to "we", "us",
or "ICS" are to the Institute of Chartered
Shipbrokers registered under Royal Charter number RC000249, and
registered address is 85 Gracechurch Street, London EC3V 0AA.
References to "this website" are
to the specific Institute website which links to this policy.
For the purposes of the General Data Protection Regulation
or "GDPR" (and all other laws relating to the
use your Personal Data), we are the "data controller", meaning that
we are responsible for deciding how your personal data is used and
more importantly, for keeping your personal data safe and only
using it for legitimate reasons.
We are committed to protecting your privacy and will take all
steps necessary to comply with our legal obligations when using
commitment, so please read this document carefully.
data collection and usage. By using the Institute website,
you consent to the data practices described in this statement.
This policy was last updated on and is effective from 25 May
What Personal Data do we collect?
You may provide us with the following types of personal data
when you interact with us (when using our website or
- Identity - first name, surname, gender, date
- Contact - email address, telephone numbers and
- Financial - billing address, purchase
information, payment history
- Profile - username, ICS number
We may collect the following types of information from you when
you use our website (using Cookies).
- Usage - information about how you use our
digital platforms, including time spent on page, click-throughs,
Cookies: What are Cookies?
Our website may place small text files, called cookies,
on your computer to distinguish you from other users of our
website. These cookies monitor how you use our website so that the
Institute can make improvements, and are also used to give you
smooth usage of our website (for example by remembering your login
details so that you do not have to enter them each time). In most
cases, cookies do not contain personally identifiable data.
How do I opt-out of cookies?
Most web browsers allow some control of most cookies through the
browser settings. To find out more about cookies, including how to
see what cookies have been set and how to manage and delete them,
You should note that deleting certain cookies may prevent you from
accessing certain parts of our website and/or may affect your
access of the membership database.
Surveys and contests
From time-to-time we may request information from
students or members via surveys. Participation is completely
voluntary and the user therefore has a choice whether or not to
disclose any information requested.
Correcting/updating personal data
Students and members can log on to their profile in
shipbrokers.org and view the data that we hold and update it at any
If a user's personal data changes, or if a user no longer
desires Institute's service, the Institute will correct, update or
remove that user's personal data provided to it if they are
notified by the user. This can be done by the user sending an email
How do we use your Personal Data?
The Institute uses the information collected from you for
purposes including the following:
- to provide you with education services and manage your student
- to manage your examinations
- to manage your membership
- to provide you with membership benefits
- to process payments that you make directly to us or through our
- for internal administration and record keeping
- to notify you of changes to this privacy notice, our terms and
conditions or other changes to our services or products
- to answer your enquiries which may involve contacting you by
post, e-mail or phone
- to manage legal claims and other compliance/regulatory
- to verify your identity and detect and prevent fraud and
- to give you the opportunity to provide us with feedback through
reviews and surveys
In addition to the above, we may also anonymise and aggregate
your personal data in a way which means you cannot be identified.
This may be helpful to us for testing our internal systems,
carrying out research and general data analysis. Because this data
is not personally identifiable, we can use it for any purposes.
As a member of the Institute, you will receive some information
from the Institute that is intrinsic to your membership (such as
your membership renewal notice) by post, email or telephone.
However you are able to manage what and how you receive other
communications from us.
The Institute communicates with members in various ways members
and students are invited to tick the boxes in their profile on
www.shipbrokers.org to give the Institute permission to contact you
and keep you informed of all the activities and news at the
Institute and branches.
How to opt-out of non essential
To unsubscribe from non essential communications from the
Institute, you simply need to untick the email and/or post
communication box on your profile in shipbrokers.org or click on
the unsubscribe link at the bottom of the relevant communication
you have received. Alternatively, please
contact us (as detailed below) to opt-out of these
What is our legal basis for processing your Personal
The Institute processes personal data on a 'legitimate
interests' basis under Article 6 (1) of the General Data Protection
Regulation (GDPR). This enables the Institute to provide a
full range of services to its students and members.
