Privacy Policy

The CWU is sensitive to privacy issues on the Internet. We believe that it is important you know how we treat the information about you that we receive on the Internet.

Information Collected

In general, you may visit the Site without telling us who you are or revealing any personally identifiable information about you. Our servers collect the domain names, operating system in use (e.g., Macintosh, Windows) and browser (e.g., Netscape, Internet Explorer). This information is aggregated to measure the number of visits, average time spent on the Site, pages viewed, etc. CWU uses this information to measure the use of our Site and to improve the content of our Site. E-mail addresses and other personally identifiable information such as first and last name, telephone number, and other similar information are known only when voluntarily provided by a visitor for registration or other participation of visitors in any available online interactive activities.

Use Of Your Information

We may use the personal information you provide for any of the following purposes: (1) to understand the use of our Site and make improvements; (2) to fulfill prizes; (3) to respond to specific requests from visitors; (4) to protect the security or integrity of our Site when necessary; (5) to send you notices and solicitations regarding Site and our businesses; and (6) in general to promote and market products to you. These solicitations may take the form of mailings or other couriers, telephone calls, e-mail solicitations and other methods of contact. If you do not want to receive these solicitations from us using your personally identifiable information, please notify us. At times, we may conduct online surveys to better understand the needs and profiles of our visitors. When we conduct a survey, we will try to let you know how we will use the information at the time we collect the information from you on the Internet.

Disclosures Of Your Information

Unless otherwise disclosed during the collection, personally identifiable information that may be collected in connection with visitors to this Site is retained by CWU. The CWU does not sell, transfer or otherwise disclose this personally identifiable information outside this company, except where disclosure is required by law.

Other Websites

This Site may contain links to other sites of third parties. We are not responsible for the content or privacy practices of those other sites. We may revise this Privacy Policy from time to time. You are responsible for checking this policy when you visit our Site to review the current policy. If you do not agree with the policy, you should cease use of the Site immediately.

Cookies

A technology called ‘cookies’ may be used to provide you with tailored information. A ‘cookie’ is a tiny element of data that a web site can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. You may be able to set your browser to notify you when you receive a cookie. Our cookies collect the operating system and browser that a visitor is using.

Access Rights

You have a right to access the personal data that is held about you. Please write to us at the following address to obtain a copy of the personal information CWU holds about you: CWU, 150 The Broadway, Wimbledon, London, SW19 1RX

GPDR – The Communication Workers Union (CWU) Privacy & Data Protection Policy

About us

The Communication Workers Union (CWU) is the largest trade union in the communications sector in the UK, representing approximately 191,000 members in the postal, telecoms, financial services and related industries.

The union is structured into a number of Departments, including:

  • Communications
  • Education
  • Equal Opportunities
  • Health, Safety & the Environment
  • Legal Services
  • Membership
  • Postal
  • Research
  • Retired
  • Telecoms & Financial Services
  • Young Workers

 

The union also has a National Executive Council, and operates a number of Regional, District and Branch offices.

The union’s main website is at: https://www.cwu.org/

The union also operates the following subsidiary sites:

Communication Workers Union Humanitarian Aid: https://www.cwuha.org/

CWU Left Click – The CWU’s online learning platform: http://leftclick.cwu.org/

CWU Young Workers: https://yw.cwu.org/

CWU merchandise shop: https://www.cwu-shop.org/

The union is based at:

CWU, 150, The Broadway,

Wimbledon, SW19 1RX

0208 9717 200

info@cwu.org

 

But for Privacy, Data Protection or General Data Privacy Regulation (GDPR) enquiries please contact the CWU’s Data Protection Officer:

Denis Lenihan

CWU Data Protection Officer

CWU, 150, The Broadway,

Wimbledon, SW19 1RX

020 8971 7279

dlenihan@cwu.org

 

Personal data

The CWU processes personal data in strict compliance with the Data Protection Act 1998 and the General Data Protection Regulations 2018. We ensure that all our staff, Officers and Officials are aware of their obligations when processing personal data on behalf of the CWU.

