Privacy statement

Legal and Privacy Statements

Introduction

Small Cell Forum (SCF) is driving network densification worldwide and encouraging the delivery of fully integrated HetNets. We are a carrier-led organisation. This means our operator members establish requirements that drive the activities and outputs of our technical groups.

SCF respects your privacy and is committed to protecting your personal data. This privacy statement will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy statement.

Important Information and who we are

Purpose of this Privacy Statement

This privacy statement aims to give you information on how SCF collects and processes your personal data when you become a member, or when you attend our events, or use, or apply to use, our services as well as your use of our websites. It is important that you read this privacy statement together with any other privacy statement or fair processing statement we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

Controller

Kava Media Ltd provides secretariat services on behalf of SCF and is the controller responsible for your personal data. Kava Media are registered on the Information Commissioner’s Office (ICO) data protection record ref Z8778999.

Small Cell Forum (SCF) is registered on the ICO data protection record ref Z2926011. SCF (referred to as “we”, “us” or “our” in this privacy statement) is headquartered in the UK. This will mean that data you provide will be processed inside the European Economic Area (EEA).

Privacy Questions

If you wish to exercise any of your legal rights, please contact the Secretariat – secretariat(at) smallcellforum (dot) org

Small Cell Forum
PO Box 23
GL11 5WA
UK

You have the right to make a complaint at any time to the supervisory authority responsible for data protection. In the UK this is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this privacy statement

This version was last updated on 07 June, 2019

We recognise that information privacy is an ongoing responsibility, and so we will update this Privacy Statement as we undertake new personal data practices or adopt new privacy policies. We will notify you of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

  1.  Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name or similar identifier, title, job title and image.
  • Contact Data includes work address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Technical Data includes internet protocol (IP) address, the region or general location where your computer or device is accessing the internet, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, the Working Groups you join, your interests, preferences, and feedback responses.
  • Usage Data includes information about how you use our websites and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Member Contribution data includes information about you and which is posted on message boards, or other message areas or in feedback.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

  1. Data we do not collect about you

We do not collect:

  • information about children;
  • any Special Categories of Personal Data about you other than your image (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data (other than your image));
  • information about criminal convictions and offences. 
  1. How we collect your personal data

We use different methods to collect data from and about you including through:

Direct interactions You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, in person, or otherwise.

This includes personal data you provide when you:

  • apply to become a member;
  • submit any items to us;
  • create an account on our website;
  • request marketing to be sent to you;
  • register for, speak at, or attend Small Cell Forum (SCF) events; or
  • give us feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Statement for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    (a) analytics providers [such as Google based outside the EU];
    (b) advertising networks such as Google Ads based outside the EU; and
    (c) search information providers such as Google based outside the EU.
  • Identity and Contact Data from the SCF Community based both inside and outside of the EU.
  • Membership Contribution Data from other members or users of our website based both inside and outside of the EU.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have asked us for information or to contact you.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

More information about the types of lawful basis that we will rely on to process your personal data is included below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To process your application to become a member and to register you as a new member
(a) Identity (b) Contact (c) Financial (d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for the administration of our community)
To process and fulfil requests and enquiries made by you through our contact form
(a) Identity (b) Contact (c) Financial (d) Marketing and Communications
(a) Necessary for our legitimate interests (for the administration of our community) (b) Performance of a contract with you
To manage our relationship with you, including: (a) Notifying you about changes to our terms or privacy statement (b) Notifying you of Working Groups (c) Notifying you of events
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Membership Contribution
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how our members use our website and services and interact)
To provide you with website features and functionality such as message boards, or other message areas of the ability to leave feedback for other members.
(a) Identity (b) Profile (c) Usage (d) Membership Contribution
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for the administration of our website)
To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our community, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content to you, including our blogs, and measure or understand the effectiveness of this content
(a) Identity (b) Contact (c) Usage (d) Profile (e) Marketing and Communications (f) Technical
(a) Necessary for our legitimate interests (to study how our website users or members use our website and services, to develop them and to grow our community)
To use data analytics to improve our website, marketing, user/member relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to keep our website updated and relevant; to develop our community and to inform our marketing strategy)
To make suggestions and recommendations to you about events, groups or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Necessary for our legitimate interests (to develop our services and grow our community)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which offers may be relevant for you (i.e. marketing).

You will receive marketing news from us if you have requested information from us and have not opted out/unsubscribed from receiving that marketing communication, or you are registered with us for a membership account.

