NFRN Privacy Notice

This is the main privacy notice for the NFRN.

You will find information on what types of data we may hold on you, how and why we process that data and how we will use that data.

Who are we?

NFRN is an employers association registered with the Certification Officer under section 123 of the Trade Union and Labour Relations (Consolidation) Act 1992. Our full legal name is National Federation of Retail Newsagents. Our registered address is Yeoman House, Sekforde Street, London, EC1R 0HF.

NFRN is registered with the Information Commissioner’s Office. Our registration number is Z1679037.

We are a membership organisation engaged in supporting our Members compete more effectively in today’s highly competitive market by providing practical help and assistance, commercial support, deals and buying opportunities, training, expertise and services as well as actively representing our members’ interests at governmental and parliamentary level and are a powerful voice for the independent retailer.

 

How and on what basis do we collect, hold use and/or process personal information?

We will only collect, hold, use and/or process (together “process”) your personal information where we are legally allowed to do so.

We will ensure that your personal information is:

  • processed lawfully, fairly and transparently
  • collected for specific, explicit and legitimate purposes
  • adequate, relevant and limited to what is necessary for the purpose of the processing
  • kept accurate and up to date
  • only kept for so long as is necessary
  • processed securely using appropriate technical and organisational measures to ensure integrity and confidentiality

For us, the lawful basis which we rely on will fall into one of the following:

  • Contractual performancewhere we process your personal information for contractual performance
    This includes enabling us to take steps you request prior to us entering into a contract; and then once we have entered into a contract, to enable us to perform the contract and to provide you with the products and services. We will process your personal information in accordance with the contract.
  • Legitimate interestswhere we process your personal information for our legitimate interests
    We are a membership organisation engaged in supporting our Members.  We have an interest in promoting, marketing, selling and supporting our products and services. Where we process your personal information for our interests we will do so only where we have carefully considered both our and your interests. We will not process your personal information if our interests are overridden by your interests or fundamental rights and freedoms.
  • Consentwhere we rely solely on your consent to process your personal information
    There may be circumstances where we need to or are required to obtain and/or rely upon your consent to process your personal information. If this is the case we will give you:

o  the reason for needing your consent, including details as to how we will process your information

o  the choice as to whether to provide consent

o  information to enable you to withdraw your consent

 

Why do we process personal information and how do we process it?

We process your personal information for a number of reasons. Primarily this will be to enable you to make use of our products, services, training, or to send you, or allow you to access, our marketing material, information relating to your membership, information in relation to the services available to you, and as we’re an association run by its members, we will also inform you of changes to the membership structure. We only process your personal information in accordance with the law, including the EU General Data Protection Regulation, as set out in this privacy notice.

Further information on these is set out below:

Example Lawful Basis for processing
You are a member We will have entered into a contract with you in order to provide you with products, services, content or training
You use our website To help inform you of our products and services. Where we process your information, we will do so with your consent
You attend one of our events To provide you details of the event. Where we process your information, we will do so with your consent
You visit our office The legitimate interests for processing information when you visit our offices is to ensure our and your security and safety during the visit
You apply for a job with us The legitimate interests for processing information you provide us is to facilitate your application for employment
You contact us The legitimate interests for processing information you provide us when you contact us on a specific enquiry is to enable us to address your query
If you are a supplier We will have entered into a contract with you in order for you to supply us with products, goods or services

 

How do we process personal information?

Example Where is the personal information captured
Where you are a member
  • In pre-contract discussions and correspondence
  • In contractual documents
  • When registering, using or receiving our services
  • Where we provide you with support and assistance in the use of our services
If you use our website
  • Via specific forms on our website, e.g. completion of surveys, applications for services etc
  • Via cookies or our website analytic tools
When you attend one of our events
  • Typically, via our website or by a sign-in sheet at the venue or via notice at the event
If you visit our offices
  • When you sign-in to our visitor book
If you apply for a job with us
  • Typically, via email when you send us your CV
If you are contacting us
  • Typically, via email to one of our staff or telephone call to our NFRN Connect team

 

What personal information do we process?

Whilst providing our services, we may require personal data. Personal data is information about you from which you can be identified, such as your name and contact details. Depending on what services you receive from us, this may include sensitive personal data such as medical information. We will not collect any personal data from you that we do not need to provide our service to you.

We may also process other personal information about you when needed to provide support, services or other information that you requested. We will make you aware of what personal information we are processing at the time of when we obtain it.

 

When do we collect it?

