This privacy notice governs the collection, storage, use, disclosure and disposal of personal information collected by us, Reform. It provides details about the personal information that we collect from you, how we use your personal information, your rights regarding the personal information that we hold about you and how to contact us or make a complaint.
For any questions relating to Reform’s Privacy Notice, please contact: email@example.com
Our full name is Reform Research Trust and our registered office is at 5 – 6 St Matthew Street, London, SW1P 2JT. We are a company limited by guarantee with registered number 5064109. We are a charity with registered charity number 1103739 .
We are an independent, non-party think tank whose mission is to achieve better and smarter public services and economic prosperity. We conduct research which we publish and host conferences and events bringing together a range of stakeholders including from industry, charities, trade associations, journalists, Government, parliament and Whitehall who have an interest in our aims.
Reform is a ‘data controller’ in respect of the personal information that it processes.
What personal information do we collect about you?
We only collect a minimal amount of personal information about individuals who are (or are employed by) stakeholders, sponsors, donors and suppliers including name, job title, organisation, and contact information (e-mail, phone number, address and postcode). We also collect financial information from our donors and suppliers relevant to donations and the provision of goods and services.
We collect this information by a number of means including:
- directly from the individuals themselves;
- from desk-based research into stakeholders with an interest in topics relevant to Reform’s aims using public sources such as websites;
- recommendations from other stakeholders;
- recommendations from members of Reform often following meetings or shared policy platforms with them; and
- (for journalists) by subscribing to the Roxhill media platform to create media lists which are relevant to the dissemination of our research or policy papers and through direct engagement with journalists by members of Reform.
We also collect personal information about stakeholders when they sign up to receive our newsletter.
Why do we process personal information?
We process your personal information for the following purposes:
- receiving and processing donations and maintaining donor relationships;
- the provision of goods and services;
- organising events;
- updating stakeholders on relevant policy events and reports;
- communicating with journalists on relevant news, events and reports; and
- communicating with stakeholders via our newsletters;
- contacting you to benchmark our performance.
What is the legal basis for the processing?
We process personal information for the purposes described on the basis that it is in our and your legitimate interests, that you would reasonably expect this processing and that it does not materially impact your rights, freedoms or interests.
Where we have a contractual relationship with you, we may process your personal information as necessary for the performance of that contract or prior to entering into it.
What do we do with your data?
We only collect personal information for the purposes described. We believe in and carry out a policy of data minimisation. Reform holds no sensitive personal data of stakeholders other than in the normal way that Members of Parliament are classified by party affiliation (e.g Labour/ Conservative/ LibDem/ SNP/ DUP member for x constituency).
All the personal data that we handle is processed by our staff, who are all based in the UK. We do not carry out any automated decision making which is likely to have a legal or similar effect on you. All our staff are subject to an obligation of confidentiality and are aware of our data protection obligations.
We take appropriate technical and organisational measures to safeguard the personal information that you provide to us.
How do we share your personal information and who do we share it with?
We only share your personal information with the following third parties and under the following circumstances:
- Sponsors: we share the names, organisations and job titles of prospective and actual attendees and speakers at events with event sponsors to allow them to tailor their input to the event, to evaluate the success of an event and to make decisions regarding future sponsorship of events. They agree that this information will be used by them only for these purposes and will not be used for marketing purposes.
- Think-party service providers: we share information with third-party service companies to facilitate or to provide certain services on our behalf. This will include IT infrastructure companies that facilitate our provision of Reform's services to you; and IT support service providers (these companies are authorised to use your personal information only as necessary to provide these services to us).
- Law enforcement or other authorities: we will share personal information if required by applicable law.
Our cloud storage company is located in the U.S. and is certified under the EU-U.S Privacy Shield Framework. This protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes and has been the subject of an adequacy decision by the European Commission.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, like and dislikes by gathering and remembering information about your preferences.
Below are example cookies the site uses:
Cookies set by Reform site
100 day duration. Allows the site to know if cookies are accepted. Set to "2" if user has enabled cookies. Empty/Unset if not accepted.
Cookies set by Google Analytics
_ga, _gat, _gid
Various duration: a mix of session and permanent cookies lasting 30 mins, 6 months, or 1-2 years. Anonymously tracks use of website. These cookies are set or updated on any page visited. Several cookies are set but all serve the same purpose: to see how people reached the site and used it, including search terms and referring sites.
Cookies set by Add2Any
_utma, _utmb, _utmc, _cfduid
Various durations. Anonymously tracks page visits, times when a user encounters social sharing buttons and their usage.
Cookies set by Twitter
guest_id, _twitter_sess, personalization_id
Various duration: a mix of session and permanent. Various anonymous settings and session cookies used by the Twitter platform. Only set/used when a page contains content from Twitter.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other that the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
How long do we keep your data?
We check annually to ensure that stakeholders are still working at the organisations and in relevant roles within those organisations to justify inclusion on our data-base. If not, their personal information is deleted.
We keep donor personal information for the duration of our relationship with you.
Where we have a contractual relationship with you and/or hold financial information, we are required to retain this information for seven years.
Transfer of your information out of the EEA
A very small number of our sponsors are based outside the EEA. Non-EEA countries do not generally have the same data protection laws as the United Kingdom and EEA. We will comply with data protection law in sharing your personal information with these sponsors and will do so only when:
- they are located in countries which have been determined by the EU to provide adequate data protection safeguards and, in the case of the US, the sponsor is certified under the EU-US privacy shield; or
- subject to standard data protection contract clauses which have been approved by the European Commission. A copy of these is available on request.
What are your rights in relation to the personal information that we hold?
Under data protection laws you have a number of important rights free of charge. In summary, those include the right to:
- access to your personal information and to certain other supplementary information this Privacy notice is designed to address;
- require us to correct any mistakes in your information which we hold;
- require the erasure of personal information concerning you in certain situations;
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that information to a third party in certain situations;
- object at any time to processing of personal information concerning you for direct marketing;
- otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- write to us (either by post or email) at Reform, 5 – 6 St Matthew Street, London, SW1P 2JT or firstname.lastname@example.org;
- let us have enough information to identify you
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill);
- let us know the information to which your request relates; and
- we will aim to respond to you within a one month period.
If you would like to unsubscribe from any marketing material you receive from us you can do so by writing to us (either by post of e-mail) at Reform, 5-6 St Matthew Street, London, SWIP 2JT or email@example.com. It may take up to 10 working days from receipt of your request for this to take place.
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. Please contact us at firstname.lastname@example.org.
If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain to the Information Commissioner’s Office (https://ico.org.uk/) or seek to remedy through local courts if you believe your rights have been breached.