TFP may change this policy at any time in which case we shall notify you of any changes to this policy by noting this on this page of our website. The changes will apply to your use of our services after we have given notice. If you do not wish to accept the new policy you should inform us and not continue to use our services. If you continue to use our services after the date on which the change comes into effect, this indicates your agreement to be bound by the new policy.
This policy was last changed on 12 October 2018.
TFP is on the Information Commissioner’s Office (“ICO”) Register of Data Controllers; Registration Number ZA013659.
What information do we collect about you?
Why do we collect this information
Data Protection law says that TFP is allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:
- When it is in our legitimate interest
- When you consent to it
- When it is necessary to fulfil contractual obligations
- When it is necessary to comply with the law
- When it is necessary to protect someone’s life
- When it is necessary to perform a public task in the public interest or for our official functions and the function has a clear basis in law
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.
Where we rely on our legitimate interest, we have detailed what it is below. For clarity, we have also detailed where consent is required.
- If you are a business or an individual acting in a business capacity, we rely on our legitimate interest to process your information in the following way:
|What we use your personal information for||Our reasons||Our legitimate interests|
|Travel news and street news updates for businesses||Legitimate interest||Fulfilling membership requirements for keeping you up to date on Shaping Change|
|Security issues and alerts for businesses||Legitimate interest||Fulfilling membership requirements on Cleaner and Safer Streets|
|Inviting to security groups such as FitzBac||Legitimate interest||Fulfilling membership requirements on Cleaner and Safer Streets|
|Business event invitations, business briefings, talks, training, savings programmes, employee wellbeing programmes||Legitimate interest||Fulfilling membership requirements on Reducing Costs, Events and Promotion, Sustainability, Insight|
|Collecting opinions from feedback forms||Legitimate interest||To gain information about how to improve our services and learn what appeals to our members|
|Insight updates for businesses||Legitimate interest||Complying with membership requirements on Insight|
|Local business activities and member businesses’ offers||Legitimate interest||Fulfilling membership requirements on Events and Promotion|
|Our loyalty scheme||Legitimate interest||To allow you to participate in exclusive offers if you choose to sign-up to our partner, LoyalFree|
- If you are a consumer/member of the general public, we rely on legitimate interest and consent to process your information in the following way:
|What we use your personal information for||Our reasons||Our interests|
|Recording reported issues on a local basis, including security issues||Legitimate interest||Being efficient in delivering customer services|
|To carry out direct marketing activities to keep you informed of offers and consumer-focused activities in Fitzrovia||Consent|
In line with PECR (Privacy and Electronic Communication regulations)
|Promoting the local area to people with an expressed interest|
How will we use the information?
We collect information about you to provide membership services through The Fitzrovia Partnership and requested services through Enjoy Fitzrovia, and if you agree or we are otherwise permitted to do so by law, to email you about other products and services we may think of interest to you.
TFP will not share your information for marketing purposes with third party companies other than for transactional processing.
Using your information Your name and contact details
|How we use your name & contact details||Why?|
|Send you information by email, SMS, or post on membership and business activities such as meetings, briefings and updates, training, events||We keep you up to date to be able to perform our contract with you|
|Process membership and business activities such as training, events, meetings||We do this to be able to perform our contract with you|
|Send you alert messages by text, e-mail or by phone regarding security, travel, local information||We do this to be able to perform our contract with you|
|Fraud prevention and detection||To prevent and detect fraud against either you or Fitzrovia Partnership Business Improvement District Limited – unfortunate, but absolutely essential|
|Keep you informed of exclusive member offers and events||We do this to be able to perform our contract with you|
|Including you in security reporting groups (if necessary)||To identify, detect and prevent crime in the area|
|Keep you informed of local area activities, offers, events||Should you opt in to receive this information including via our loyalty scheme, we do this as per your request|
Your industry, sector, occupation and job information
|How we use your industry, sector, occupation and job||Why?|
|Provide information, business introductions, meeting invites that are suitable to your industry, occupation and job||We do this to be able to perform our commercial and membership obligations|
|Offer services that are suitable for your organisation||We do this to be able to provide you with relevant services to your business and its employees as part of your Fitzrovia Partnership membership|
|To provide business continuity||We do this to be able to perform our commercial and membership obligations|
Your membership activity information
|How we use your membership activity information||Why?|
|Contact with relevant information and meeting invites to business specific activities||We do this to be able to provide you with information that is relevant to the business areas you may represent such as Business Watch, Sustainability, Sector Groups, FitzBAC|
|Keep you informed of activities that may be of interest to you at the relevant levels, for example, training and wellbeing||We do this to be able to provide you with relevant information|