Information about you may be collected when:

  • You open an account with partner organisations who provides us with details of your joining
  • One of our field or telephone team members call or visit your premises
  • You write to us or call us (we record our calls) in relation to your membership or attempting to use our services
  • You make a complaint to us
  • You apply for a job or are employed by us
  • You use our website. Please see our separate Cookie Policy here

If you have provided information to us about someone else, you would have confirmed that you have the consent of these individuals to share their personal data with us. You should share this privacy notice with all individuals whose personal data you have shared with us as it may also apply to them.

 

Why do we collect it?

We will only ever process your personal data if we have legal basis to do so. We particularly process data for the following lawful reasons:

fulfilment or preparation of a contract:

–  in order to fulfil our contractual obligations in providing you with the services covered by your membership to the organisation. This may include administering your membership or benefit handling.
–  providing you with the services as described on our website.
–  we may anonymise and combine the information you have given us to create new services, as well as use it for generating statistics for internal and external management or performance reports.
–  recording and monitoring calls for training and security purposes, to improve the quality of our service, to help us deal with queries or complaints from you and to prevent and detect fraud and financial crime.

If you don’t provide the personal data that we request, we may not be able to provide you with the benefits provided as part of the membership you have purchased.

fulfilment of a legal obligation

This is so that we can satisfy any legal and regulatory obligations we may have to keep any records relating to your membership including preventing and detecting fraud, financial crime and money-laundering.

necessary as part of a service you apply for

We may on occasion process sensitive personal data, such as medical information and will only do so if it is necessary for the purposes of your Serious Illness and Convalescence & Respite claims.

Typically we use your personal information for the purposes of:

  • Verifying your identity
  • Developing the design and style of the our products and services to make improvements
  • Understanding more about you, such as your location and demographic information
  • Informing you about the latest changes to our services
  • Informing you of promotional offers that you might find interesting
  • Dealing with and responding to you about an enquiry you have made either direct to us or via social media
  • Enabling you to share our content with others e.g. using “Twitter/Facebook” with the share this article feature on our website.
  • Member services and support
  • Informing you if you have been successful in any competitions or promotions
  • Conducting market research
  • Carrying out statistical, technical and logistical analysis and strategic development
  • Communicating with you in relation to your account or service, service updates or other non-marketing communications
  • Communicating (and personalising such communication) with you, according to your preferences
  • Sending you periodic newsletters and other communications to keep you informed of the organisation and the services available to NFRN Members.
  • Sending you direct marketing. This may include communications by post, telephone or email or SMS about us and our services.
  • Providing you with personalised services, such as recommendations on our websites, apps and in direct marketing and tailored advertising. This includes where we use cookies or similar technologies in relation to the devices you use, for example to make some of the adverts you see more relevant to you
  • Maintaining records of our communications with you if you get in contact with us
  • Blocking disruptive use and ensuring the security of our products and services
  • Ensuring the integrity of votes, competitions and polls

 

Who do we share your personal data with?

We will never sell your information to a third party.
We will only share your information with a third party or transfer your data outside of the UK / EU if we need to. Where we do this, we will comply with all of our legal obligations and we ensure that there are adequate protections in place to protect your information.

If we need your consent we will:

  • explain why we need to share your personal information
  • explain the purpose for which we will be sharing it
  • provide you with details of the third party
  • obtain your explicit consent for such

You will be able to easily withdraw your consent in the same way in which you gave it.

Where we rely on a different lawful basis, such as ‘legitimate interests’ or ‘contractual’, we will do so only to the extent permitted by such lawful basis.

Organisations with whom we may share your personal information with in order to provide you with services include:

   Membership Subscription Payment Collection:

  • Menzies Distribution Company number 01430241, Registered office address: 2 World Business Centre Heathrow, Newall Road, London Heathrow Airport, Hounslow, TW6 2SF. Where we share your information with Menzies Distribution for the purposes of membership subscription payment collection, we do so in accordance with our contractual arrangements with Menzies Distribution, whereby Menzies Distribution are a processor acting on our instructions. For details of the protections that Menzies Distribribution has in place to protect personal information please click here
  • Connect Group t/a Smiths News Rowan House Kembrey Park Swindon SN2 8UH Where we share your information with Connect Group for the purposes of membership subscription payment collection, whereby Connect Group are a processor acting on our instructions. For details of the protections that Connect Group has in place to protect personal information please click here
  • First Capital Cashflow Ltd, 16 Daresbury Court, Manor Park, Evenwood Close, Runcorn, WA7 1LZ Where we share your information with Connect Group for the purposes of membership subscription payment collection, whereby Connect Group are a processor acting on our instructions. For details of the protections that Connect Group has in place to protect personal information please click here
  • Jersey Evening Post Ltd, Guiton House, Five Oaks, St Saviour, Jersey, JE4 8XQ Where we share your information with Jersey Evening Post Limited for the purposes of membership subscription payment collection, whereby Jersey Evening Post Limited are a processor acting on our instructions. For details of the protections that Jersey Evening Post Limited has in place to protect personal information please click here

