INTRODUCTION
This Privacy Policy is intended to describe the practices The Spectator (1828) Ltd (referred from here as The Spectator) 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
This Policy refers to personal information provided, on behalf of a company or business partnership entering the Awards (the “Entrant”) by a director, partner or senior executive (the “Representative”, who may also be referred to as “you” and “your”) on behalf of that company or partnership. The provision of your personal information to us is optional; however, to process the Entrant’s entry for the Awards, 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 permit us to process your personal information thereafter will result in the Entrant not being able to participate in the Awards.
WHO MANAGES THE INFORMATION?
The Spectator (1828) Ltd (“we”, “us” or “The 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 Thursday 4 April 2024.
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 Representatives of Entrants. It may include the Representative’s name, contact details (email, work phone number and address) 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 an entry form to be completed. Mandatory data fields will be marked in the entry form via a red asterisk.
The Spectator may seek information about an Entrant, its Representative(s) or other directors, partners and executives to confirm or supplement information contained within the entry 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, The Spectator will also ask Entrants for financial information relating to the Entrant.
In submitting financial information for the purposes of the Awards, the Representative confirms that: the provision of such information does not breach the privacy or any other legal rights of the Entrant which is the subject of the information; the information has been obtained in a duly authorised manner; and the Representative is duly authorised to provide The Spectator with the right to use such information in connection with the Awards.
ACCESS TO AND TRANSFER 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:
- Representatives of Entrants can access (read, edit, print) the personal information relating to the Entrant’s nomination prior to their form being submitted. After submission, Representatives can only view the respective entry form on a read-only basis.
- Judges can access personal information relating to the Entrants they are judging. The Judges include non-Spectator personnel who will be given access to entry forms in order to evaluate them. Judges will typically be located in the geographic area of the particular Entrant. Once the judging period is completed, a judge will be asked to delete all copies of the information provided to them.
- The sponsor of the Awards, Investec Wealth & Investment (UK) (“the Sponsor”), will be given access to personal information about the Representative of the Entrant included in the entry form or otherwise gathered for the purposes of the Awards process.
- The Organiser will create a bespoke and detailed entry form, of which all entrants’ data can be shared with the Sponsor. The Sponsor shall have the right to contribute to the entry form with questions to be included.
- 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 Representatives of Entrants for the Awards. Generally, such information is available to Spectator personnel on a “need to know” basis (e.g. the Events Manager overseeing the Awards ceremony may see the information relating to Representatives of Entrants, whereas employees not involved in the Awards would not have access to such personal information).
- Venues for regional lunches and podcasts and the Awards ceremony will have access to limited information on Representatives of Entrants (e.g. their names for guest lists or table plans).
- Third Party Email Management Systems will be given email addresses and limited data on Representatives of Entrants.
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 the Entrant’s 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.
2. To invite Representatives of Entrants to attend selected events which The Spectator considers relevant and beneficial to entrepreneurs.
3. To invite Representatives of Entrants to participate in research or thought leadership studies relating to entrepreneurship.
4. For purposes of contacting Representatives of Entrants who might potentially benefit from relevant Spectator service offerings and/or introductions to other entrepreneurs or business leaders.
5. For the development and publication of marketing materials in connection with the Awards, whether such items are intended for an internal or external audience.
The accuracy of personal information held is maintained by The Spectator. Once the Awards for a given year are completed, personal information held is not updated.
In the Awards entry form we will ask your consent to add your contact details into both The Spectator’s and the Sponsor’s Customer Relationship Management systems for marketing purposes. Should you later wish to opt out of receiving marketing materials from The Spectator you may withdraw your consent by emailing data.protection@spectator.co.uk. To opt out of receiving marketing materials from the Sponsor, you may click the unsubscribe link in the Sponsor’s email footer.
DATA RETENTION
Personal information such as Representatives’ contact information will be deleted five years after completion of the Awards, or such period as is required by applicable law. For the period beyond this, the only information that will be retained on Representatives is their name, the Entrant they are associated with, the year it participated in the Awards and whether it was a winner in the Awards. This information is retained so that The Spectator has a complete and accurate history of the Awards.
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 Awards entry 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 and/or sensitive personal data.
ACCESS, RECTIFICATION AND OPPOSITION
Data protection laws operating in many countries around the world provide certain rights to data subjects. The Spectator provides you with 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. Entrants will not be able to participate in the Awards if their Representatives do not consent to the above.