PROCEEDS OF CRIME LAWYERS’ ASSOCIATION
Privacy Notice – General Information Protection Regulation (“GDPR”)
Please read the following information. This privacy notice contains information about the information collected, stored and otherwise processed about you and the reasons for the processing. It also tells you who the Proceeds of Crime Lawyers’ Association shares this information with, the security mechanisms it has put in place to protect your information and how to contact the association in the event you need further information.
Who are we?
The Proceeds of Crime Lawyers’ Association (“POCLA”) is an unincorporated association. It is available for membership to lawyers, investigators and other professionals with a professional interest in the law and practice connected to the proceeds of crime.
It collects, uses and is responsible for personal information about you. When POCLA does this, it is the ‘controller’ of this information for the purposes of the GDPR and the Data Protection Act 2018.
If you need to contact POCLA about your information or the processing carried out, you can use the contact details at the end of this document.
What does POCLA do with your information?
POCLA collects some or all of the following personal information that you provide:
- Personal details (name, business address, occupation and contact material);
- Limited financial details relating to the bank from which you make subscription and other payments;
- Your dietary requirements if you provide them when you attend a POCLA function
How POCLA uses your personal information: Purposes
POCLA may use your personal information for the following purposes:
- To contact you for, and to promote, professional, social and other services provided by or offered by POCLA or associated purposes;
- To collect subscriptions and other payments due for services provided by POCLA;
- To trade with you as a supplier of goods or services.
Marketing and promotion
In relation to personal information collected for marketing the activities of POCLA purposes, the personal information consists of:
- names, contact details, and name of organisation;
- the nature of your interest in POCLA activities ;
- your attendance at POCLA events.
This will be processed so that you can be provided with information about POCLA and to invite you to events. You may contact POCLA using the contact details at the end of this document if you no longer wish to receive such invitations or information
Whether information has to be provided by you, and why
If you apply for membership of POCLA, your personal information has to be provided, so that your application can be properly assessed and to enable POCLA to comply with its regulatory obligations, and to keep membership and accounting records.
If you are offering or providing POCLA with goods or services, your information may be processed in relation to such offers or contracts.
The legal basis for processing your personal information
POCLA relies on the following as the lawful bases to collect and use your personal information:
- If you have consented to the processing of your personal information, then POCLA may process your information for the Purposes set out above to the extent to which you have consented to POCLA doing so;
- POCLA relies on its legitimate interests and/or the legitimate interests of a third party in carrying out the processing for the Purposes set out above.
Who will POCLA share your personal information with?
It may be necessary to share your information with the following:
- Information processors, such as IT support staff, email providers, information storage providers;
- Financial institutions connected to and for the purpose of collecting subscriptions and other payments due to POCLA;
- Other members of POCLA, and third parties for the purpose of organising and promoting professional and social events.
POCLA may be required to disclose your information to the Information Commissioner’s Office. If so, there is a risk that your information may lawfully be disclosed by them for the purpose of any civil or criminal proceedings, without POCLA’s consent or your consent.
POCLA may also be required to disclose your information to the police or intelligence services, where required or permitted by law.
If you would like any further information, please use the contact details at the end of this document.
How long will POCLA store your personal information?
POCLA will normally store all your information:
- Names and contact details will be stored indefinitely or until POCLA becomes aware or is informed that the individual has ceased to be and will not in the future be a potential member or business supplier; otherwise –
- Until at least 1 year after the expiry of any relevant limitation period relating to the date of the last provision of service or goods, the date of the last payment made or received or the date on which all outstanding payments are written off, whichever is the latest. This is because it may be needed for potential legal proceedings. At this point any further retention will be reviewed and the information will be marked for deletion or marked for retention for a further period. The latter retention period is likely to occur only where the information is needed for legal proceedings. Deletion will be carried out as soon as reasonably practicable after the information is marked for deletion.
You may withdraw your consent to POCLA processing your information.
You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity carried out prior to you withdrawing your consent. However, where POCLA may also be required by law to process your information, withdrawal of consent may not prevent this.
If there is an issue with the processing of your information, please contact POCLA using the contact details below.
Under the GDPR, you have a number of rights that you can exercise in certain circumstances. These are free of charge. In summary, you may have the right to:
- Ask for access to your personal information and other supplementary information;
- Ask for correction of mistakes in your information or to complete missing information POCLA holds on you;
- Ask for your personal information to be erased, in certain circumstances;
- Receive a copy of the personal information you have provided or have this information sent to a third party. This will be provided to you or the third party in a structured, commonly used and machine-readable format, e.g. a Word file;
- Object at any time to processing of your personal information for direct marketing;
- Object in certain other situations to the continued processing of your personal information;
- Restrict the processing of your personal information in certain circumstances;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR.
If you want to exercise any of these rights, please:
- Use the contact details at the end of this document;
- POCLA may need to ask you to provide other information so that you can be identified;
- Please provide a contact address so that you can be contacted to request further information to verify your identity;
- Provide proof of your identity and address;
- State the right or rights that you wish to exercise.
POCLA will respond to you within one month from when it receives your request.
Please note if you wish to unsubscribe from any marketing emails that you have signed up for, please contact POCLA using the contact details below. It may take 21 days for this to become effective.
How to make a complaint?
The GDPR also gives you the right to lodge a complaint with the Information Commissioners’ Office if you are in the UK, or with the supervisory authority of the Member State where you work, normally live or where the alleged infringement of information protection laws occurred. The Information Commissioner’s Office can be contacted at: http://ico.org.uk/concerns/.
POCLA does not intend to process your personal information except for the reasons stated within this privacy notice. If this changes, this privacy notice will be amended and placed on POCLA’s website at www.pocla.org.
Changes to this privacy notice
This privacy notice was published on 15 February 2019 and last updated on 12 February 2019.
POCLA reviews its privacy practices and may change this policy from time to time. When it does an amended privacy notice will be placed on its website.
If you have any questions about this privacy notice or the information POCLA holds about you, please use the contact details below.