   Others Organisation we may share information with for the purpose of providing member services:

  • Those whom we use for our back-office systems, for the purpose of hosting those back-office systems.
  • Those whom we use for our website or our other hosted/managed services, for the purpose of hosting such.

o  IDC Limited, IDC House, 76 Oxford Road, Stone, Bucks, HP17 8PL: Provider of NFRN Direct portal and ordering system.  For details of the protections that IDC Limited has in place to protect personal information please click here

o  Site Ground Hosting Limited, 3rd Floor, 11-12 St. James’s Square, London SW1Y 4LB: Host for nfrnonline.com.  For details of the protections that Site Ground Hosting Limited  has in place to protect personal information please click here

o  Quality System Solutions Ltd, Lansdowne Court, Bumpers Way, Chippenham, Wiltshire SN14 6RZ: Provider of Email Marketing and Information Platform.  For details of the protections that Quality System Solutions Ltd has in place to protect personal information please click here

  • Those acting on our behalf for our conferences, events or webinars, for the purpose of providing the facilities, to enable the conference, event or webinar to take place, and where applicable to ensure your safety.
  • Those acting on our behalf to provide our members with legal, financial, insurance and purchasing services, for the purposes of providing those services.

o  ARAG PLC, 9 Whiteladies Road, Clifton, Bristol BS8 1NN.: Provider of NFRN Legal & NFRN Legal Plus services. For details of the protections that ARAG PLC has in place to protect personal information please click here

o  McCambridge Duffy, 35 Templemore Business Park, Northland Road, Derry, BT48 0LD: Provider of NFRN Assist services.  For details of the protections that McCambridge Duffy has in place to protect personal information please click here

o Camelot UK Lotteries Limited, Tolpits Lane, Watford, Hertfordshire, WD18 9RN: We work with Camelot UK Lotteries Limited to assist in maximise the lottery income of our members who are also agents of Camelot UK Lotteries Limited. This involves the NFRN providing Camelot UK Lotteries with the postal addresses or our members retails stores (we do not include names or any other contact details). Click here for details of the protections that Camelot UK Lotteries Limited have in place to protect personal information.

  • Events or webinars, for the purpose of providing the facilities, to enable the conference, event or webinar to take place, and where applicable to ensure your safety.
  • Venues used to deliver our external training courses, for the purpose of enabling the delivery of the training and to ensure your safety when onsite at that venue.

On occasion we may need to refer you to a third party who is not legally related to our organisation. When we are doing this, you will be informed prior to referral. This is only relevant on the rare occasion where we are recommending a solution that we do not offer and where we have a third party who can deal with this on your behalf. Where we need to pass information to a third party, we will send only the information provided to us by the visitor via the online form or any other information that we discuss over the phone. We do not use any other database or services to find out further information other than that provided.

If you decide to enter into a contract with a third party provider through a channel on our website, our telephone agents or field team, the information you have provided to us, together with any further information requested and supplied by you to the third party provider will be held by the provider for the purposes set out in that provider’s privacy policy. Therefore, you are strongly advised to read your chosen provider’s privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We have no responsibility for the uses to which a provider puts your personal information once you have contracted with that provider.

 

Your Consent

By submitting your information, you consent to the use of that information as set out in this policy. If we change our privacy policy, we will post the changes on this page, and may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. We will also email you should we make any changes so that you may consent to our use of your information in that way. Continued use of the service will signify that you agree to any such changes.

 

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • Sending us a request via email to dataprotection@nfrn.org.uk
  • If you wish to stop receiving marketing emails from us, click the unsubscribe link which can be found at the bottom of each email.
  • You may request details of personal information which we hold about you under the Data Protection Act 1998 and GDPR 2018 Legislation. If you would like a copy of the information held on you please write to Data Enquiries Team, NFRN, Yeoman House, Sekforde Street, London, EC1R 0HF.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.