Membership Privacy Policy

1. Summary

This Membership Privacy Policy (this "Policy") describes the types of personal information, which the College of Policing 'the College' and our partners (collectively, "the police service", "we" or "us") may collect, how we may use the information, with whom we may share this information, and the choices that you can make regarding our use of this information.

The use and disclosure of personal data is governed by the General Data Protection Regulation (GDPR) and relevant Data Protection legislation.  The College is registered with the Information Commissioner as a 'Data Controller' [registration no: Z3458257]. As such we are obliged to ensure that all personal data is held and processed in accordance with the law.

The College takes that responsibility very seriously and takes great care to ensure that personal data is handled appropriately in order to secure and maintain individuals' trust and confidence in the College.

The identifiable information  that you provide to the College as a member of the College (your "personal data") will be used for the processing and management of your membership, providing you with online account access and enabling you to take up services and products that you are eligible to receive. Your personal data will be protected in accordance with this Policy and relevant Data Protection legislation. As set out below, personal data includes any identifiable information about you that you or anyone else may provide (on your or the College's behalf) in the context of managing your membership with the College.

For information on the College's general Privacy Notice or cookie policy, please go to:

2. Lawful basis for processing personal data

The College is relying on your consent in order to process your information for the purposes of providing membership services. By submitting your personal information, you confirm and agree that:

  • you have read and understood this Policy;
  • the College may process your membership data according to the purposes set out in this Policy;
  • You have the right to withdraw your consent at any time.

3. Collection of Personal Data

The College and other partner agencies working with the College use various methods to collect personal data in order to evaluate the eligibility of a person's [continued] membership with the College.

Such methods may include:

  • The processing of any applications you make to the College whether that be online, via email or via paper submission.
  • Any direct interactions (enquiries, complaints etc.) via email, telephone or letter.

For Professional Members;

  • Information supplied to us via the Managed Learning Environment (MLE) including, but not limited to, employment status and course results.

Members should be aware that providing false information during the application process or the term of your membership to the College will be a breach of the Code of Ethics and is likely to lead to the termination of your College membership.

4. Purposes for Processing Personal Data

The College and other partner services working with the College may process your personal data for the purposes of providing membership services as outlined in this policy.

These purposes include but not necessarily limited to:

  • identifying and/or evaluating applicants for College membership;
  • making a decision about whether an individual should be held on a College professional register
  • the purposes of equal opportunities monitoring;
  • maintaining appropriate record-keeping related to membership services;
  • to provide individuals with membership information and details of relevant College products or services to eligible members
  • any additional purposes set out in a service or product offered for purchase.

Members are also asked to note the following additional purposes:

4.1 Research and Statistics

The College may collect member feedback and opinions periodically (e.g. surveys) for business purposes, such as improving processes.

In addition, the College may process information gathered about you as part of this process. This data will never be shared with third parties, it will be used for analysing our membership service offering including (but not limited to) advertising, training, promotion, attrition and outcomes.

Such analysis may be conducted by the College or our external police-related organisations and academic partners, and may lead to the publication / official reporting of any research results compiled. However, such publications will only publish accumulated statistical data and will not, under any circumstances, publish any personal data about you unless specifically stated and / or consent obtained.

You are free to choose whether to respond to any surveys sent to you by the College or not, and your membership will not be affected by a decision not to partake in any survey. You will also have the option to not receive any emails that are not service related and considered as direct marketing.

4.2 Membership Online Functionality

The College provides members with access to the College membership website. Member data
will be used to:

  • authorise an individual to log into the website, view and amend their data (where member data amendment is not appropriate, instructions will be provided on how to request data changes);
  • control a member's permissions to see and use products and services available from the website;
  • enable a member to set permissions on the use of their data e.g. whether data is used for direct marketing, confirm whether selected personal data can be shared with other members.

4.3 Transparency Requirements

Members should be aware that the College have provided a firm commitment to the public, our members and the UK government that we will operate transparently (as far as is possible to do so). In addition, we are also subject to the provisions of the Freedom of Information Act 2000, requiring us to publish / disclose information that is held by the College and does not fall under an exemption. Such information may include the actions, activities and other information processed by us about you in your official capacity while you are a member of the College. This commitment / requirement does not affect your privacy' rights. We will never disclose your personal information related to your private life.

