Privacy Notice

The Marine Biological Association (“MBA”) is a registered charity, registration number 1155893.

The MBA is registered with the Information Commissioner’s Office (ICO) with the Data Protection Registration Reference Z8249388.

The MBA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information about how the MBA collects and processes your personal data through either your use of our website (https://www.mba.ac.uk) and/or services or your supply of goods and/or services to us (as appropriate).

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

Controller

The Data Protection Officer at the MBA is the controller and is responsible for your personal data (collectively referred to as “MBA”, “we”, “us” or “our” in this privacy notice).

Contact details

If you have any questions about this privacy notice or out privacy practices, please contact us at DPO@mba.ac.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website 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 their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Occasionally, we may amend this notice and the changes will come into effect from the date it is amended on this page. The notice was last updated on the 13 July 2022.

• The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The MBA collects a variety of data categories in order to plan, support and execute our work. We May collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name (if required), last name, marital status, title, date of birth and gender.
• Contact Data includes billing address (if required), delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details (as required).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your 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 use to access our website.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please see below in this privacy notice for the Special Categories of Personal Data that we may collect in certain circumstances.

Children’s data

Some of our services are specifically aimed at young people and to deliver these services safely it is necessary for us to collect data through a registration process. Children have the same rights as adults over their personal data and we are committed to protecting the personal data of children and ensuring that safeguards are in place.

Before we collect data from anyone under 18 years of age, we will ask them to obtain permission from a parent or guardian before registering or ask that a parent or guardian register on their behalf.  It is our policy not to request donations or subscriptions, or to accept product orders, from anyone under 18 years of age. Membership of the MBA will always be sought from the parent or guardian, or purchased as a gift for a young person.

For children and young people between 12 and 18 years of age, who have sufficient understanding of the consent processes and the implications for them, the child/young person can create their own membership profile, although payment will need to be completed by an adult. Please note parental consent will always be sought to attend both digital and in-person events, and again, if the young person has sufficient understanding of the consent processes and the implications for them, they should be involved in completing the form and their consent should be considered.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data 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.

• How information about you is collected

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

• Direct interactions. Your interactions with the MBA may result in personal data being created. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. For example, if you purchase membership, the membership fee, the transaction date and membership expiry date, along with the campaign that you responded to will be recorded. This engagement information is added to your individual record so that we can make sure that any future communications are tailored to your interests.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Suggest please contact our Data Protection Officer for more information.
• Third parties or publicly available sources. We may combine information provided by you with information available from external, publicly available sources in order to get a better understanding of our customers, members, supporters, and audiences and to improve our products, services, marketing and fundraising methods. We will receive personal data about you from various third parties as set out below:
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• How we will use your personal data

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

• Where we need to perform the contract we are about to enter into or have entered into 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.

Please see the Glossary at the end of this privacy notice to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us and further details are available below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal 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 data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To review and improve the services we provide which will include: Notifying you about changes to our terms or privacy noticeAsking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To fulfil your requests such as membership applications, donation processing, participation at events and provision of information. We may be required to collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) and to meet our charitable aims
To process sales transactions, donations or other payments, and verify financial transactions	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) and to meet our charitable aims
To organize and administer events and fundraising activities	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and deliver events) and to meet our charitable aims
To handle orders, deliver products and communicate with you about orders	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To carry our research and analysis on demographics, interests, behaviour, response and feedback of our users and supporters to help gain a better understanding of them and to inform and improve our services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our activities and to achieve our charitable aims
To administer and protect our charity and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security and to prevent fraud (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our charity and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our charity)
To contact your emergency contact in the event of an emergency	(a) Identity (b) Contact	Necessary to protect your vital interests
To effectively manage MBA sites and facilities, including the use of CCTV	(a) Identify	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Necessary to protect your vital interests and our staff’s vital interests (e) Substantial public interest in processing this information for the purposes of detecting and preventing crime
To safeguard employees, visitors, members of the public and young people	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Necessary to protect your vital interests and our staff’s vital interests
To manage applications for grants and bursaries	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to meet our charitable aims (d) Necessary to protect your vital interests and our staff’s vital interests
To undertake educational and outreach activities, in addition to core activities, including youth education	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation and to safeguard children (c) Necessary for our legitimate interests (to keep our records updated and to meet our charitable aims

Special category data

There are certain circumstances when we process special categories of data which is limited to data concerning your health.

In the case of specialist training and events, we may ask for, and process, information classed as a special category and we will rely upon your explicit consent to do this. This is to ensure we can make any appropriate reasonable adjustments for participants, to assess whether people can participate in specific training, and for equal opportunities monitoring purposes. In all these instances, we will not use your data for any purpose other than for which it was sought. We have internal policies and controls in place to ensure that special category data is not misused, disclosed or accessed except by our employees in the proper performance of their duties.

CCTV

We have CCTV in operation at our sites, including The Laboratory, Citadel Hill, PL1 2PB. For further information, please contact our Data Protection Officer.  

Visual Data (photography and film)

We capture images and video footage of our work. This provides a valuable resource to inform the public about what we do and to promote the importance of our work. In essence, capturing visuals is vital to ensure we are here for the long term.

Under data protection law, photos are classed as personal data and as such, we need to gain your consent. Where practically possible we will seek consent in advance of an event to provide the lawful data and at all times we will provide clear instructions on how you can opt out of any photography or filming. There is no obligation to give consent but we would also like to reassure you that we will not accompany visuals with any other personal information without seeking additional consent to do so first.