Third Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message send to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Statement

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosure of your personal data

We do not sell or lease personal information to anyone. SCF will only share your personal data with the parties set out below for the purposes set out in the table (at section 4) above:

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our company or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

Small Cell Forum Ltd is a UK registered company. Information we collect from you will be processed by us in UK. We will always protect the privacy and security of your personal data and use your personal data only as described in this privacy statement.

Where we share information globally, both internally within the SCF Community and externally with External Third Parties, information controlled by SCF will be transferred or transmitted to, or stored and processed in, the UK or other countries outside the European Economic Area (EEA) for the purposes as described in this privacy statement. These data transfers may be necessary to provide the services.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use certain service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Our networks are regularly monitored to ensure they remain secure.

In addition, we restrict access to your personal data to those who need to know that information to provide benefits or services to you. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

If you have a password to allow access to certain parts of our website, you must keep that password safe and not share it with anyone, or your personal information could be at risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

We will only retain your personal data for the duration of your membership, business relationship, or other active engagement (e.g. subscription to our newsletters, or attendance at SCF meetings and events) with SCF and for a reasonable period of time afterwards (typically three years) (unless you request erasure sooner) after which we will delete the personal data we hold with the following exceptions:

  • Content you have posted in our discussion forums and other collaboration spaces that are visible to other participants of such collaboration spaces, may continue to be visible indefinitely.
  • If you have consented to receive marketing communications from us, we may continue to use your contact information for such communications until you revoke your consent. We may retain some of your personal data to the extent required under applicable laws and regulations and to the extent necessary to document our compliance with such laws and regulations.
  • We may retain some of your personal data to the extent necessary for tax, accounting, financial reporting, and auditing purposes.
  • We may need to retain some of your personal data indefinitely to support the services we offer. For example, if you have unsubscribed from marketing communications or opted out of certain types of processing (i.e. a suppression list), we would need to retain your unsubscribe or opt-out request indefinitely in order to comply with such request.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further statement to you.

  1. Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of your legal rights, please contact SCF’s secretariat secretariat(at) smallcellforum (dot) org.

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties:

SCF Community means our members as listed on our website here and updated from time to time.

External Third Parties:

Industry Associations with which we have an MOU/Partnership agreement with as listed on our website here and updated from time to time.

Service providers acting as processors based inside or outside of the EU who provide the following services on our behalf:

  • Mail Server: Microsoft Corporation, a company based in the US
  • Collaborative platform: Xendica Ltd, a company based in the UK.
  • Hosting: Xendica Ltd, a company based in the UK. Krystal Hosting Ltd, a company based in the UK.
  • Business/document management: Dropbox, Inc, a company based in the US. EGNYTE, a company based in the US, BackBlaze, a company based in the US
  • Marketing and PR services: Kava Communications (a trading name of Kava Media Ltd), a company based in the UK. Temono Communications Ltd, a company based in the UK
  • Secretariat services: Kava Communications (a trading name of Kava Media Ltd), as SCF secretariat and Data Processor
  • Direct marketing: Campaign Monitor Pty Ltd (trading as Campaign Monitor) a company based in Australia
  • Event management: Inizio Marketing Services Ltd, a company based in the UK. Cvent (providing event registration services as RegOnline) a company based in the US.
  • Accounting: XERO, a company headquartered in New Zealand
  • IT System & Security: Kava Communications (a trading name of Kava Media Ltd)
  • Content Management Systems: Kava Communications (a trading name of Kava Media Ltd). Xendica Ltd, a company based in the UK.
  • Online meeting & web conferencing: Cisco WebEx collaboration software, owned by Cisco Systems, Inc, a company based in the USA. GoToWebinar collaboration software, owned by LogMeIn, Inc a company based in the USA. Microsoft Teams communications platform, owned by Microsoft Corporation, a company based in the USA. Skype communication tool, owned by Microsoft Corporation, a company based in the USA.

Professional advisers acting as processors including lawyers, bankers, auditors and insurers and who provide consultancy, banking, legal, insurance and accounting services, who are based either in or outside the EU

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based either in or outside the EU who require reporting of processing activities in certain circumstances.

Other members or website users acting as joint controllers based both inside and outside of the EU as part of us operating message boards or other interactive services.

Other Terms

Your use of this site is subject to our Terms & Conditions. Accessing this site constitutes agreement with those terms.

Changes to the Privacy statement

Please accept this Privacy Statement as current. We reserve the right to change, modify or update this statement at any time without notice.

© Small Cell Forum Ltd 2007-2019. Registered in the UK no. 6295097.