Privacy Statement

About Us

The Association of MBAs and Business Graduates Association (AMBA & BGA) is the impartial authority on postgraduate management education and is committed to raising its profile and quality standards internationally for the benefit of business schools, students and alumni and employers. AMBA established that vision in 1967 and it’s as relevant today as it was almost 50 years ago.

The Business Graduates Association is an international membership and quality assurance body of world-leading and high-potential Business Schools who share a commitment for responsible management practices and lifelong learning, and are looking to provide positive impact on their students, communities, and the economy as a whole. 

Students and graduates of BGA member, validated and accredited Schools may join BGA as individual members.

We also provide guidance and advice to students and graduates, and connect employers and suppliers of services to the Higher Education industry with our member schools and individuals.

Our GDPR Owner and data protection representatives can be contacted directly here:

  • Catherine Walker, Finance & Commercial Director (c.walker@associationofmbas.com)
  • Association of MBAs & Business Graduates Association, 25 Hosier Lane, London, EC1A 9LQ

Updates to this privacy statement

This privacy statement is regularly reviewed. This current version was published in May 2018 to coincide with the EU’s General Data Protection Regulation (GDPR), and updated on 8 November, 2019.
 

Personal data

Under the GDPR personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How and why does AMBA & BGA need to collect and store personal data?

This privacy statement tells you how we, AMBA & BGA, will collect and use your personal data. In order for us to provide you with the relevant service(s) we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

Will AMBA & BGA share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to AMBA & BGA in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf or directly to us. When they no longer need your data to fulfil this service, they will dispose of the details in line with AMBA & BGA’s procedures. If we wish to pass any sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

We use Dotmailer, a UK-hosted third party provider operated by Dotdigital to send and manage our email communications which is certified as adhering to the EU-US Privacy Shield. Please note that Dotdigital is a third-party service that is not owned or managed by AMBA & BGA. This privacy policy only refers to the way AMBA & BGA will use your information. You should refer to Dotdigital’s privacy policy we do not accept any responsibility or liability for their policies. We are reviewing our email service provider arrangements.

When we send you email communications, we monitor whether you have opened the communication and clicked on any included links, using industry standard technology. This will enable us to track and analyse your level of engagement/interest in the communication we are sending you and will provide us with further insight on what type of communications are most of interest to you.

How will AMBA & BGA use the personal data it collects about me?

AMBA & BGA will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

We do not carry out automated decision making or profiling.

How long will AMBA & BGA hold the information for?

AMBA & BGA is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. AMBA & BGA will process and store personal data for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.

Under what circumstances will AMBA & BGA contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. We endeavour to contact you only with information relevant to you.

Can I find out the personal data that the organisation holds about me?

AMBA & BGA at your request, can confirm what information we hold about you and how it is processed. If AMBA & BGA does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of AMBA & BGA or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

What forms of ID will I need to provide in order to access this?

AMBA & BGA accepts the following documentation as proof of ID when information on your personal data is requested:

  • Signed passport
  • Signed driving licence
Your ID will only be used to verify who you are and will not be stored or kept in our database.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by AMBA & BGA (or third parties as described in above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and AMBA & BGA’s data protection representatives.

The details for each of these contacts are:

 Supervisory authority contact detailsAMBA Data Protection Owner contact details
Contact Name:Information Commissioner’s OfficeCatherine Walker
Address line 1:Wycliffe HouseAssociation of MBAs & Business Graduates Association
Address line 2:Water Lane25 Hosier Lane
Address line 3:WilmslowLondon
Address line 4:CheshireEC1A 9LQ
Address line 5:SK9 5AF 
Email:casework@ico.org.ukc.walker@associationofmbas.com
Telephone:01625 545 74502072462686

Read more about how and why we use your data by expanding the section(s) relevant to you below:

How we define our legitimate interest

Professionally relevant individuals.

We may rely on legitimate interest as the legal basis for processing where this is not overridden by your interests and rights or freedoms.

We have therefore conducted a Legitimate Interest Test which includes the following considerations:

  • The relationship between ourselves and you as the data subject
  • The sensitivity of the personal data involved
  • The reasonable expectations we think you have
  • Whether you’d be likely to object to the processing or find it intrusive
  • Any vulnerability you may have
  • How big an impact could this processing have on you as an individual
  • The safeguards we have in place to minimise the risk and impact of a breach
  • Whether a mechanism exists via which you can challenge our assessment

The Purpose Test

We consider that we have a legitimate interest in carrying out a business in favour of the well-being of all our employees and shareholders. This is enshrined in the EU Charter of Human Rights – Article 16 – Freedom to conduct a business. For customers and prospective customers, identified as working for legal entities and whom we consider are professionally relevant post holders; we consider we have a legitimate interest to process your data for the purposes of marketing of products and services. This purpose is supported by Recital 47 of the GDPR which states that:

“The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest”

We believe that professionals rely on being kept up to date about products or services to help them achieve their business objectives. Direct marketing is generally seen as an important tool to facilitate this. However, we will always respect your wishes, if you’re the recipient of our marketing.

