Welcome to the Libraries Connected privacy policy.

Libraries Connected respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website at https://www.librariesconnected.org.uk/ (“our website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy also applies to any personal data collected or received through means other than our website – for example via email, telephone, post or face-to-face contact.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Libraries Connected collects and processes your personal data, including any data you may provide when (if applicable) you sign up to one or more newsletters or mailing lists, obtain a product or service, take part in a competition or survey or otherwise engage with us. 

Our website is not intended for children and we do not knowingly collect data relating to children. If you are below 16 you must stop using our website unless you have our express written consent to use it.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any such notices and is not intended to override them. 

Controller

Libraries Connected is the controller and responsible for your personal data (collectively referred to as "Libraries Connected", "we", "us" or "our" in this privacy policy). 

We have appointed a Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as set out in paragraph 9 of this privacy policy), please contact the Privacy Manager using the details set out below. 

Contact details

Our full details are:

Full name of legal entity: Libraries Connected (charity number 1176482)

Name and title of Privacy Manager: Isobel Hunter, CEO

Email address: isobel.hunter@librariesconnected.org.uk

Postal address:

Mailbox 1201
Maggie O'Neill Business and Training Centre
433 Liverpool Road
Huyton
Liverpool L36 8HT

Telephone number: 020 33701 2306

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 1 March 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy/notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity & Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, job title, employer, billing address, home address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Services Data includes details of products and services you have obtained from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. 
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Awards Data includes lists of achievements, nominations for Queen’s honours and other awards.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not routinely collect Special Categories of Personal Data about you (this includes 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). We may however collect certain special categories of special data where relevant to a project on which you are involved, with your explicit consent. We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise, including face-to-face contact. This includes personal data you provide when you:

• obtain or enquire about our products or services;
• create an account on our website;
• subscribe to our service or publications; 
• attend our events or training;
• participate in one of our projects;
• engage with us in respect of funding, bursary or awards notification;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at paragraph 10 for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 

• Technical Data from the following parties:

(a)    analytics providers such as Google, some of whom are based outside the EEA; 
(b)    advertising networks, some of whom are based outside the EEA; and
(c)    search information providers, some of whom are based outside the EEA.

• Identity & Contact, Financial and Services Data from providers of technical, payment and delivery services, some of whom are based outside the EEA.
• Identity & Contact Data from data brokers or aggregators, some of whom are based outside the EEA.
• Identity & Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EEA.
• Identity & Contact Data and Services Data from software/providers we use such as Learning Pool and Basecamp.
• From your employer and/or the library service with whom you are associated.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan (or may in the future plan) to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. It is entirely your choice whether you consent to us providing you with direct electronic marketing – we will only do so where you have given us your consent to do so. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us to stop (and to ask third parties to whom we have provided your personal data to stop) sending you marketing messages by contacting us at any time. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. 

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

Where none of the above apply, we will ask you to specifically consent to the transfer.

7. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our data retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

If you wish to exercise any of those rights (as further detailed in the Glossary), please contact us. 

No fee usually required

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.