Privacy Notice

1. Important notice

This is the Privacy Notice of Shell Pensioners Association of Shell Centre, York Road, London SE1 7NA, an unincorporated association (“SPA”, “we”, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data. Please read this Privacy Notice to understand how we may use your personal data.

This Privacy Notice relates to personal information that identifies “you” meaning members of the SPA, individuals signed up to our online community, individuals who browse our website, and individuals outside our organisation with whom we interact. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children. Additionally, this Privacy Notice is not intended to apply to personal data collection during the recruitment of employees, for which there is a separate privacy notice.

Any reference to Shell in this privacy notice refers to a company or companies within the Shell group, being Shell PLC or its successor company, and its wholly or majority-owned affiliates.

This Privacy Notice may vary from time to time so please check it regularly. This version of this Privacy Notice was first published on 1st March 2022 and has not been updated since.

2. Who we are

The SPA is an unincorporated association for ex-Shell employees with a UK-based Shell pension, who would like to stay in touch with Shell and their former colleagues after leaving the company. We receive some funding and support from Shell International, but we are not part of the Shell group.

Local branches of the SPA are entirely independent of us, and each have their own constitutions and membership rules.

This Privacy Notice is intended to cover the SPA’s processing of personal data in respect of all of the services we provide to members, those who are enquiring about / are seeking to become members, and non-members (e.g. family of members or browsers of the SPA’s public facing website).

3. How to contact us

Controller

This Privacy Notice applies where we are a controller in respect of your personal data – this is where we decide how and why your personal data is processed.

If you wish to:

correct your personal data held by us;
opt out at any time from receiving marketing correspondence from us;
alter your marketing preferences; or
contact us in connection with our use or processing of your personal data, or gain access to it,

please contact us using the following details:

Shell Pensioners Association, Shell Centre, York Road, London SE1 7NA

Email: SI-Shell-Pensioners-Association@shell.com

Tel: +44 (0) 207 934 5129 or +44 (0) 207 934 5137

Data Protection Manager

Our Data Protection Manager is Amanda Hunt, and you can contact her at:
SI-Shell-Pensioners-Association@shell.com

4. Categories of personal information we collect

The categories of personal data about you that we may collect, use, store, share and transfer are:

Individual Data. This includes personal data which relates to your identity, such as your name, date of birth, pension number and your contact details such as your address, email address and telephone numbers;
Marketing Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences;
Health Data. This includes personal data which is gathered for health and safety purposes, including any accident report or claim log or any information you provide about allergies, or any other health information (including details around medical conditions) you provide to us;
Information Technology Data. This includes personal data which relates to your use of our website, such as your geo-location data, internet protocol (IP) address, login and website activity data, traffic data, weblogs and other communication 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 our website;
Subscription Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, or details of subscriptions to our services or publications;
Account and Profile Data. Where you have signed up for an account on the Members’ Website, this includes personal data which relates to your account or profile such as your username and password, your interests, preferences, feedback and survey responses; and
Content Posted/Uploaded by You on the Members’ Website. This includes announcements, stories, photos, documents, comments, events and jobs.

We may also create Personal Data about you, for example, if you contact us by telephone to discuss your membership or a family member’s membership, we may make a written record of key details of the conversation so that we can take next steps as necessary.

We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-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 Notice.

In addition, we may obtain certain special categories of your data, and paragraph 8 of this Privacy Notice specifically sets out how we may process these types of personal data. The special categories of data are: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

We do not collect any information about criminal convictions and offences.

5. The sources from which we obtain your personal data

We obtain, or may have obtained in the past, your personal data from the following sources:

Directly from you, via our website, by telephone, in person, or through correspondence by post. This could include personal data which you provide when you:

enquire about, sign up for or attempt to sign up for SPA membership;
use our services or browse our website;
contact us about a family member’s membership of the SPA;
contact us about a deceased member of the SPA;
create a profile for access to our Members’ Website;
subscribe to our publications;
request information on our products or services or for other marketing to be sent to you;
enter into a competition, prize draw or promotion; and
complete a survey from us or give us feedback.

Via automated technologies, such as cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

From someone else, such as:

Shell Pensions Trust Ltd, including its replacement from time to time;

Shell PLC including its replacement or affiliates from time to time;

members of the SPA and family members.

6. How we use your personal data

We collect personal data about you in order to:

perform our contractual obligations to you. This would include:

processing and performing any services requested by you; and

making or receiving payments, fees and charges.

manage our relationship with you including

to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);

to send communications regarding events and SPA news to our members (including SPA News magazine where relevant);

administrative purposes, including processing a donation or event registration, or updating your settings on the Members’ Website;

to send you information you have requested from the SPA;

to deal with your enquiries;

to ask you to leave a review or feedback on us; and

to act as an effective method of communication between members and Shell.

administer the SPA and carry out its services and activities;
allow you to participate in the SPA’s online community (via the Members’ Website) and the SPA’s Facebook group;
to moderate the use of and the content posted on the SPA’s online community and Facebook group;
communicate with you about, and administer your participation in, special events, programs, promotions, any prize draws or competitions;
inform certain third parties as to whether you are a member of the SPA in order for you to benefit from those third parties;
for internal purposes to use data analytics, or in aggregated and anonymised form to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, services, marketing, member relationships and experiences;
protect our interests including to deal with any misuse of our website and to comply with our security policies at our locations;
use your personal data to comply with our own legal obligations e.g. to assist in a police investigation;
enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties;
use your personal data in an official role which we have been designated to carry out by an official authority (e.g. the government) or where we are otherwise carrying our tasks which are in the public interest (e.g. which have been designated as such by government, or which would otherwise be deemed in the public interest);
to detect and prevent fraud and other illegal activities (and to assist regulators and law enforcement agencies in relation to the same);
finance, restructure, sell, make ready for sale or dispose of the SPA in whole or in part including to any potential buyer or their advisers;
use our knowledge of any health related personal data you disclose to us in the event of illness or injury or some other related emergency or to record any accident or injury or other incident you may suffer when engaged in any of our activities; and
investigate and defend any third-party claims or allegations.