Your privacy is very important to us and we are fully committed to providing you with clear and transparent information about how we use your personal information.

We will ensure all practicable measures to keep your information secure and will only use it for the purposes set out in this policy.

 

How we collect your information

We may collect data in relation to you:

  • When you register with us, or log into your membership account through our websites
  • When you carry out transactions through our websites
  • When you generate website cookies and traffic analytics  by browsing our website
  • When you fill in any forms on the website, such as surveys or campaign actions
  • When you contact us by email or otherwise
  • When you fill in a membership form

See our website Privacy notice for further information: https://www.cwu.org/privacy/

Personal information

Personal Information can be anything that identifies and relates to a living person.

What information we collect

We may collect information about you such as:

  • Name
  • Date of birth
  • Postal Address
  • National Insurance number
  • Email and telephone details
  • Workplace/Region/District/Branch
  • Payroll number
  • Payment and transactional information
  • Grade
  • Any Union positions held
  • Records of communications from, to or relating to you.

Your equality profile including:

  • Gender
  • Disability
  • Ethnicity
  • Religion
  • Sexual orientation

From time to time, and only where appropriate (i.e. where CWU is recognised for collective bargaining purposes with an employer) and as a necessary part of our activities as a trade union, we may request personal data (usually in relation to your subscription payments) from your employer to ensure that the information we hold is accurate and up to date.

 

Purpose

We need to know some aspects of your personal data to comply with the ‘Aims and Objectives’ of the CWU and the other conditions of the CWU Rulebook and CWU Policy.

This means we need to know some aspects of your personal data to provide you with a full range of membership services, to administer your membership record and to facilitate our relationship with you.

We also provide you with information about CWU activities and other related purposes.

The CWU is committed to principles of equality and proportionality and to meet this commitment better, we are interested to know about members in protected characteristics categories. This is why we ask for this class of personal information, but there is no compulsion to provide this data and you have rights in this regard (see ‘Your Rights’ below)

 

Legal Basis for processing your data

The CWU processes your information under paragraph ‘D’ in the conditions listed in Article 9(2) of the GDPR:

“Processing is carried out in the course of legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects.”

See the section on ‘Lawful basis for processing’ on the Information Commissioner’s Office (ICO) website:

 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/

Who will have access – including any third parties

Some of your personal information will be available to CWU employees, Officers, Branch Officials, workplace representatives and others formally instructed by the CWU for the purposes of carrying out trade union duties. But this will be on the strict basis of data protection best practice and in line with the GDPR data protection principles, meaning that personal data shall be:

Processed lawfully, fairly and in a transparent manner in relation to individuals;

Used for a limited purpose

Processed and stored securely

Accurate and, where necessary, kept up to date

Deleted when no longer necessary

You will also still be able to exercise your individual rights under the GDPR as discussed below (or see the relevant section of the ICO’s website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ )

 

Third parties

Where a third party organisation is carrying out trade union-related processing of your data on CWU’s behalf, the CWU may share the appropriate level of personal data with them. Organisations include those carrying out, on behalf of CWU:

  • Ballots administration
  • Elections administration
  • Legal advice and support
  • IT systems support

The CWU works with a number of affiliates and partner organisations to offer our members a range of supplementary benefits and services. These organisations have close links with the CWU and are therefore, trusted partners who share our ethics and standards.

We will ensure any such third party is GDPR compliant and we also ensure there are strict data protection standards written in to all contracts.

These benefits and services are an important part of our service to members and also provide much needed finance to the CWU that we use to make the union a better and stronger organisation and this benefits us all.

Examples of partner organisations providing services and benefits to CWU members are:

Unionline https://www.cwu.org/unionline/

Member Benefits: https://www.cwu.org/my-union/member-benefits/

 

Will personal data be sent abroad?

