Privacy Policy & Cookies

1. Summary

This Membership Privacy Policy (this “Policy”) describes the types of personal information, which the Independent Living Group (ILG) and our partners (collectively, “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 in the United Kingdom by the General Data Protection Regulation (GDPR).

The ILG takes the act very seriously and takes great care to ensure that personal data is handled appropriately in order to secure and maintain member’s trust and confidence in the group.

The identifiable information about yourself that you provide to the ILG as a member of the ILG (your “personal data”) will be used for 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 applicable law. As set out below, personal data includes any identifiable information about you that you or anyone else may provide (on your or the ILG’s behalf) in the context of managing your membership with the ILG.

2. Lawful basis for processing

ILG will rely on the following basis when processing personal data for the provision of the contract and throughout the handling of the policy:

• Consent;
• Contract;
• Legitimate Interests.

By submitting your personal information, you confirm and agree that:

• you have read and understood this Policy;
• the ILG may process your membership data according to the purposes set out in this Policy;

3. Collection of Personal Data

In order to provide you with a membership quote or subscription we need to collect your personal information. We only collect the information we need to provide you with the best service and experience we can.

The ILG use various methods to collect personal data in order to evaluate the eligibility of a person’s [continued] membership with the ILG.

Such methods may include:

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

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

4. Purposes for Processing Personal Data

The ILG may process your personal data for legitimate membership purposes as set out in this policy.

These purposes include but not necessarily limited to:

• identifying and/or evaluating members;
• maintaining appropriate record-keeping related to membership services;
• to provide individuals with membership information and details of relevant member benefits 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 ILG may collect member feedback and opinions periodically (e.g. surveys) for business purposes, such as improving processes.

In addition, the ILG 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.

You are free to choose whether to respond to any surveys sent to you by the ILG or not, and your membership will not be affected by a decision not to partake in any survey.

4.2 Membership Online Functionality

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

• authorise a member to log into the website, view and amend their data (where members data amendment is not appropriate, instructions will be provided on how to request data changes);
• control a members 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 ILG 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 in the public interest. 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 ILG. This commitment / requirement does not affect your ‘privacy’ rights.

5. Types of Personal Data

The types of personal data we may obtain include:

• Online questionnaire results;

• Contact information (e.g., your name, address, email address, and/or phone number as applicable);

• 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 ILG 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 ILG takes the security of all personal data under our control very seriously. We comply with the relevant parts of the GDPR 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 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 this data privacy statement for a period of 6 years following your last contact (in relation to membership) with the ILG or your last login to the membership website. In this event, you will be contacted to ask whether 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 ILG is kept up to date.

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 ILG’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 ILG’s privacy policy.

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.

Your personal data may be passed to (but not limited to):

• Mark Bates Ltd (our IT and administration support provider);
• Perks Direct Ltd (our GP service provider);
• Kuiper Technology (our IT support provider);
• Xelion (our telecommunications provider);

9. Changes to this Policy

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

10.  Cookies

This website stores small data files on your computer or device whilst you use this site. These small files are called ‘cookies’ and are used to remember when you accessed this website and are essential in ensuring you have the best possible experience with this website you can. They also allow you to use our on line services like policy management and used to tailor the products and services offered and advertised on this website to our customers.

Disable cookies

If you want to disabled cookies you need to do so in your browser. How to do this depends on the browser you use but you will typically find you can do this in the browser options or preferences.

We cannot guarantee this website will operate properly if you do disable cookies.

11. Controlling your personal information

ILG will always require you to ‘opt-in’ to direct marketing and confirm how you wish to receive this. You can remove yourself at any time by contacting our office by post, email or telephone.

The personal data we collect may also be used for the marketing of other services or products we feel you may be interested in.

We may use your personal information to send out promotional information about current and new policies available which may be of interest to you.

Your Rights

The GDPR provides the following rights for individuals:

• The right to be informed – The right to request details of the data being processed
• The right to access – The right to be made aware of what details are being held
• The right to rectification – The right to have incorrect data corrected
• The right to erasure – The ‘right to be forgotten
• The right to restrict processing – The right to restrict certain processing of data including objecting to personal data being used for direct marketing purposes
• The right to data portability – The right to have your data transferred to another insurer
• The right to object – The right to object to your data being processed
• Rights in relation to automated decision making and profiling

12. Contact Us

Any member with concerns over the way the ILG handles their personal data may contact us at support@ilgcommunity.com

13. Changes to this privacy policy

Independent Living Group Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.