal information in this manner.

    THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO THIRD PARTIES
    TPI will collect personal information from third parties, including members of the
    general public who contact us.


    The information we collect
    We may collect the following types of information:


    • Name, address, email address, telephone number(s) and other contact
    details
    • Your company’s name, your position in the company, the company’s address
    and your company email address and telephone number
    • Details of any enquiry you have made to the TPI (for example, complaints
    raised)


    How we collect it
    We use different methods to collect information from and about you, including
    through:
    • Direct interactions: You may give us information by filling in forms or by
    corresponding with us by post, phone, email or otherwise. This includes
    personal information you provide when you:


    o apply for a job or contact another company through our jobs pages
    o agree to provide us with any products or services
    o apply for or purchase our products or services
    o create an account on our website(s)
    o subscribe to our services or publications
    o request marketing to be sent to you
    o enter a competition, promotion or survey
    o give us feedback or contact us


    • Automated technologies or interactions: As you interact with our website(s), we will automatically collect technical data about your device, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
    • Third parties or publicly available sources: We will receive personal
    information about you from various third parties and public sources as set
    out below:


    o technical information from analytics providers such as Google, based
    outside the UK and outside EU
    o contact details, financial and transactional data from providers of
    technical, payment and delivery services such as


    ▪ DotDigital based outside the UK and outside the EU
    ▪ EventBrite based outside the UK and outside the EU
    ▪ SurveyMonkey based outside the UK and outside the EU
    ▪ Moodle based outside the UK and outside the EU


    o information from your employer or former employer relating to your
    employment status, qualifications and experience
    o information relating to your identity and contact details from publicly
    available sources such as Companies House and the Electoral
    Register based in the UK.

    Why we collect it

    The collection of this information helps us to:


    • Provide our members, associates, partners and ARM Network Members with
    services they expect to receive from us
    • Improve and develop our services and performance
    • Meet our key objectives
    • Meet our regulatory obligations
    Who we share it with
    From time to time, we may share your personal information with the following
    categories of recipients:
    • Companies who are advertising jobs which you have applied for through our
    website(s)
    • Website and IT support (including
    Basecamp https://basecamp.com/about/policies)
    • Marketing platforms and services (including
    Mailchimp https://mailchimp.com/legal/privacy/)
    • Survey platforms and services (including Survey
    Monkey https://www.surveymonkey.com/mp/gdpr/?ut_source=footer)
    • Adjudication Scheme, CEDR, TPI Board, TPI Consultants and TPI
    Committees.
    • Auditors


    Some of those third-party recipients may be based outside the European
    Economic Area — for further information including on how we safeguard your
    personal data when this occurs, see ‘Transfer of your information out of the EEA’.


    We will share personal information with law enforcement or other authorities if
    required by applicable law.


    We will not share your personal information with any other third party.


    Where your personal information may be held
    Information may be held at our offices, and third party agencies, service providers, representatives and agents as described above.


    We have security measures in place to seek to ensure that there is appropriate
    security for information we hold.


    How long your personal information will be kept
    We will retain your personal information for no longer than is reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.


    To determine the appropriate retention period for personal data, we consider the
    amount, nature and sensitivity of the personal information, the potential risk of
    harm from 

    unauthorised use or disclosure of your personal information, the purposes for
    which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    Details of retention periods for different aspects of your personal data are available on request from us by contacting us.


    Our lawful basis
    We will only use your personal information when the law allows us to. Most
    commonly, we will use your personal data in the following circumstances:


    • Our use of your personal data is necessary for us to carry out a contract that
    we have with you.
    • Where it is necessary for our legitimate interests (or those of a third party)
    and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal obligation


    It is necessary for us to process the personal information we have described so that we can perform our role as a member organisation. Our processing activities are a targeted and proportionate way of achieving this.


    Generally, we do not rely on consent as a lawful basis for processing your personal information but there are certain circumstances where we will seek your consent to the processing of your personal information, such as where we carry out direct marketing activities.