The majority of personal information is stored on systems in the UK. But there are occasions where your information may leave the UK, when we engage another organisation to carry out trade union related processing of your data on the CWU’s behalf.

Where this is the case, we will have additional protections on your information in place. These will include secure methods of transferring data and robust contract conditions with that third party abroad.

We will ensure that your personal information is not sent to a country that is not considered ‘safe’ by the Information Commissioner’s Office.

For further information see: https://ico.org.uk/for-organisations/guide-to-data-protection/principle-8-international/

 

Whether provision of data is required and consequences of not doing so

Your membership of the CWU can only function if we can collect certain types of personal information from you (see ‘Purpose’ and ‘What information we collect’ above).

Furthermore, we need to have records of our membership to fulfil statutory obligations in areas such as balloting, elections and returns to the Certification Office.

To ensure that we can communicate with you effectively as a member of the CWU, it is important that the contact details we have for you are up to date. You can make sure that your contact details are accurate, and amend them as necessary, by logging into ‘My Union’.

Alternatively you can contact us, to alert us to any changes, via your Branch or directly via our Membership Dept. (See Contact us at: https://www.cwu.org/contact-us/).

 

How long will data be kept for?

We will only keep your information for as long as we have to. This means that we will retain your information for the period of your membership of the CWU.

But for legal reasons, we also have to retain your record for six years following the termination of your CWU membership. This is because of the potential of future litigation or other claims.

We are also committed to keeping only the information that is required for the above purposes.

If you have communicated with us, but are not a member of CWU, we will retain details of your communication for one year, and for individuals enquiring about membership, we may wish to contact you again within this one year period to follow up your interest. There will be further explanation of this, when you initially express an interest.

 

Security

We take all steps reasonably necessary to ensure your data is treated securely and in accordance with the DPA and GDPR. We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

All individual data will be kept secure, by regular office security procedures or through the controls over the computer network. Sensitive data will be treated with appropriate security. Employees and representatives will also take care to meet high standards of security by disposing appropriately of any written reports, which are generated from individual records.

Further technical details are available on request.

 

Your rights

The law gives you a right to control in relation to what personal information is used by us and how it is used by us.

 

You can ask for access to the information we hold on you

This process is normally referred to as ‘Subject Access Requests’.

You have the right to ask for all the information we have about you and the services you receive from us. When we receive such a request, we must give you access to everything we have recorded about you. However, we cannot let you see any parts of your record which contain confidential information about other people.

Much of the information we have about you will be available to view when you log into ‘My Union’ on our website.

But to make a request for anything not available there, please make a Subject Access Request to our Data Protection Officer whose contact details are:

Denis Lenihan

CWU Data Protection Officer

CWU, 150, The Broadway,

Wimbledon, SW19 1RX

020 8971 7279

dlenihan@cwu.org

 

By making your request direct to the Data Protection Officer, you will ensure a response as quickly as possible. But you can also make your request via any other CWU communication routes.

You can ask us to rectify information you think is inaccurate

You should let us know if you disagree with something in your file. We may not always be able to change or remove that information, but we will correct factual inaccuracies and may include your comments in the record to show you disagree with it.

Please contact the Data Protection Officer to inform us of any inaccuracies.

You can ask us to delete your information

In some circumstances you can ask for your personal information to be deleted. For example:

  • Where your personal information is no longer needed for the reason why it was collected
  • Where you have removed your consent for us to process your information
  • Where there is no legal reason for retaining the information (see How long will data be kept for, above)

Please contact the Data Protection Officer for further information.

Where your information may have been shared with partner organisations (see Who will have access – including any third parties above) we will ensure that they also comply with your request for erasure.

You can withdraw consent for us to communicate with you

Under the legislation, you have the right to opt-out of all communications from the CWU. But if you are a CWU member this will mean that we will no longer be able to carry out the Union’s ‘Aims & Objectives’ in relation to you.

