How CPI uses your information
1 – Who we are
We are the Confederation of Paper Industries Ltd, a company incorporated in England and Wales with registered number 3886916.
We are also registered with the Information Commissioner’s Officer with registration number Z8439281. This registration covers the uses of personal information set out below.
2 – How we collect your personal information and why
The Confederation of Paper Industries Ltd (we, us, our, CPI) may need to collect personal information about you, and there are different ways that we might do so; this privacy notice tells you what to expect when we collect personal information on:
(a) visitors to our website, www.paper.org.uk;
(b) anyone who interacts with us or contacts us through social media;
(c) anyone who contacts us (other than for the purposes of membership of CPI);
(d) anyone who applies for membership of CPI;
(e) any user who has access to our membership only areas;
(f) anyone who subscribes to our newsletter.
2.1 – Visitors to our websites
Our website (including the application forms) is managed by [ ]. As part of the service provided by [ ], they will help to maintain the security and the performance of our website by (i) encrypting data in transit and protecting user connections (ii) using third party scanning services to scan against known web attacks (iii) investigating site errors and (iv) providing secure hosting services through [Microsoft Azure]. [ ]’s privacy notice can be found at [www.[ ]
2.1.1 – Cookies
You can block cookies at any time by activating the setting on your browser that allows you to refuse some or all cookies. However, if you do block cookies there may be parts of our website that you will be unable to access or that will not function properly.
We use the following types of cookies:
(a) Strictly necessary cookies
These are cookies that are essential for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and session cookies that remember your login information. If these are disabled then various functionality on the website may be broken
Strictly necessary cookies
[ ] [ ] [ ]
(b) Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Google Analytics – stores each user’s amount of visits, and the time of the first visit, the previous visit, and the current visit
Google Analytics – used to check approximately how long you stay on a site: when a visit starts, and approximately ends
Google Analytics – works with _utmb and do approximately the same job
Google Analytics – stores where a visitor came from (search engine, search keyword, link)
(c) Functionality cookies
These are used to recognise you when you come back to our website so that we can personalise our content for you, greet you by name and remember your preferences (for example, your region).
[ ] [ ] [ ]
(d) Targeting cookies
These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
2.1.2 – Third party services
(a) Whenever you visit our website, www.paper.org.uk we will use a third party service, Google Analytics, for our legitimate interests, to collect standard information about your website use, such as internet logs and details of your visitor behaviour patterns. The reason we use this service is so that we can find out how many people visit the website and the various parts of the website. This information helps us to find out how our website is working and how to improve it. We do not identify anyone, and we do not make or allow Google Analytics to (or attempt to) identify anyone visiting our website other than as set out in this privacy notice.
(c) Some cookies used on our site are provided by third-parties, for example pages that contain embedded content, such as YouTube videos, may send you cookies. These cookies are out of our control and you should check these third-party sites for further information.
2.2 – Social media
Our website contains links to our social media pages. Any information you provide to us or share from us via social media (including messaging, “liking”, “following” and other communications) is controlled by the social media network. We currently use:
2.2.1 Facebook, which has its own privacy notice that can be located at https://www.facebook.com/privacy/explanation;
2.2.2 Twitter, which has its own privacy notice that can be located at https://twitter.com/en/privacy;
2.2.3 Instagram, which has its own privacy notice that can be located at https://www.instagram.com/about/legal/terms/api/; and
2.2.4 LinkedIn, which has its own privacy notice that can be located at https://www.linkedin.com/legal/privacy-policy.
We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal information. Contacting us (other than in respect of an application)
2.3 – Contacting us (other than in relation to membership)
Our website provides you with different ways to contact us. All communications are handled, reviewed and responded to internally by us.
Please note, however, that:
(a) email monitoring or blocking software may also be used and that you have a responsibility to ensure that any email you send to us is within the bounds of the law;
(b) we use caller ID services, we will only use this information for the purposes of handling your call and contacting you in relation to the purpose of your call.
2.4 – Application for membership
We only accept applications from commercial entities. The applicant confirms that it has complied with all data protection laws (including the General Data Protection Regulation (EU) 2016/679) in providing the personal information of any named contact or individual as part of the application process and has provided a copy of this privacy notice to all such named persons.
2.5 – Accessing our membership only areas
As part of the application, a member will also submit personal information about its contacts and users that we require in our legitimate interest. This includes their name, address, additional contact details and job role with the member. It is the member’s responsibility to ensure that their named contact is provided with this privacy notice in respect of what we will do with their personal information.
