One Moorgate Place Privacy notice

This notice (referred to as this “privacy notice”) explains what Personal Data The Institute of Chartered Accountants England and Wales (ICAEW) on behalf of One Moorgate Place (OMP) holds about you, how we collect it, and how we use and share Personal Data. This notice applies to data collected through the OMP website and in connection with OMP visits and bookings. OMP is a commercial arm of and owned by ICAEW who collects and uses different information about people, depending on our relationship with you. Please refer to the ICAEW webpage to ensure that you read this privacy notice and any other privacy notice(s) which are relevant to you. Please ensure that you read this privacy notice and any other privacy notices we may provide to you from time to time when we collect or process Personal Data about you.

What is covered:

• Who can I contact if I have questions?
• What is personal data?
• What personal data do we collect?
• How do we protect your personal data?
• Your rights
• Complaints

1. Who can I contact if I have any questions?

One Moorgate Place is owned by ICAEW. ICAEW is the controller of Personal Data collected via the One Moorgate Place website and in connection with One Moorgate Place bookings and visits. ICAEW is registered with the Information Commissioner’s Office (ICO) with registration number (Z5765897). In this privacy notice, references to ‘we’, ‘us’ or ‘our’ mean ICAEW. You can contact ICAEW in a number of ways as follows:

Email: dataprotection@icaew.com
Post: The Data Protection Office, ICAEW, Metropolitan House, 321 Avebury Boulevard, Milton Keynes, MK9 2FZ UK
Telephone: +44 (0)1908 248 250

2. What is Personal Data?

2.1 Personal Data is any information which directly or indirectly identifies an individual, for example, your name, address and contact details.

2.2 Special categories of Personal Data are a set of Personal Data that we are required to look after even more carefully. Special categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. In some circumstances, we collect special categories of Personal Data about you and your guests via email or booking forms, for example, we may collect details of your health data to ensure that we can make provide the correct catering or access requirements during your visit or booking.

3. What personal data do we collect?

Where we collect information, we are doing so in order to offer you better services, both on the website and in the rest of our operations.

Identity Data	Your name, title, date of birth.
Contact Data	Your address and contact details, including email address and telephone numbers.
Biometric Data	Facial photography and videography from CCTV.
Website Data	Information collected during your use of our website.
Health Data	Information about your health, medical conditions or disabilities.
Survey/Questionnaire Responses	Information provided by you in response to OMP Surveys and Questionnaires

We do not collect any financial information on the OMP website. If you make a debit or credit card payment online e.g. to pay room hire deposits or to settle final bills, you will be taken to a secure payment service provider who will take your payment on our behalf and return you to this website when your order has been completed.

4. Purposes and legal basis for which we will use your Personal Data

4.1 Processing Personal Data from customers allows us to manage and administer the process of planning and delivering events and venue hire. In order to comply with Personal Data protection laws, we need a lawful basis (a reason) to process your Personal Data. We use the following lawful bases to obtain and use your Personal Data.

(a) Performance of a Contract – We need to process your Personal Data to take steps at your request, prior to entering into a contract with you and for the performance of our contract with you as an OMP customer.

(b) Consent – Some Personal Data is processed because you have given your consent. Consent can be withdrawn at any time by contacting us at dataprotection@icaew.com.

(c) Legal or Regulatory Obligation – In some cases, we need to process Personal Data to comply with a legal or regulatory obligation which we are subject to.

(d) Legitimate Interest – Where processing the Personal Data is in our legitimate interests (or those of a third party) provided that your fundamental rights do not override such interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Personal Data for our legitimate interests.

4.2 The table below describes the ways in which we use your Personal Data and the legal bases we rely on to do so. Where appropriate we have also set out our legitimate interests in processing your Personal Data.

Purpose and/or activity	Type of Data	Legal basis for processing
For feedback, research, analysis and development purposes, to request and collect feedback on your customer journey and experiences to help us to assess the service and products we provide; to help us develop and improve our services.	Identity Data Contract Data Response data provided by you.	Legitimate interest: in requesting, collecting and responding to feedback from customers about their experiences of OMP. Legitimate interest: understanding how customers use our services, in researching and analysing what customers want from OMP. Legitimate interest: in developing and improving our services.
To provide you with updates and information around your enquiry or confirmed booking by phone, email, post; to send you other information or updates relating to our services that you may be interested in including direct marketing emails and offers. We will only send direct marketing emails to you with your consent. Please see the Direct Marketing section in this table below for more information.	Identity Data Contact Data	Performance of a Contract: to provide all relevant information to you for the purposes of successfully planning and delivering the services you acquire from OMP. Legitimate interest: to provide relevant information that will more generally assist you in your enquiry and activities.
To take payment or provide you with a refund.	Financial Data	Performance of a Contract: to allow us to take, if necessary refund, payments made by you for the provision of services by ICAEW to you as a customer.
To support any access or dietary requirements you or your guests may have	Health Data	Consent: where you have actively supplied the information and consent to us using it for these purposes.
To share relevant details with 3^rd party suppliers/organisations, who will be sub-contracted by OMP to supply services e.g. catering, security.	Contact Data Health Data	Explicit consent: where you have actively supplied the information and consent to us using it for these purposes. Legitimate interest: receiving and sharing information with other entities regarding customers.
Direct Marketing, sending you emails to promote our services, networking opportunities and offers.	Identity Data Contact Data	Consent: where you have consented to receiving the communications.
Controlling and monitoring entry and use of our buildings including monitoring of CCTV and PWA app.	Contact Data Image Data Member Data	Legitimate interests: to monitor and manage customer access to our premises, systems and facilities.
Collecting personal data to enable member club entry via PWA.	Contact Data Member Data	Consent: where you have confirmed registration and use QR code to gain access to the members club at OMP.
Internal Audit	A Sample of all Personal Data	Legitimate Interests: where we have a legitimate interest in auditing our internal processes and procedures to ensure that we are complying with applicable laws and internal and managing risk appropriately.
Anonymisation of personal data for the onward activities of Management Information and Business Intelligence	All Personal Data	Legitimate Interest of the ICAEW for business improvement and intelligence purposes.