We will not be able to offer a comprehensive membership service and we may have difficulty to comply with our statutory duties in relation to you as a member (to allow you to take part in a ballot or union election for example).

Ultimately, withdrawal of consent will mean that you are hampered in taking a full and democratic part in your Union.

Portability

The Regulations say that you can ask to have your information moved to another provider.

This particular Regulation is mainly aimed at increasing competition in areas such has financial services or utilities, but it does apply to all organisations, so do contact the CWU Data Protection Officer for further information.

You also have the right to complain to the Information Commissioner’s Office.

If you have a problem related to your personal information and how the CWU processes this information you should let our Data Protection Officer know with a view to obtaining a resolution, but you do have the right to make a complaint to the ICO.  Please see contact details below:

Information Commissioner’s Office – Report a concern

If you have a concern about an organisation’s information rights practices, report it to us.

Helpline 0303 123 1113

Our offices: https://ico.org.uk/about-the-ico/who-we-are/

Email https://ico.org.uk/global/contact-us/email/

https://ico.org.uk/concerns/

Policy Review & Update

This policy is publicised on the CWU website and is also available on request from the CWU’s Data Protection Officer (contact details below).

We may change our privacy policies from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons.

We will also keep such polices under regular review to consider any improvements.

When we do, we will give you notice of any material changes by posting the revised privacy policy on our website and by other means.

Denis Lenihan

CWU Data Protection Officer

CWU, 150, The Broadway,

Wimbledon, SW19 1RX

020 8971 7279

dlenihan@cwu.org

Data Protection Register

The CWU is registered to process information by the Information Commissioner’s Office (ICO). You can view the registration on the ICO’s website via link below, or see attached annex.

Data Protection Register – CWU Entry Details

Registration Number: Z6427899

https://ico.org.uk/ESDWebPages/Entry/Z6427899

Annex

Data Protection Register – CWU Entry Details

Registration Number: Z6427899

Date Registered: 20 February 2002    Registration Expires: 19 February 2019

Data Controller: COMMUNICATION WORKERS UNION

Address:

150 THE BROADWAY
WIMBLEDON
LONDON
SW19 1RX

This register entry describes, in very general terms, the personal data being processed by:

COMMUNICATION WORKERS UNION

Nature of work – Trade Union

Description of processing

The following is a broad description of the way this organisation/data controller processes personal information. To understand how your own personal information is processed you may need to refer to any personal communications you have received, check any privacy notices the organisation has provided or contact the organisation to ask about your personal circumstances.

Reasons/purposes for processing information

We process personal information to enable us to provide a range of services to our members which may include administering membership records including the balloting of members and potential members; providing and organising activities for union members; promoting our services; supporting and managing our employees.

Type/classes of information processed

We process information relevant to the above reasons/purposes. This information may include:

  • personal details
  • family details
  • financial details
  • employment and education details
  • goods and services provided

We also process sensitive classes of information that may include:

  • physical or mental health details
  • racial or ethnic origin
  • religious or other beliefs
  • trade union membership
  • sexual life
  • political opinions
  • lifestyle and social circumstances
  • information about offences and alleged offences

Who the information is processed about

We process personal information about:

  • members
  • supporters
  • enquirers, complainants
  • employees

Who the information may be shared with

We sometimes need to share the personal information we process with the individual themselves and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Act (DPA). What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.

Where necessary or required we share information with:

  • current, past or prospective employers
  • suppliers and service providers
  • employment and recruitment agencies
  • family, associates and representatives of the person whose personal data we are processing
  • educators and examining bodies
  • financial organisations
  • trade union and employer associations
  • professional bodies
  • data processors
  • central government 

Transfers

It may sometimes be necessary to transfer personal information overseas. When this is needed information is only shared within the European Economic Area (EEA). Any transfers made will be in full compliance with all aspects of the Data Protection Act.

Statement of exempt processing:

This data controller also processes personal data which is exempt from notification

https://ico.org.uk/ESDWebPages/Entry/Z6427899