Who do we share your Personal Data with?
Your data may be shared with your local Institute branch,
teaching centre or examination centre if appropriate and to our
third party logistics provider for the purpose of distributing our
magazine Shipping Network and other Institute publications to
members and students.
We require these parties to agree to process this information
based on our instructions and requirements consistent with this
Your data will not be shared with any other third party without
your express permission.
We may pass on your personal data to government or regulatory
authorities or law enforcement officials to assist with their
requests and comply with our legal obligations.
Do we send your personal data outside the
The European Economic Area or "EEA" is deemed to have good
standards when it comes to data privacy. As such, we consciously
limit the occasions when we may need to transfer or handle your
personal data outside of the EEA. Where we do, for example to a
branch or teaching centre based outside of the EEA, we make sure
that your personal data is still treated fairly and lawfully in all
respects (including making sure we have a legal ground for sending
your data outside the EEA and putting in place all necessary
safeguards for such arrangement).
What is our personal data retention policy?
We will keep your personal data for as long as you are a
registered student or member, or for as long as is necessary for us
to provide products or services for you, and for a limited period
of time afterwards.
Once you no longer wish to be engaged with the Institute we may
still need to keep hold of your data if there is a legal reason for
doing so (such as for tax purposes where you have made purchases
from us or where we need to resolve any disputes with you).
How do we keep your personal data secure?
We adopt industry standard security processes to ensure your
data is kept safe and secure and to prevent unauthorised access or
use or loss of your data. We also make sure that third parties who
need to handle your data when helping us to deliver our services
are subject to suitable confidentiality and security standards.
Despite the security measures we implement, please be aware that
the transmission of data via the internet is not completely secure.
As such, we cannot guarantee that information transmitted to us via
the internet will be completely secure and any transmission is at
your own risk.
Our websites may contain links to third party websites
and services. Please be aware that the Institute is not responsible
for the privacy practices of such other websites. It encourages its
users to read the privacy statements of these third party websites
and services. This Policy applies solely to information collected
by the Institute.
Your rights as a data subject
At any point whilst the Institute is in possession of or
processing your personal data, you may have the following
- Right of access - you have the right to request a copy of the
personal data that we hold about you.
- Right of rectification - you have a right to correct personal
data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten - in certain circumstances you can ask
for the personal data we hold about you to be erased from our
- Right to restriction of processing - where certain conditions
apply you have a right to restrict the processing of your personal
- Right of portability - you have the right to have the personal
data we hold about you transferred to another organisation.
- Right to object - you have the right to object to certain types
of processing such as direct marketing, as well as processing we
undertake based on our legitimate interests.
- Right to object to automated processing, including profiling -
you also have the right not to be subject to the legal effects of
automated processing or profiling.
If you want to exercise any of these rights, please contact us.
You don't have to pay a fee to exercise your rights, unless your
request is clearly unfounded, repetitive or excessive (in which
case we can charge a reasonable fee). Alternatively, we may refuse
to comply with your request in these circumstances. Where your
request is legitimate, we will always respond within one month
(unless there is a legal reason to take longer, such as where your
request is particularly complex). We may also need you to confirm
your identify before we proceed with your request if it is not
clear to us who is making the request.
In addition to the above, you may get in touch with the ICO
(Information Commissioner's Office) if you are concerned about the
way in which we are handling your personal data. However, where
possible, we would really appreciate you speaking with us first if
you have any concerns.
Notification of changes
If the Institute decides to change this policy, it will
make the updated version available via this website so its users
are always aware of what information it collects, how it uses it
and under what circumstances, if any, it discloses it. If, at any
point, it decides to use personal data in a manner different from
that stated at the time it was collected, it will notify users.
Members and students will have a choice as to whether or not the
Institute uses their information in this different manner. The
Institute will use information in accordance with this policy
if you want to exercise your rights, please get in touch:
Data Protection Officer
Institute of Chartered Shipbrokers,
85 Gracechurch Street,
London EC3V 0AA
By Email: firstname.lastname@example.org