4.3 Information you give in response to surveys and questionnaires on the website will be used in two ways

by ICAEW itself to help improve our services to customers; or
by third parties that ICAEW may give the information to for market research; in this case, the information will only be made available as anonymous statistical reports

5. How Long will Personal Data be retained?

5.1 ICAEW keeps Personal Data for no longer than is necessary for the purposes for which it is processed. How long we keep your Personal Data will depend on how long you remain a customer, the nature of the Personal Data concerned and the purposes for which it is processed.

6. Who will have access to the information?

6.1 Any information you give will be available to ICAEW.

We may need to share your information with our service providers and agents for the purposes set out in this privacy policy, but we will ensure that it is protected. These service providers and agents include:

Email campaign service providers.
Insights and analytics service providers – provided with anonymous data only.
Third party suppliers e.g. caterers.
We also occasionally work with external organisations to carry out market research about OMP on our behalf. We may share your email address with these organisations so that they can contact you directly and carry out this research independently from ICAEW. We only use organisations that adhere to the Market Research Society code of practice.

Your Personal Data may be transferred to other third-party organisations in certain scenarios:
(a) If we are discussing selling or transferring part or all of our business. Personal Data may be transferred to prospective purchasers under suitable terms as to confidentiality;
(b) If we are reorganised or sold, Personal Data may be transferred to a buyer who can continue to provide services to you;
(c) If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority, for example the Police, we may need to share your Personal Data; or
(d) If we are investigating or defending any legal claims your Personal Data may be transferred as required in connection with defending such investigations and/or claims.

7. Transferring Data Overseas

7.1 In some cases, we or our suppliers may need to process Personal Data outside the European Economic Area (EEA) and/or United Kingdom (UK). Where this is the case we will only share the minimal amount of Personal Data necessary for the purpose of processing and, where possible, we will share the Personal Data in an anonymised form.

7.2 Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK;
(b) where we use certain processors, we may use specific contracts approved by the UK which give Personal Data the same protection it has within the UK. When we rely on this measure we will ensure that the third-party can comply with the provision of such contracts and we have confirmed that the country to which the Personal Data is transferred has adequate data protection laws in place to protect Personal Data.

7.3 Please contact us at dataprotection@icaew.com if you would like further information about the specific mechanism used by us when transferring your Personal Data.

8. Technical Information

Our website staff are fully trained in the data protection and are aware of their obligations.

Like most websites, our server gathers limited information about you during a session, including the IP address and domain name from which you are accessing the server. We use this information to help us improve the content, design and performance of the site. We do not give the log files or the information they contain to any third parties.

Our website software can recognise the configuration of the computer and the browser software you are using. This will help us to provide you with an optimised experience.

If you provide feedback via an online feedback form, we will collect your name, email address and, if appropriate, membership or student number.

This site uses Google Analytics, and specifically Google Analytics Demographics and Interests reporting. Should you wish, you can opt-out of the Google Analytics advertising features used for demographics and interests reporting using. Google have provided more information and a simple plugin to allow you to do this on any website. For more information on how to opt-out of Google Analytics please visit: Google Analytics Opt-Out.

9. Use of cookies

A cookie is a tiny file that is saved by your browser when you visit a website. It enables certain information about your visit to be stored by the site. We have set out full details about our use of cookies on a separate page, where you can find out which cookies we use, why we use them, and what you need to do if you don’t wish to accept some or all them.

10. Other websites

Our website and emails may contain links to other websites. We are not responsible for the content or practices of these other sites, and we recommend that you check their own privacy policies.

11. How we protect your Personal Data

11.1 We have appropriate security measures in place to prevent Personal Data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

12. Your Rights

12.1 Under data protection law, you have rights including:

(a) Your right of access – You have the right to ask us for copies of your Personal Data.

(b) Your right to rectification – You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete.

(c) Your right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.

(d) Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.

(e) Your right to object to processing – You have the right to object to the processing of your Personal Data in certain circumstances.

(f) Your right to data portability – You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.

(g) Rights related to automated decision making, including profiling –You have the right not to be subjected to a decision based solely on automated processing (including profiling) which may significantly affect you. We do not make any employment decisions, solely using automated decision making technologies.

12.2 In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request. If we need to extend the time period for responding to your request, we will let you know within the one-month period. We do not charge a fee for any such requests, unless there are exceptional circumstances.

12.3 If you wish to exercise any of your rights, please contact our Data Protection Office via email using dataprotection@icaew.com.

13. Complaints

If you have any concerns about the Personal Data we use about you, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, by contacting them at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance via email using dataprotection@icaew.com.

Updated September 2024