5. Types of Personal Data

The types of personal data we may obtain include:

  • Work history and experience;
  • Education, including professional qualifications, and other memberships;
  • Professional Register status;
  • Job position / title
  • Online questionnaire results;
  • Contact information (e.g., your name, email address, and/or phone number as applicable);
  • Any previous names you may have used;
  • Any additional information you may provide (e.g., interests, skills);
  • Other sensitive information (e.g., your image, sex, gender, ethnic origin, languages spoken / preferences, ethnicity, religion or belief, age, date of birth and sexual orientation).

The College reserves the right to process the above information for the purposes of national security, the prevention and detection of crime, and the apprehension of offenders. Whilst we will endeavour to notify you of such processing, there may be occasions that such notifications will act in contrary to these purposes, which will necessitate the need to process this information without notification.

6. Security and Confidentiality

The College takes the security of all personal data under our control very seriously. We comply with the GDPR and relevant Data Protection legislation relating to security, and seek to comply with the National Police Chiefs' Council (NPCC) Community Security Policy and relevant parts of the ISO27001 Information Security Standard.

We will ensure that appropriate policy, training, technical and procedural measures are in place, including audit and inspection, to protect our manual and electronic information systems from data loss and misuse, and only permit access to them when there is a legitimate reason to do so, and then under strict guidelines as to who can access specific data and what use may be made of any personal data contained within them. These procedures are continuously managed and enhanced to ensure up-to-date security.

We suggest that you use a secure email address (e.g. accredited by an official body) to contact us and register for membership.

Please be aware that emails sent to and from us via an unaccredited email address are not secure, as these email messages can be intercepted. We will hold your information securely, but there can be no guarantee of privacy with email communication as above. Therefore, we advise you do not email any information which, if disclosed to unrelated third parties, would be likely to cause you damage or distress. You should perform your own virus checks on any emails you receive via an unaccredited email address.

If you need, or are required to send documentation to us, we recommend, where possible you provide documentation via your online membership account. If this is not possible and you use email, you should encrypt your email and any attachment, and password protect the attachment. You should then contact us by a separate communication (email or phone) to notify us of the password.

7. Retention Periods

The information you submit will be held in accordance with our retention schedule for a period of 2 years following your last contact (in relation to membership) with the College or your last login to the membership website. In this event, you will be contacted to ask whether you wish to retain your membership, if you do not respond or no longer wish to maintain your membership, all personal data will be deleted and your membership will be revoked. You will need to complete the membership application process should you wish to apply again after this period ceases; note previous online account information will not be accessible.

You are encouraged to ensure that the membership Information you provide to the College of Policing is kept up to date and accurate.

8. Disclosure to Third Parties and International Transfers

It may be necessary to disclose some personal data to a supplier or contractor organisations supplying services on the College's behalf, who require the use and/or creation of personal information about members. Such processing will be subject to strict contractual agreements, which will require any data processor or third party data controller to abide by the requirements of the College's Privacy and Security policies.

Membership data will be held in the UK, however it may be necessary to utilise the services of international suppliers, to assist in the processing of member data. However, we will do so only for the purposes described in this Policy. If we provide your personal data to other countries, we will take steps to ensure the same level of protection for that personal data as is set out in this Policy unless otherwise required by applicable laws.

9. Rights

Individuals have various rights under GDPR and members are asked to refer to the College's Privacy Notice for further information and a list of their rights.

10. Changes to this Policy

The College may need to modify this Policy as needed, for example, to comply with changes in business operations or laws and regulations. The College will post all changes to this Policy on our Internet sites.

11. Contact Us

Any individual with concerns over the way the College handles their personal data may contact our Data Protection Officer as below:
Email: foi@college.pnn.police.uk
Mail: Data Protection Officer
Central House
Beckwith Knowle
Otley Road
Harrogate
HG3 1UF

Requesting information under Data Protection

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