For young people under 18 years of age, full parental/guardian consent is required. As it is mandatory for us to obtain permission prior to each photographic/video/film session, it is necessary for each child to have a copy of this form signed by the parent/guardian prior to the relevant photographic/video session. Children and young people between 12 and 18 years of age, who have sufficient understanding of the consent process and its implications for them, the child/young person should be involved in completing the form and their consent should be sought. The child/young person may also sign the form.

Photos and recordings containing personal data will be protected and disposed of securely in accordance with data protection legislation.

Profiling and screening

Data profiling is when we examine our database and collect information or statistics about that data. We may profile your data to find out more about your interests so we are more likely to contact you about relevant products or events that will be of more interest to you. Through profiling, we can understand more about you and our supporters as a whole which means we can tailor communications appropriately and importantly for us, manage our charitable resources effectively.

Data screening is where we match your details against another database to ensure everything is up-to-date. An example of this would be to check supporter’s details against the National Change of Address database. Through screening, we can reduce the number of newsletters and other pieces of mail that are sent to the wrong person or place and help manage our charitable resources effectively.

You have the right to opt-out of data profiling and screening at any time. Please contact us on email: DPO@mba.ac.uk

Prospect Research and wealth screening

We steward a small number of highly influential supporters who act as advocates, sharing their networks to promote the MBA, and (or) donate significant gifts, and (or) who may wish to do so in the future. To make our interactions with this small group of supporters as impactful as possible, we research an individual’s professional and charitable interests and their likely capacity to support us. This helps us identify activities that are the best match to their philanthropic ambitions and desire to make a difference. We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, trustees or other lead volunteers. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations.

We use publicly available data, from reputable sources, where someone would expect their information may be read by the public for this work. Prospect research is where we do this manually and wealth screening is where we compare our data with external data through the use of reputable specialist agencies, such as Prospecting for Gold.

We use legitimate interest as the legal basis for processing this kind of data. So, we need to make sure that your interests are examined in balance with the MBA’s. By undertaking this kind of research, we minimize the potential of inappropriate contact and ensure we can be more cost-effective in our work by sending out appropriate and tailored communications that are more likely to be welcomed than a ‘one size fits all’ approach.

If we undertake research on an individual that we then decide to contact we will make contact via post and seek consent for this processing as soon as it is practical. In this instance, electronic communication still requires consent. However, if we can identify the individual’s email as a ‘personal corporate’ email (for example ‘firstname.lastname@org.co.uk’), and can be sure the individual is not a sole trader we may make initial contact via email. This approach will only be used if there are no other channels of communication available to us. We also envisage this will be an extremely rare situation. Here, individuals will have the right to object at any time.

You can opt-out of this at any time by emailing DPO@mba.ac.uk.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

The MBA undertakes a range of marketing activities to keep our audiences informed and up-to-date with events and activities, to promote and grow membership, to raise essential funds, and to reach new supporters. We operate an opt-in approach for all electronic communications and legitimate interest as the basis for post and phone activity. This combination of these two approaches has been deemed the most appropriate approach in meeting the needs of the MBA and the expectations of our supporters.

If you have provided us with your postal address, you may receive information about news, events, membership, fundraising appeals/activities/campaigns, and information that relates to our charitable objectives. We encourage you to keep us informed of your communication preferences so we can keep in touch with you, in the way you want. You can opt-out of receiving marketing materials through the post by contacting us at DPO@mba.ac.uk.

In the case of electronic marketing such as email marketing, we will only ever contact you if you have given us your explicit permission to do so. However, if you are purchasing an item, membership or are making a donation online but do not complete the transaction a reminder email may be generated.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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 goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. This can be done online as all email communications will include an unsubscribe option. You can also update your communication preferences by contacting us at DPO@mba.ac.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• Disclosures of your personal data

Your data is incredibly important to us, which is why we will never rent, share or sell your information with any other organization or individual for their own commercial purposes. However, we may share your personal data in certain circumstances with the parties set out below for the purposes set out in the table above:

• External Third Parties as set out in the Glossary below.

We only choose trusted partners who have signed a contract or agreed to terms of service with us that require them to abide by the UK General Data Protection Regulation and successive regulations, and only use the information for the purposes for which it was supplied. We would also share your data if we believe it’s necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites

• Data security

Your information is securely stored on a database called Preside. This service is provided under contract as a data processor by PIXL8 Group, 2 Tun Yard, Peardon Street, London SW8 3HT. For more information please visit https://www.pixl8.co.uk/.

We have appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

• Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, 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.

It is necessary to keep information to fulfil statutory obligations such as the requirement to retain financial information and Gift Aid declarations for a set period of 6 years after your last transaction with us. In these circumstances, our lawful reason for continuing to retain data cannot be overridden by an objection from you. We may process and keep data for longer periods of time such as information surrounding a supporter who has left a legacy. In this specific circumstance, we keep the information until their death plus 3 years although this could be longer if the family/ estate wish to maintain an ongoing relationship with the MBA. This enables us to best honor the wishes of those who have indicated that they are intending to leave the MBA a gift in their Will.

When we no longer need information, we will always dispose of it securely, using specialist companies if necessary, to do this work for us.

In some circumstances you can ask us to delete your data. See below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Human Resources and Job Applications

Any recruitment process requires the collection and processing of personal data relating to job applicants. We are committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. Please see our separate privacy notice about human resources for more detail.

• Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us.

 You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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.

• Glossary

Legitimate Interest means the interest of our charity in conducting and managing our charity to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External Third Parties

• Service providers acting as processors based around the world who provide IT, system administration, payment card processors and similar services.
• Services to fulfil our charitable objectives such as a printing services, marketing agencies, research firms and data disposal specialists.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• The Police, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.