Privacy policy for the Economic Innovator Awards

INTRODUCTION

This Privacy Policy is intended to describe the practices The Spectator (1828) Ltd follows in relation to The Spectator Economic Innovator of The Year (the Awards) entry process with respect to the privacy of all individuals whose personal information is processed and stored by The Spectator. If you have any questions or you feel that your concerns have not been addressed by this Privacy Policy, please feel free to contact us. Please refer to the Spectator’s Website Privacy Policy for information on how we use your personal information collected via the Spectator website generally.

REQUIREMENT OF INFORMATION

The provision of your personal information to us is optional; however, to process your application your personal information needs to be shared with third parties listed in this policy. Please be aware that your refusal to provide us with your personal information or to process your personal information thereafter will result in you not being able to participate in the Awards.


WHO MANAGES THE INFORMATION?

The Spectator (1828) Ltd (“we”, “us” or “Spectator”) is the data controller of personal information collected by us in relation to the Awards. We respect and safeguard the privacy of all entrants to the Awards.

The information is hosted on servers located at our registered office at 22 Old Queen Street, SW1H 9HP and is backed up on cloud storage.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 24th March 2020.

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.

WHAT TYPE OF PERSONAL INFORMATION IS PROCESSED?

Personal information collected and processed relates to Nominees

Personal information processed relating to the Nominees includes their name, contact details (email, work phone number and address), nominee photograph and company-related information such as length of time with company. This list is not exhaustive.

It is not mandatory for all the data fields within a nomination form to be completed by Nominees. Mandatory data fields will be marked in the nomination form via a red asterisk.

The Spectator may seek information about a Nominee or their company/organization to confirm or supplement information contained within their nomination form for the Awards (“Background Checks”). Background Checks may include information obtained from publicly available sources such as (social) media, credit history, court and other available registers, record-of-offense searches (to the extent permitted by applicable law) or information from third-party sources.

In addition to the personal information that is processed, at a later stage in the Awards process The Spectator will also ask Nominees for financial information relating to their company/organization. Any future personal information gathered will be subject to this Privacy Policy.

In submitting the financial information for the purposes of the Awards, Nominees confirm that: the provision of such information does not breach the privacy or any other legal rights of the company/organisation which is the subject of the information; they have obtained the information in a duly authorised manner; and they are duly authorised to provide The Spectator with the right to use such information for purposes in connection with the Awards.

ACCESS TO AND TRANFER OF YOUR PERSONAL INFORMATION IN THE SYSTEM

The Spectator will not sell, distribute or lease your personal information to third parties (other than those parties referred to below) unless we have your permission or are required by law to do so. We will only disclose your personal information to third parties that have agreed in writing to provide an adequate level of privacy protection. Your personal information may be accessed by the following persons in connection with the Awards:

Nominees can access (read, edit, print) the personal information relating to their own nomination prior to their form being submitted. After submission, Nominees can only view their nomination (read only).

Judges can access personal information relating to the Nominees they are judging. The Judges include non-Spectator personnel that will access the data to view and evaluate the nominations. Judges will typically be located in the geographic area of the particular Nominee. Once the judging period is completed, a judge will be asked to delete all copies of the information provided to them.

Sponsors (including Julius Baer International Limited and others tbc. will be given full access to personal information, including names of Nominees, and in some cases a PDF or similar copy of the nomination form plus any further information gathered for the purposes of the Awards process.

The Spectator personnel at all levels are subject to internal policies and procedures governing the use of private information obtained during the course of their work, and these guidelines apply to private information collected on nominees for the Awards. Generally, Nominee information is available to Spectator Personnel on a “need to know” basis (e.g. the Events Manager overseeing the Awards would generally see the information relating to nominees for the Awards whereas an employee not involved in the Awards would not have access to personal information).

Venues for the regional podcasts and the Awards ceremony will have access to limited information on Nominees (e.g. their first and last name for a guest list or table plan).

Third Party Email Management Systems will be given email addresses and limited data on Nominees.

The access rights detailed above may involve the transfer of personal information in various jurisdictions including jurisdictions outside the European Economic Area. Except where this is on your specific instructions, this will always be subject to adequate safeguards as to the protection and security of your personal data.

WHY DO WE NEED YOUR INFORMATION?

Personal information that is processed is used primarily to support your nomination for the Awards.

In addition, The Spectator may, as necessary for our legitimate interests as the organiser of the Awards, from time to time, use personal information for the following purposes:

1. In aggregated or anonymized form for purposes of research conducted solely by The Spectator or in conjunction with other organisations into topics relating to Economics.

2. To invite certain Nominees to attend select events for Awards or Alumni which The Spectator considers would be relevant and beneficial to entrepreneurs.

3. To invite certain Nominees to participate in research or thought leadership studies relating to topics that affect entrepreneurs

4. For purposes of identifying and contacting Nominees that would potentially benefit from either relevant Spectator service offerings and/or introductions to other entrepreneurs or business leaders that have a relevant interest in meeting such Nominees.

5. For the development and publication of marketing material, promotional publications, media publications and coverage, videos and other materials in connection with the Awards, whether such items are intended for an internal or external audience.

The accuracy of the personal information processed is maintained by The Spectator. Once the Awards for a given year is completed, the personal information is not updated any further.

In the Awards nomination form we will ask your consent to add your contact details in both The Spectators and the Sponsor’s (Julius Baur International Limited) and others tbc. CRM systems for marketing purposes. Should you later wish to “opt-out” of receiving marketing materials from The Spectator or the Sponsors you can always withdraw your consent by emailing The Spectator at data.protection@spectator.co.uk.

DATA RETENTION

Personal information such as participants’ contact information, will be deleted 5 years after completion of the Awards, or for such period as is required under local law. For the period beyond this, the only information that will be retained on participants is their name, the company/organisation they are associated with, the year they participated in the Awards and their status achieved. This information is retained so that the Programme Managers have an entire history of participants. They are frequently asked if a certain company or person has participated in the Awards and if they won an award.

SENSITIVE PERSONAL DATA

Sensitive personal data is data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.

The Spectator does not intentionally collect any sensitive personal data from you in the application process, and it is not the intention to process such information. In addition, please note that free text field(s) should not be populated with excessive personal data (including any sensitive personal data) and/or confidential client information.

ACCESS, RECTIFICATION AND OPPOSITION

Data protection laws operating in many countries around the world provide certain rights to data subjects. The Spectator provides you the ability to keep your personal information accurate and up-to-date. If at any time you would like The Spectator to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your personal information is processed by The Spectator, access your personal information, exercise your right to data portability or withdraw your consent to processing, please feel free to contact us.

SECURITY

The Spectator has implemented accepted standards of technical measures and security policies that protect the personal information in the system which it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.

COMPLAINTS

If you are concerned about an alleged breach of privacy law or any other regulation by The Spectator, please feel free to contact us.

If you are not satisfied with the way in which The Spectator has resolved your complaint, you have the right to complain to the Information Commissioner at www.ico.org.uk or 0303 123 1113.

CONTACT US

If you have questions or you do not feel that your concerns have been addressed in this Privacy Notice, please feel free to contact us.

ACKNOWLEDGEMENT

Upon your electronic acceptance, the terms contained in this Privacy Policy are deemed effective as of the date of that acceptance and shall remain effective for the whole period of your participation in the Awards and following that period, in accordance with the Data retention section above. Those who do not consent to the above will not be able to participate in the Awards.