Any personal information that is provided by a member as part of an application is used only for the purpose of reviewing the application granting membership website access controls out and conducting the ongoing administration and management membership.
Please note that we may need to contact your named contacts about the application or membership through any of post, email or telephone. Please can you make sure that you keep us updated of any changes to their contact details.
2.6 – Subscribing to our newsletter
We will collect your contact details (name and email address) in our legitimate interest, if you have opted to subscribe to our e-newsletter. We will provide you with a clear choice in an application or purchase to opt out of receiving our newsletter at the time of your application. Where you have not completed an application or made a purchase, you may still chose to receive our newsletter, but you will have to opt into receiving it or contact us to explicitly ask to receive it.
We use third parties, [ ] and [ ] to manage our newsletter subscriptions. If you ever decide you no longer wish to receive our newsletter, you can do so at any time by unsubscribing from the mailing list, using the link provided in the newsletter email, or by using the contact details below. If you do unsubscribe, please note that [ ] will still keep your email in a separate secure list on our behalf so that we can make sure that you do not receive our newsletter again in the future.
3 – Disclosure of personal information
We do not transfer personal data outside of the European Union.
We will not usually disclose your (or your contacts’ and users’) personal information other than as already explained in Section 2 above. However, there may be circumstances where we need to share personal information other than as anticipated in Section 2 above. These include:
3.1.1 where we are legally required to disclose the information. This includes sharing the personal information with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;
3.1.2 where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
3.1.3 disclosure is required to protect the our interests;
3.1.4 disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);
3.1.5 it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required we will take steps to ensure that the third party protects the personal information in the same way that we do.
4 – Keeping personal information secure
We know that you provide your personal information in good faith and expect it to be look after. This is why we take the security of your personal information seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal information. This includes:
(a) [keeping special categories of data in a separate password protected file to all other personal information;] (b) [locating all personal information that we control on internal servers located in the United Kingdom;] (c) [ensuring strict access controls on a need to know basis;] (d) [monitoring access to the personal information; and] (e) [double encryption of the personal information on our servers.]
5 – Your rights
You have rights in respect of your personal information and this Section explains a bit more about those rights that are applicable to what we do with your personal information and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out below.
5.1 – Accessing your personal information
We want you to fully understand and be comfortable with how we use your personal information. You can contact us at any time to ask whether we process any personal information about you. If we do hold or use your personal information in any way, you have the right to access that personal information. All we ask is that:
5.1.1 you make your request to access in writing to the contact details below;
5.1.2 you verify your identity; and
5.1.3 you are fair and reasonable with how often you make this kind of request.
Please allow us up to one month from receipt of your request in order to provide a response.
5.2 – Requesting more information
We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal information. We have tried to be as clear and as open as we can. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details below.
5.3 – Additional rights[From 25th May 2018], you will also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses below and provide verification of your identity.
5.3.1 You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address)
5.3.2 You have the right to request that we erase your personal information. Please be aware that we can only comply with such a request if
(a) your personal information is no longer required for the purposes it was collected for (for example, we need your personal information to [respond to a communication];
(b) the collection, storage or use of the personal information by us is prevented by law;
(c) we do not require your personal information for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.
5.3.3 You have the right to request that we restrict or refrain from processing your personal information:
(a) for the time it takes us to verify the accuracy of your personal information where you have disputed its accuracy;
(b) where the collection, storage or use of the personal information by us is unlawful but you decide not to ask for erasure;
(c) where, we no longer need your personal information but you need them for the purposes of establishing, exercising or defending a legal claim;
(d) for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal information, where you have exercised your right to object to processing.
5.3.4 You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract. If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.
5.3.5 You have the right to object to our use of your personal information:
(a) where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal information; or
(b) at any time, where we use your personal information to send you the newsletter or any other type of direct marketing, in which case it will no longer be used for that purpose, but may use it for another lawful purpose.
6 – Complaints
You are important to us, and so is protecting your personal information. We have high standards when it comes to collecting and using personal information. For this reason, we take any complaints we receive from you about our use of your personal information very seriously and request that you bring any issues to our attention.
Where you are communicating with us for the purpose of making a complaint, we will only use your personal information to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of CPI team, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don’t want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis.
If you are unhappy, you can also contact the Information Commissioner’s office to make a complaint directly.
7 – Updating this privacy notice
We keep our privacy notice under regular review in order to ensure that it properly reflects our use of personal information. This privacy notice was last updated on [DATE].
8 – How to contact us
You can contact us by:
8.1 Post: [ ] 8.2 Email: [ ] 8.3 Telephone: [ ]