How Financial Markets Law Committee (“FMLC”) uses your information
This privacy notice tells you what to expect when FMLC collects personal information. It applies to information FMLC collects about:
- visitors to FMLC’s website;
- people who receive or request FMLC publications including newsletters and papers;
- complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry; and
- job applicants and (former) employees and volunteers.
In accordance with the Data Protection Act 1998, FMLC follows strict rules called “data protection principles” to ensure information is:
- used fairly and lawfully;
- used for limited, specifically stated purposes;
- used in a way that is adequate, relevant and not excessive;
- kept for no longer than is absolutely necessary;
- handled according to people’s data protection rights;
- kept safe and secure; and
- not transferred outside the European Economic Area without adequate protection.
Visitors to the FMLC website:
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most web browsers allow some control of most cookies through the browser settings. Currently the FMLC website does not use any cookies. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
2. Search engine
FMLC’s website (www.fmlc.org) uses a search function. Search queries and results may be logged anonymously to help improve website and search functionality. No user-specific data is collected by either FMLC or any third party.
FMLC uses a third party website hosting service, WordPress, which collects and receives certain information from its activity in hosting our website. For more information about how WordPress processes data, please see the privacy notice at https://en-gb.wordpress.org/about/privacy/.
FMLC maintains an account on LinkedIn and Twitter. Please refer to their privacy statements for further information regarding how they may treat your personal information.
People who email us
FMLC’s Secretariat is housed in the Bank of England and is part of their IT network. FMLC relies on Bank of England systems, which implement and maintain appropriate monitoring arrangements in relation to email usage. Any email sent to us, including any attachments, may be monitored and used by the Bank of England for reasons of security and for monitoring compliance purposes. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to FMLC is within the bounds of the law. For continuity and record keeping purposes, FMLC may store email communications.
FMLC contacts’ database
FMLC uses Microsoft Dynamics CRM Live 2 to record and manage contact details for Members, patrons, stakeholders, Secretariat members and so on. This data is stored on-site at the Bank of England in a replicated SQL database cluster. Aside from the CRM Team at the Bank of England and FMLC Secretariat, no other parties have access to this data and the data is not referenced by any other system. There are no feeds in or out.
Job applicants, current and former FMLC employees
When individuals apply to work at the Secretariat, FMLC will only use the information he or she supplies to enable the Secretariat to process their application and to monitor recruitment statistics. Where FMLC would like to disclose information to a third party, for example where FMLC wants to take up a reference, obtain a “disclosure” from the Criminal Records Bureau or security clearance from the Foreign and Commonwealth Office, the Secretariat will not do so without informing the individual beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for six months after the recruitment exercise has been completed and will then be destroyed or deleted. FMLC may retain de-personalised statistical information about applicants to help inform Secretariat recruitment activities, but no individuals will be identifiable from that data.
Once a person has taken up employment with FMLC, a file relating to his or her employment will be compiled. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once his or her employment with FMLC has ended, the Secretariat will retain the file in accordance with the requirements of the retention periods detailed in the FMLC Data Protection Policy (copy available on request) and then delete it.
Complaints or queries
FMLC endeavors to meet the highest standards when collecting and using personal information. For this reason, any complaints relating to this are taken very seriously. FMLC encourages individuals to contact the Secretariat if they think that FMLC’s collection and/or use of information is unfair, misleading or inappropriate. The Secretariat also welcomes any suggestions for improving procedures. Please see the Contact section, below, for further details.
People who make a complaint to us
When FMLC receives a complaint from a person a written record will be made of the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. FMLC will only use the personal information collected to process the complaint. FMLC does not at present compile or publish statistics showing information such as the number of complaints received, but in any event would not do so in a form which identifies anyone.
FMLC may have to disclose the complainant’s identity to the individual the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, FMLC will make reasonable effort to respect that, however, it may not be possible to handle a complaint on an anonymous basis.
FMLC will keep personal information contained in complaint files in line with the retention section of the FMLC Data Protection Policy. Such information will be retained in a secure environment and access to it will be restricted according to the “need to know” principle. Similarly, where enquiries are submitted to FMLC the Secretariat will only use the information supplied to deal with the enquiry and any subsequent issue(s) and/or to check on the level of service provided.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of FMLC’s collection and use of personal information. The Secretariat will be happy to provide any additional information or explanation needed. Any requests for this should be sent to FMLC’s Data Protection Officer, details below.
Access to personal information
FMLC tries to be as open as possible in terms of giving individuals access to their personal information. Individuals can find out if FMLC hold any personal information by making a “subject access request” under the Data Protection Act 1998. If FMLC does hold information about you the Secretariat will:
- give you a description of it;
- tell you why FMLC is holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request to FMLC for any personal information the Secretariat may hold you need to make a written request to FMLC’s Data Protection Officer (please see below). If you agree, FMLC will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If FMLC does hold information about you, you can ask the Secretariat to correct any mistakes by, once again, contacting the FMLC Data Protection Officer.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. FMLC encourages you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
FMLC keeps this privacy notice under regular review. This privacy notice was last updated on 1 November 2017.
If you want to request information about FMLC’s Data Protection Policy please contact the FMLC Data Protection Officer Venessa Parekh by email (firstname.lastname@example.org) or telephone ((44)(0) 207 601 3988).