Last updated: 10/05/2023

‘The All-Party Parliamentary Group for Environmental, Social, and Governance’ and the ‘APPG on ESG’ are the names of an informal cross-party group within Parliament that has a particular interest in Environmental, Social, and Governance. The All-Party Parliamentary Group for Environmental, Social, and Governance utilises College Green Group Ltd, a company registered in England with company number 12270590 and with a registered address at 77 Victoria Street, Office 120, London, United Kingdom, SW1H 0HW (‘College Green’) as its Secretariat. Under this policy, the data controller is The All-Parliamentary Group for Environmental, Social, and Governance. The All-Party Parliamentary Group for Environmental, Social, and Governance uses College Green as a Data Processor. [College Green’s privacy policy can be found at https://www.collegegreengroup.com/privacy/.]

This policy sets out the basis on which any personal data we (The All-Party Parliamentary Group for Environmental, Social, and Governance) process that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The All-Party Parliamentary Group for Environmental, Social, and Governance is committed to ensuring privacy and compliance with UK Data Protection law. This Privacy Policy explains our approach to personal data, and we comply with our obligations under the ‘Applicable Privacy and Data Protection Law,’ which includes: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (‘UK GDPR’), the Data Protection Act 2018, the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.

It is important that you read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.

By interacting with our Website ([https://www.appgesg.org] or The All-Parliamentary Group for Environmental, Social, and Governance) in other communications you must be willing to be bound by the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then please stop communication with us.

For the purposes of this Privacy Policy, the term ‘Personal Data’ means any information, which identifies you, or which allows you to be identified when combined with other information. It does not include data where your identity has been removed (‘Anonymised Data’).

Information We Collect And How

When you communicate with us, including attending any event we organise, we may collect certain Personal Data that can be used to identify you. Any data that does not enable you to be identified will not be considered Personal Data.

We may collect information and Personal Data from you:

• Via your interaction with us online or via our Website;
• Through social media engagement including responses to online advertisements;
• By email;
• Over the phone; or
• In-person (e.g. paper-based records).

We may collect and process the following data about you:

Personal Data that we require in order to keep you informed of our work and activity will include First name, Last name, email or postal address, telephone numbers and social media account information. Other information may be gathered depending on the circumstances. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

Device Information

When you use our Website, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, and advertising ID), language, time zone and IP address. For more information, please refer to our Cookie Policy.

Information we obtain from third parties

We may receive information about you from our third-party service providers (such as Google Analytics or social media platforms like Facebook), who collect this information through our social media or from interaction with our Websites in accordance with their own privacy policies.

Special category data

The information you may provide to us may include personal data revealing racial or ethnic origin, political opinions and other special categories of data. Such categories of data may be considered Special Categories of Personal Data for the purposes of the Applicable Data Protection Law unless they are adequately anonymised. We shall always process such personal data with suitable care and in accordance with the data protection law.]

Use of Personal Data

We may use information about you for various purposes, including to: Provide, maintain and improve our website and social media content, and to communicate with you which will include sending you newsletters and other information on our activity or political content that we think will be of interest to you.

Sharing of Information

We may share information about you with College Green, consultants and other service providers who need access to such information to carry out work on our behalf, to maintain our online content or output of information; in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation; if we believe your actions are inconsistent with Terms then with our legal advisors.

Aggregated Anonymised Data

The information we collect from you may be combined with information provided by others, but only in an anonymised format, to produce aggregated anonymised data sets for research purposes. We refer to this combined data as ‘Aggregated Data.’ Aggregated Data is not considered to be Personal Data as it does not reveal your identity. However, in the event that we combine or connect Aggregated Data with any of your Personal Data that enables you to be directly or indirectly identified, we will treat such data as Personal Data to be used in accordance with this Privacy Policy.

Use Of Cookies And Google Analytics

The All-Party Parliamentary Group for Environmental, Social, and Governance’s Website may use ‘cookies’ and similar technologies to enhance the users’ experience. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy [https://www.collegegreengroup.com/privacy/].

Legal Basis For Using Your Personal Data

The legal bases we rely upon to use your Personal Data may include your consent and our legitimate interests, or where we need to comply with a legal or regulatory obligation. When processing special category data this will be by consent or the contract you have with us. Please contact us if you require further details concerning the specific legal ground(s) we are relying on to process your Personal Data.

We offer here non-exhaustive examples of the ways in which we use your Personal Data and the legal bases we may rely upon to do so:

• If you are a participant completing one of our surveys, our legal basis for processing is your consent in taking part.
• To administer our Website our legal basis for processing is legitimate interests for running The All-Party Parliamentary Group for Environmental, Social, and Governance.
• We may use your Personal Data if you apply for employment with us, data will initially be processed under consent and then under contract if you become employed by us.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to process it.

Data Retention

Your Personal Data will likely be retained for as long as you remain subscribed to The All-Party Parliamentary Group for Environmental, Social, and Governance. Any Personal Data deemed no longer relevant is deleted. However, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If we have taken steps to anonymise your personal data (so that it can no longer be associated with you) we may use this indefinitely for analytical, research and statistical purposes.

Your Rights

You have a right to withdraw consent and cease to be a subscriber at any time. Whenever we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact The All-Party Parliamentary Group for Environmental, Social, and Governance using the contact details provided at the end of this privacy policy. This will not affect the lawfulness of any processing carried out before you withdraw, nor ongoing contractual or other obligations requiring us to process data for example due to a court-ordered law enforcement request.

The UK GDPR provides the following rights for individuals:

• The right to be informed – is met by this policy and the information provided when you have contact with us.
• The 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 information you think is incomplete.
• The right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.
• The right to restrict processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
• The right to data portability – You have the right to ask that we transfer your Personal Data to another organisation, or to you, in certain circumstances.
• The right to object – You have the right to object to the processing of your Personal Data in certain circumstances.

Your Right To Access The Personal Data We Hold About You

You have the right to make a request to access your Personal Data (known as a ‘Data Subject Access Request’ or ‘SAR’). We aim to respond electronically to all SARs within 28 days. We may require you to prove your identity before we reply to ensure we do not give out personal data to the wrong person. In circumstances where it may take us longer to respond (for example if your request is particularly complex or if you have made a series of requests), we will notify you. We do not charge a fee for responding to a SAR. However, we may charge a reasonable fee if your SAR is manifestly unfounded or excessive.

Changes To This Privacy Policy

We may occasionally update this Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your information.

Opt-out & Unsubscribe

We respect your privacy and give you an opportunity to opt out of receiving communications. Users may opt out of receiving any or all communications from us by contacting us or selecting the ‘Unsubscribe’ option on their email.

Contact Information

If you have a question please contact our Data Controller at [compliance@collegegreengroup.com].

We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time about our processing of your personal information.

If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO).

College Green Group is registered with the ICO with registration number [ZA844556]. The ICO contact information can be found at https://ico.org.uk/global/contact-us/.