Who this notice is for?
This notice is for advertisers in the CSTA’s magazine, The Fulcrum, and describes ways in which the CSTA needs to process personal information in order to fulfil your advertising.
What this notice is about
This notice tells you what personal data we collect, how we use it, and your rights relating to our use of your information. You should make sure you understand this information, and if you have any questions, please contact us.
Who we are
The Craniosacral Therapy Association UK (CSTA) is an accreditation and regulatory professional body for craniosacral therapy in the UK. Our charity number is 1156168.
Data protection legislation applies to ‘personal data’. This means information about someone (a living individual), who can be identified as that person. Generally this will include information such as full name, address, phone number, email address. Data protection law regulates how that data is ‘processed’ i.e. collected, stored and used, and in the UK is currently governed by the Data Protection Act 2018 and by the Europe-wide General Data Protection Regulation 2016 (GDPR).
The CSTA is the ‘data controller’ for the information it holds about advertisers in The Fulcrum. This means it controls what happens to that information and takes legal responsibility for this.
We are committed to ensuring that the way we process personal data is compliant with applicable data protection law, as well as best practice for a professional body. All personal information that we collect from you to fulfil your advertising is treated in confidence within the organisation and is used only for the purpose of maintaining the records we need to meet our responsibilities.
The types of personal data we may hold about you
In general most information will have been supplied by you by email in your advertising request and booking. This information may include:
• Your name, address, phone number, email address
• Your billing address and payment history
The purpose of processing
The purpose of holding and processing personal information about you is to manage your advertising with us (processing and responding to your initial advert request and any subsequent adverts and contacting you about this where needed) and to maintain a database of advertisers.
We will contact you where needed in relation to your advertising, for example to respond to or confirm your advert request; to remind you of submission deadlines and to check queries or proofs; to respond to enquiries from you; to invoice and receive payments; and, from time to time, with general notices, for example relating to changes in fees.
The legal basis for holding your information
We rely on ‘legitimate interests’ as our main ‘lawful basis’ for processing your personal data under the current data protection regulations (GDPR and 2018 Data Protection Act UK). This means that we need this information in order to process your adverts and to manage your payments, including fulfilling any legal requirements this may entail.
Retention – how long will we keep your information and why
We will not keep information for longer than is needed in order to fulfil our purposes as described above, unless we are specifically obliged to by law.
• Your information is held in an active record for a minimum of three years.
• Financial records must by law be kept for at least seven years.
• General emails that you may send about your advertising are deleted on a rolling approximately three-yearly basis.
Who we share your information with
CSTA communications and The Fulcrum
The records of your advertising account are kept in a secure GDPR-compliant cloud system.
We may use third party services to send communications for The Fulcrum journal. These services include, but are not restricted to, Printmark and Mailchimp. Only the minimum required personal data is shared for each purpose, for example your name and contact email or postal address, and these details are not accessed or used by the service for any other reason. We have checked that each service is GDPR-compliant.
We take the security of your personal information very seriously. We regularly review both our policies and our IT systems to ensure our security measures are adequate and reflect up to date technological advances as well as the requirements to prevent unauthorised access to, destruction or loss of your information.
All CSTA Fulcrum advertiser data is held on a secure and compliant cloud content management system, using GDPR-compliant hosting facilities.
Data protection and your rights
Data protection regulations say that anyone who holds and controls personal information about individuals must respect their privacy rights, and must also inform them about these rights –
Your right to refuse to give information
Under the GDPR, you should not be forced to provide your personal information to a data controller, and you have the right to be informed of any consequences of refusing to give it.
The CSTA respects the principle of ‘data minimisation’ which means we only request information which we actually need for each type of membership or subscription.
Because this information is needed to maintain your advertising account, if you do not wish to give your personal information as described above, we will not be able to process an advert for you.
Your right to object to personal data processing
If you object to us processing your personal information, you can ask us to restrict our use of it and delete any records we are not required to retain. At your request, for example, we will stop using your data to contact you – this may mean we are not able to accept adverts from you.
Your right to see what information we hold about you
You have the right to request access to the information we hold about you, and we must respond to your request within one month. We will need to see proof of your identity and address before we can transfer a copy of your records to you. We will also respond to any concerns or questions you may have about our use of your information.
It should be noted that we are not obliged to disclose to you all the information we hold about you, in particular where disclosure could be a risk to the privacy rights of someone else.
Your right to rectify any information we hold which is not correct
If you believe that any of the information we hold about you is inaccurate or incorrect you have the right to tell us about this and request that the information is corrected.
Please do let us know if any of your details change so we can keep your records up to date.
Who to contact at the CSTA about personal data and your privacy rights
For any questions or concerns about this privacy information, or to make a request to exercise your privacy rights, please contact firstname.lastname@example.org, telephone 0844 700 2358, or write to us at CSTA, 27 Old Gloucester Street, London, WC1N 3AX.
Your right to make a complaint
You have the right to complain if you are unhappy about the way we look after your information, or feel we have not properly respected your rights – please contact email@example.com and we will do our best to answer you and work with you to resolve any concerns. If you are still unhappy you can appeal to the Information Commissioner’s Office (ICO) https://ico.org.uk/concerns/ or 0303 1231113.
Changes to this privacy notice
We may modify this privacy notice at any time to reflect best practice or changes in the laws or regulatory guidelines on data protection. If we make changes to this privacy notice, we will highlight this on our website where the new documents will be available, and for significant or major changes we aim to inform current members by email.
This privacy notice was last updated on 12th June 2019