|Analysis based on usage and take up||We do this to assess the popularity of services and activities to help develop new ones|
Your loyalty activity information (if appropriate)
|How we use your loyalty activity information||Why?|
|Trend analysis based on usage, points collected, redemptions||We do this to help develop the programme and to provide products you like and value|
Your contact history with us
What you’ve said to us — for example, on phone calls, during meetings and briefings, at events
|How we use your contact history||Why?|
|Provide customer service and support||We’ve got to do this to perform our contract with you, so you receive the best service from us|
|Tailor training, events, meetings, briefings||Adapting our services and provisions to meet your needs|
|How we use your attendance history||Why?|
|Provide customer service and support||We’ve got to do this to perform our contract with you|
|Finding out what you, and other customers/members, like||To ensure we are giving you what you want.|
|Finding out which event, training, meeting you attended||To enable analysis on what is the most successful/least successful|
Users of Enjoy Fitzrovia Consumer
We would like to send you information about our services, which include offers and rewards of third-party entities within our community, by email that may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please click here or email firstname.lastname@example.org.
Users of The Fitzrovia Partnership
We may send you information about our services, which include offers and rewards of third-party entities within our community, by email. You have a right at any time to stop us from contacting you. If you no longer wish to be contacted for marketing purposes, please click here or email email@example.com.
How long do we keep hold of your information
We hold on to your information for as long as is needed to be able to provide the services to you, or for as long as is necessary to provide trend analysis or business continuity only.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or left your company or it is no longer needed to provide the services to you. In any event we will delete your personal data on the date within one month after the date on which you end your relationship with us.
You have many rights concerning your personal information. Please quote your name and organisation (where applicable) together with your telephone number and/or email address on any requests. We would be grateful if could clearly indicate what you would like to know or what information you want a copy of (this helps us to more readily locate your data.) Your rights include:
- The right to be informed about whether, where and how your personal information is being used (like this notice)
- The right to access the personal information we hold about you
- The right to access with whom the data may be shared
- The right to request the period for which the data will be stored (or the criteria to determine that period)
- The right to request the correction of inaccurate personal information we hold about you
- The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
- The right to stop direct marketing messages, which you can also do through ‘unsubscribe’options, and to withdraw consent for other consent-based processing at any time
- The right to request that we transfer or port elements of your data either to you or another service provider
- The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office (ico.org.uk)
If you would like a copy of some or all of your personal information, please email firstname.lastname@example.org or write to us at the following address:
Fitzrovia Partnership Business Improvement District Limited
13 Fitzroy Street
As part of this request, we will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.
We will respond to all enquiries/subject access requests within 30 days. This may be extended to 90 days in exceptional circumstances for highly complex requests. You have the right to make as many access requests as you would like, however frequent and repeated requests may incur reasonable charges to cover the administrative time required. Should this arise, it will be discussed with you. You have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioners Office (ICO) and you can find out how to do this online here: https://ico.org.uk/concerns/
TFP recognises that its customers are increasingly concerned about how companies protect personal information from misuse and abuse and about privacy in general. We are constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.
We use industry standard TLS certificates to provide encryption of data in transit, for example, all access to our website, internal systems and management portals is covered by HTTPS.
Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
Third party service providers working on your behalf
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. When we use third party service providers, we only disclose the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep the information secure and not for use it for their own direct marketing purposes.
Third parties will be required to remove your information from their systems as soon as it is no longer needed for the purposes it was shared for (for example providing services for an event).
Data Storage and Security Systems
TFP stores all personal data securely on either CRM cloud storage systems or its own internal storage systems. All our cloud storage is kept in EU based or EU GDPR compliant data centres which are managed with sophisticated high-level security systems. These storage services have their own data protection policies which we can provide you with on request. We choose storage providers with excellent security policies and systems to ensure minimal risk of data breaches and unauthorised access.
Our internal storage and communications systems are protected by high level, managed security systems, which are updated regularly.
Our IT infrastructure is managed by experts and is regularly reviewed to ensure security is constantly up to date.
How to contact us
Fitzrovia Partnership Business Improvement District Limited
13 Fitzroy Street