The Balancing Test

A balancing test has been undertaken to compare our legitimates interests and the interests or fundamental rights and freedoms of prospective customers who require protection of their personal data,

We will only process personal data if we have determined that our services are ‘professionally relevant’ to you and your organisation. Material that we send to you may be relevant based on your profile, because of the type, size or location of the organisation that you work in, or because you are the right post-holder for a certain set of decisions based on factors like your role, seniority, and responsibilities.

We believe that the recipients of our marketing have a reasonable expectation that we as a Controller will process their Personal Data. The data we may hold on recipients originates from primary research by our research team, publicly available material held on websites, events we have jointly attended, personal data we have captured via business cards or similar interaction, referrals from other organisations, or from your colleagues.

The personal data we hold is limited and in addition is never sensitive data, and in most cases exists in the public domain.

Our assessment has taken into consideration the security measures that AMBA & BGA has in place based on the ISO27001 framework combined with the safeguards we have put in place through the implementation of the British Standard BS10012:2017 – Personal Information Management Framework delivering readiness to GDPR. Outputs of this framework include, but are not limited to:

  • Data Protection Impact Assessments as standard
  • data minimisation
  • de-identification
  • technical and organisational measures
  • privacy by design and default
  • adding extra transparency
  • additional layers of encryption
  • multi-factor authentication
  • data retention limits
  • restricted access
  • opt-out options
  • anonymisation
  • encryption, hashing, salting
  • other technical security methods used to protect data

Our conclusion is that the likelihood of impact and the severity of negative impact or distress of the data processing we undertake is negligible.

However, we want to respect your wishes about how and if you are contacted. On occasion we will contact you to verify your position, check how you would prefer to receive direct marketing, whether by post, by phone or by email and to remind you of your rights via our latest privacy statement. You may of course tell us you do not wish to be contacted at all, and we will respect your wishes, add you to a suppression list, and not contact you again. If you feel we are not being fair with you, please tell us. We would like to correct this. You may also complain to the UK regulator, Information Commissioners Office (www.ico.org.uk).

Private Individuals

We may rely on legitimate interest as the legal basis for processing where this is not overridden by your interests and rights or freedoms.

We have therefore conducted a Legitimate Interest Test which includes the following considerations:

  • The relationship between ourselves and you as the data subject
  • The sensitivity of the personal data involved
  • The reasonable expectations we think you have
  • Whether you’d be likely to object to the processing or find it intrusive
  • Any vulnerability you may have
  • How big an impact could this processing have on you as an individual
  • The safeguards we have in place to minimise the risk and impact of a breach
  • Whether a mechanism exists via which you can challenge our assessment

The Purpose Test

We consider that we have a legitimate interest in carrying out a business in favour of the well-being of all our employees and shareholders. This is enshrined in the EU Charter of Human Rights – Article 16 – Freedom to conduct a business.

Moreover, as a membership body, we consider that we have a legitimate interest in holding the personal information of individuals who have signed up to BGA membership, and that this is essential for the provision of membership services.

The Balancing Test

A balancing test has been undertaken to compare our legitimates interests and the interests or fundamental rights and freedoms of individuals who require protection of their personal data,

We believe that BGA members, prospective students registered with BGA, and event registrants have a reasonable expectation that we as a Controller will process their Personal Data. The data we may hold on these individuals originates from registration forms filled out by the individual him or herself or from online analytics such as Google Analytics.

The personal data we hold is limited and is not sensitive data.

Our assessment has taken into consideration the security measures that BGA has in place based on the ISO27001 framework combined with the safeguards we have put in place through the implementation of the British Standard BS10012:2017 – Personal Information Management Framework delivering readiness to GDPR. Outputs of this framework include, but are not limited to:

  • Data Protection Impact Assessments as standard
  • data minimisation
  • de-identification
  • technical and organisational measures
  • privacy by design and default
  • adding extra transparency
  • additional layers of encryption
  • multi-factor authentication
  • data retention limits
  • restricted access
  • opt-out options
  • anonymisation
  • encryption, hashing, salting
  • other technical security methods used to protect data

Our conclusion is that the likelihood of impact and the severity of negative impact or distress of the data processing we undertake is negligible.

 

However, we want to respect your wishes. If you feel we are not being fair with you, please tell us. We would like to correct this. You may also complain to the UK regulator, Information Commissioners Office (www.ico.org.uk).

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