The Editors’ Code of Practice Committee Privacy Notice
Last updated: August 2024
The Editors’ Code of Practice Committee is committed to proper privacy compliance with General Data Protection Regulation (GDPR) and other privacy legislation as laid out in ICO guidelines. We hope to earn the trust of organisation members, those who are required to meet the standards set by the organisation, and site visitors through respectful and diligent handling of both data and data privacy. To earn that trust, we aim to be transparent and ensure you understand our privacy practices including the information we collect, why we collect it, how it is used and your choices regarding your personal information.
For ease of reading the Editors’ Code of Practice Committee will be referred to as “we, our, us”, and our users will be referred to as “you, your, me, my” for the purposes of this document. If there is any confusion regarding specific wording, please get in touch.
1. Who are The Editors’ Code of Practice Committee?
The Editors’ Code of Practice Committee reviews the Editors’ Code of Practice, which is the foundation stone of the UK press self-regulatory system. It sets out the rules that the voluntarily subscribing newspaper and magazine industry members have pledged to accept.
You can find out more by visiting our About page.
2. Who does this Privacy Notice apply to?
This Privacy Notice applies to our website and services operated by the Editors’ Code of Practice Committee (our “services”).
3. What information does The Editors’ Code of Practice Committee collect about me?
Information you give us.
You choose to give us certain information when using accepting our terms of service.
This includes:
- Contact details: If you choose to provide us with contact details, – through either signing up as a member or through our contact form, we will retain this information to provide any required services and as means of contacting you.
- Cookies: This site uses Google Analytics cookies to collect and analyse information on visitor behaviour. Google Analytics generates statistics and information based on the pages you visit, the length of time you view pages, how the website was navigated to, and what selections you make when using the side. The information we receive is not personally identifiable and is anonymised for our purposes. You can find more information about our service provider’s privacy policy here: https://www.google.com/policies/privacy/
This site also uses WordPress cookies to administer the website. - Service data: If a digital service is carried out for you by us then we will retain information regarding the specifics of this service in our records so it may be recalled if need be.
- Demographic information: We collect basic information about you, such as your preferences and interests, primarily this is carried out by our cookies however you can choose to opt out from giving this information. Basic anonymised information regarding site visitation and usage may still be retained.
Information we receive from others.
In addition to the information you provide to us directly, we receive information about you from others, including:
- Service providers: We may engage service providers when we need to carry out legally required checks (such as Anti Money Laundering legislation [AML]).
Information collected when you agree to our terms of service.
- Device information: We may collect information from and about the device(s) you use when agreeing to our terms of service, including:
- hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
- information on your wireless and mobile network connection, like your service provider and signal strength; and
- information on device sensors such as accelerometers, gyroscopes and compasses.
4. What does the Editors’ Code of Practice Committee use my personal information for?
To provide our services
This includes the contact information you supply us with and any further information we require in order to supply the services we provide to publishers and editors, as well as to other interested parties.
To gather useful information about our users and site visitors.
This includes:
- Required information of you as a client and providing the agreed services;
- Customer support based on the specifics of your request;
- Communicating with you about our services, including service management.
- Keeping record of requests for information retaining to requests for information regarding rulings and adjudications from the committee.
To prevent, detect and fight fraud or other illegal or unauthorised activities.
We perform personal information analysis to better understand and design countermeasures against these activities and retain personal information related to fraudulent activities to prevent against recurrences.
To ensure legal compliance.
And to comply with legal requirements, assist law enforcement and enforce or exercise our rights, for example our Terms and conditions.
5. What are the Editors’ Code of Practice Committee’s legal basis to process my personal information?
Contractual Necessity.
We process your personal information required for the basic functioning of our services and agreements with you. For example, contact information.
Legitimate Interests.
We collect and process information in order to ensure effective service to our committee members and site visitors, and to ensure that we know how to best assist those we need to.
We may use your personal information where we have legitimate interests to do so. For example, for administrative, fraud detection and other legal purposes.
Legal obligation.
In some cases, applicable laws may require us to process certain information about you.
Consent.
We may ask for your consent to use your personal information for certain specific reasons. This may also include your explicit consent to send your personal data to a country where there are not legally adequate protections for the data. You may withdraw your consent at any time by contacting us via the means provided at the end of this Privacy Notice.
6. Who does the Editors’ Code of Practice Committee share your information with and why?
With our service providers and partners.
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including personal information hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also provide aggregated (anonymised) information to third parties. A list of these third parties is available on request.
In corporate governance transactions.
We may transfer your personal information if we are involved, whether in whole or in part, in a reorganisation, dissolution, bankruptcy or other change of ownership or control.
When required by law.
We may disclose your personal information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights.
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request.
We may ask for your consent to share your personal information with third parties.
In any such case, we will make it clear why we want to share the information.
7. How does the Editors’ Code of Practice Committee send information outside of my country?
When we send your personal information outside of your country, we have in place adequate safeguards to do so. As a UK organisation we are compliant with ICO regulations regarding data transfers and operate under the standard parameters of GDPR.
This includes UK/EU/EEA standard contract clauses approved by the European Commission or other suitable safeguard to permit personal information transfers from the European Economic Area (“EEA”) to other countries. In certain circumstances we may also send the data following your explicit consent to do so, including to third countries outside of the jurisdiction of GDPR.
8. What are my privacy rights?
In certain circumstances, if you live in a country that has codified GDPR or are using our UK services as a foreign national, you may exercise the rights available to you under applicable data protection laws as follows:
- If you wish to access, correct, update or request deletion of your personal information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. This may mean your access to certain services is restricted or denied as a result. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Please note not all of these rights are absolute, for example if we have a legal obligation to retain data despite a request from you to delete it. You can exercise your rights at any time by contacting us using the details below. We respond to all requests we receive from users in accordance with applicable data protection laws.
We may ask you to provide proof of identity before we can answer the above requests.
9. How does the Editors’ Code of Practice Committee protect my personal information?
We have implemented, and will maintain current, reasonable physical, technical, and organisational security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
Unfortunately, the transmission of information via the internet is not completely secure.
Although we have security measures in place to protect your personal information, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk.
10. How long does the Editors’ Code of Practice Committee retain my personal information?
Your personal information will be stored in accordance with applicable laws and kept for as long as needed to carry out our services and site functions are detailed in this Privacy Notice; or as required by law.
11. Can this Privacy Notice change?
This Privacy Notice may be amended from time to time. We will post any changes we may make on this page, and to ensure you are aware of when the Privacy Notice was last updated, we will include the date at the top of this page. When amendments are made, we will update the “last updated” date at the top of this Privacy Notice and include a brief section that describes the changes made.
12. How can I contact the Editors’ Code of Practice Committee?
If you have any questions or comments, please contact the data protection team in the following ways:
Email:
editorialcode@gmail.com
By post:
Editors’ Code Committee, c/o News Media Association, c/o Crowe LLP, 2nd Floor, 55 Ludgate Hill, London EC4M 7JW.