7. Online Community

You may choose to join our online community by registering on the website (shellpensioners.org.uk) and creating an online profile for access to our Members’ Website. This Privacy Notice covers our use of your personal data where you access the Members’ Website and participate in our online community.

Controlling your visibility

Via ‘My Settings’ you can choose to hide your profile, limit access to your profile so that it’s only viewable to your connections and adjust some of the automatic notifications that you receive from this website. Please note that your name (but not full profile) may appear in various places around the Members’ Website, such as a ‘Recent Joiners’ box and in ‘Search’ results, irrespective of the privacy settings you have selected.

8. Our lawful basis for processing your personal data

Where we may rely on consent:

For certain purposes it may be appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.

In the event that we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact details set out in paragraph 1 to do so.

Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.

An example of where we may rely on your consent to process your personal data includes where we or our carefully selected third parties have new products and services which we think you will be interested in.

Other legal bases we may rely on:

Where we are relying on a basis other than your consent, the lawful basis for processing personal data will be one of the following:

the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);

the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;

processing is necessary for the establishment, exercise or defence of legal claims; or

the processing is necessary for the pursuit of our legitimate interests. In particular, our legitimate interests include:

the provision of our membership services;

the provision of administration and/or IT services;

the provision of the SPA website and Members’ Website;

the prevention of fraud;

marketing of the SPA’s services and promotion of our work;

the reorganisation, sale, transfer or refinancing of the SPA or any of its activities;

the study in how to develop and the update of our products and services;

the development of the strategies and aims of the SPA;

protecting our activities, objectives and property.

the processing is necessary in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our events.

the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Special category data:

Where we are processing your special category personal data one of the following conditions will also apply:

you have given your explicit consent to the processing;

the processing relates to personal data which are manifestly made public by you;

the processing is necessary for the establishment, exercise or defence of legal claims;

the processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;

the processing is necessary to protect an individual’s vital interests where the individual cannot give consent;

the processing is necessary for reasons of substantial public interest;

the processing is necessary in relation to your or our rights in the field of employment and social security and social protection law;

processing by a not-for-profit in certain circumstances;

the processing is necessary for the purposes of preventative or occupational medicine; and

the processing is necessary for reasons of public interest in the area of public health.

9. Who receives Your personal data

We may disclose your personal data to:

other Shell companies or entities and affiliates (as listed below), or third party data processers who may process data on our behalf to enable us to carry out our usual practices as an unincorporated association. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;

the Shell Pensioners Benevolent Association, a charity registered in England, number 262049

the Shell Pensioner Programme, a service provided by Shell International;

and/or local branches of the Shell Pensioners Association, which are separate from and independent of the SPA.

external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
third parties which are considering or have decided to acquire some or all of our assets, merge with us or to whom we may transfer our undertakings (including in the event of a reorganisation, dissolution or liquidation);
third parties, operating plugins or content (such as Facebook) on our website which you choose to interact with;
our website developers, software providers and suppliers providing data hosting and email hosting services including:

ToucanTech Ltd., our web platform host, and their sub-processors ¶

GoDaddy.com LLC, our domain and email host provider

NB A list of these sub-processors is available on request from the Data Protection Manager, via the details in Paragraph 3.

10. Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as a member of your family) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

11. Accuracy of your personal information

It is important that the personal data we hold about you is accurate and current. We take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us. SPA contact details can be found on the home page of the Shell Pensioners Association website, in the ‘Contact us’ tab in the main menu..

We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

12. International transfers of personal data

It is possible that personal data we collect from you may be transferred and/or processed outside of the United Kingdom including outside the European Economic Area. In connection with such transfers we will ensure that:

(a) there are appropriate safeguards in place such as binding corporate rules or approved model contractual clauses; or

(b) the transfer is to a country that provides an adequate level of protection; or

(c) one of the derogations for specific situations applies to the transfer including explicit consent, or the transfer is necessary for the performance of a contract, or for the exercise or defence of legal claims.

13. How long we will store your personal data for

We will store your personal data for the time period which is appropriate in accordance with the following criteria:

(a) the on-going relationship that we have with you or the period for which you are a member of the SPA;

(d) the type and size of the data held and whether any if it is deemed to be special category personal data; or

(e) our accounting requirements in relation to that personal data.

We keep the length of time that we hold your personal data for under review. These reviews take place annually.

14. Requirements on you to provide personal data

It is your choice as to whether you provide us with your personal data for the purposes of becoming and being a member of the SPA. If you do not provide your personal data then the consequences are that we may not be able to perform to the level you expect as part of your membership. An example of this would be where we are unable to post SPA News to you because we have an incorrect address.

15. Your rights in relation to your personal data

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 6), you may have a number of rights in connection with the processing of your personal data, including:

the right to request access to your personal data that we process or control;

the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;

the right to request, on legitimate grounds as specified in law:

erasure of your personal data that we process or control; or

restriction of processing of your personal data that we process or control;

the right to object, on legitimate grounds as specified in law, to the processing of your personal data;

the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and

the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

16. Data security

If you have an online profile for the Members’ Website, you are responsible for keeping your login details (email and password) confidential and we ask that you do not share your password with anyone.

17. Links to other websites

This policy only applies to us. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.