The Data Protection Act (directive 95/46/EC) was replaced by the General Data Protection Regulation on 25 May 2018. The new regulation helps us ensure that our members and stakeholders understand what personal data we hold relating to them, why we have it and how we use and store it. We want to ensure that our stakeholders understand and agree to our policy. If something is not clear, or you disagree, you can contact us at any time using the details below.
The ICA considers personal privacy to be very important and this policy explains why we might request personal information, how we store it and when we use it.
The International Cotton Association Limited, or ICA, is the world’s leading cotton trade association and arbitral body. Established in 1841, we operate on a not-for-profit basis which means that the income we generate is used to pursue the organisation’s objectives. Our mission is to protect the legitimate interests of all those who trade cotton. The services that we provide are membership, training, networking and arbitration along with cotton testing and research through our joint venture company, ICA Bremen.
The types of information that we collect across the organisation are:
Name, date of birth, email address, telephone numbers, personal addresses, racial or ethnic origin, IP addresses, device information, business name, business address, nature of business, business age, registration number, website, trading volume, nationality, directorship, annual accounts, association memberships. We also use your banking details to make and receive payments.
We collect your data through a variety of methods. For example, when you apply to become a member, we collect the information from your application.
We use your details from your membership application to populate our member directory and safe trading search on our website. We also add your details to our membership database.
When you sign in to your member area on our website, we see your email address and we can see which pages you visit.
When you sign up to our newsletter, we ask for your email address. The newsletter is provided through MailChimp, a third-party supplier, which gives us insights on links clicked and open rates.
Any data that we share with third-party suppliers is given in order to provide our services. We have carefully reviewed our suppliers to ensure that their data protection processes are compliant and secure.
Most of the data that we hold is processed with the legal basis of Legitimate Interest. Legitimate interest is when we have a business or commercial reason to use your data, but this does not mean that we can use your information in a way that is not right for you. This means that we make sure that you don’t miss out on news, membership matters, event and training dates by using your name and email address to send you notifications, emails and our newsletter. We also use your data in ways that enable us to provide useful services to our members and other stakeholders.
This can include, for example, contacting you:
We aim to keep all Information as accurate as possible. If you would like to review or change the Information that you have supplied to us, please contact us using the details below. ICA will remove any data that is no longer relevant to business pursuit.
All Information will be kept securely as confidential. This means that Information can only be exchanged between you, the ICA and any third party to whom the ICA decides to transfer the Information to for the purposes detailed above. We follow strict security procedures for storing and disclosing data so as to prevent unauthorised access.
The ICA uses industry standard practise to safeguard the confidentiality of the Information. We treat your Information as an asset that must be protected against loss and unauthorised access. ICA employees and relevant contractors use many different security techniques to protect the Information from unauthorised access by users inside and outside the ICA. These include password protection, encryption, firewalls and backup files.
If at any time you decide that you do not want the ICA to retain information that you have provided, you can exercise your right to erasure (right to be forgotten).
Article 17 of EU GDPR, The Right to erasure, states:
Upon request, we will delete or anonymise personal data unless we are legally bound to keep it.
If you want to cleanse your data, contact us using the details below.
In the event that any term of this policy is held to be invalid, unlawful, void or for any reason unenforceable, that term shall be deemed severable and the remainder of this policy shall remain valid and enforceable. No waiver of any term of this policy shall be deemed a further or continuing waiver of such term or any other term.
This policy shall be governed and construed by the laws of England.
Address: The International Cotton Association Limited
Telephone +44 (0)151 236 6041
Fax +44 (0)151 255 0174
Policy last updated 17 December 2018