    We have set out below, in a table format, a description of the ways we plan to use
    your personal information and which lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


    Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific lawful basis we are relying on to process your personal information where more than one ground has been set out in the table below.

    FURTHER INFORMATION ABOUT HOW WE MAY USE YOUR PERSONAL
    INFORMATION


    Direct marketing
    We strive to provide you with choices regarding certain uses of your personal
    information, particularly around marketing and advertising.
    We may use your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.


    You will receive marketing communications from us if:


    • you have requested information from us or purchased products or services
    from us and you have not opted out of receiving that marketing; or
    • you have expressly consented to receiving marketing from us.


    We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.


    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by
    contacting us at [email protected] at any time.


    Where you opt out of receiving marketing messages, this will not apply to
    information provided to us as a result of a purchase of products or services,
    membership or other transactions.


    If you fail to provide information
    Where we need to collect information by law, or under the terms of a contract we
    have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


    Aggregated information
    We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your personal information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect personal information so that it can directly or indirectly identify you, we treat the combined information as personal data which will be used in accordance with this privacy policy.


    Links to third party websites
    Our website(s) may include links to third-party websites, plug-ins and applications. 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 any privacy statements on such. When you leave our website(s), we encourage you to read the privacy policy of every website you visit.


    Transfer of your information out of the UK
    We may transfer your personal information to locations outside the UK including
    countries within the European Economic Area and other countries outside the
    European Economic Area, including the United States of America.


    TPI is satisfied that any transfer of your personal data to platforms outside of the UK has adequate levels of data protection for your personal data, through one of the following safeguards:


    • we will only transfer personal information to countries that have been
    deemed to provide an adequate level of protection for personal data by the
    Information Commissioner’s Office including those countries in the
    European Union
    • where we use certain service providers, we may use specific contracts
    approved by the Information Commissioner’s Office which give personal
    data the same protection it has in the UK.


    Please contact us if you want further information on the specific mechanism used
    by us when transferring your personal data out of the UK.


    Your rights
    Under the UK GDPR and DPA you have a number of important rights free of charge.
    In summary, those include rights to:


    • fair processing of information and transparency over how we use your use
    personal information
    • access to your personal information and to certain other supplementary
    information that this Privacy Notice is already designed to address
    • require us to correct any mistakes in your information which we hold. Our
    members are encouraged and invited to log into their online account and
    amend their contact information and update it where necessary.
    • require the erasure of personal information concerning you in certain
    situations
    • receive the personal information concerning you which you have provided to
    us, in a structured, commonly used and machine-readable format and have
    the right to transmit those data to a third party in certain situations
    • object at any time to processing of personal information concerning you for
    direct marketing
    • object to decisions being taken by automated means which produce legal
    effects concerning you or similarly significantly affect you
    • object in certain other situations to our continued processing of your
    personal information
    • otherwise restrict our processing of your personal information in certain
    circumstances
    • claim compensation for damages caused by our breach of any data
    protection laws

    For further information on each of those rights, including the circumstances in
    which they apply, see the Guidance from the UK Information Commissioner’s
    Office (ICO) on individuals rights under the General Data Protection Regulation.

    If you have any questions about this privacy policy, including a request to exercise any of your rights, please:


    • Email us at [email protected]
    • let us know the information to which your request relates, including any
    membership number or reference number, if you have them


    We try to respond to all legitimate requests within one month. Occasionally, it could 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.

    We hope that we can resolve any query or concern you raise about our use of your information.


    The General Data Protection Regulation also gives you right to lodge a complaint
    with a supervisory authority. The supervisory authority in the UK is the Information
    Commissioner who may be contacted
    at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.


    Keeping your personal information secure
    We have appropriate security measures in place to prevent personal information
    from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those


    processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
    We also have procedures in place to deal with any suspected data security breach.
    We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    Changes to this privacy notice
    This privacy notice was last updated on 11 March 2022.
    We may change this privacy notice from time to time, and when we do we will
    inform you.