This Privacy Notice sets out the privacy policy of the Liberian Shipowners’ Council Ltd (“LSC”). LSC is a New York State registered Not-for-Profit Corporation (NYS Department of State #342125) with additional permission to operate in Virginia (State Corporation Commission #F211290-4). References hereafter to “we”, “us” and “our” refer to LSC.
Introduction
Data protection legislation gives individuals rights to understand how their personal data is used. Personal data is information that identifies an individual – it may be factual information, images or other recorded information.
This Privacy Notice provides detailed information about how and why we use (or “process”) personal data and what we do with that information. It also explains the decisions that you can make about your own information. Please read it carefully, and if you have any questions regarding your personal data or its use, please contact us at info@liberianshipowners.com; or by telephone at +1.703.251.2493.
Liberian Shipowners’ Council (“LSC”)
LSC is a national shipowners’ association representing all sectors of the shipowner community registered with Liberia. LSC’s mission is to promote and protect the interests of Liberian-flag shipowners and operators in all matters of shipping policy and operations and to ensure that shipowners can continue to operate their vessels to the highest practical standards of quality, safety, and environmental protection while retaining the cost-effective advantages of the Liberian-flag open register system. LSC’s activities include participation in meetings with government and public stakeholders and sharing positions on behalf of its Members, hosting of meetings and events for its shipowners, and circulating regulatory updates and advisories to its Membership.
In order to carry out the core functions of LSC, i.e., to operate effectively as a shipowners’ association and a professional secretariat and meet legislative, contractual and statutory obligations, we need to process personal data relating to various categories of individuals.
Types of personal data we process
LSC is a membership organization with shipowners, operators, managers and associated service providers as its members. Our Members provide personal data on individuals within their companies who are nominated to represent them in LSC activities or have been requested to receive LSC-related emails. This data will include name, role and contact details. This data is used when providing member services; for example, names and company affiliations form part of a record of activity, such as attendance notes, minutes of committee, sub-committee, panel and working group meetings. We also liaise, consult and cooperate with the Liberian Registry, other associations, organizations and individuals connected with the shipping industry in order to provide effective representation to our members. This may entail the use of personal data of individuals in those other organizations or operating independently. This personal data is usually limited to business contact details and includes name, role and contact details.
LSC also organizes a range of seminars and meetings and workshops for members and relevant stakeholders. As part of this activity, personal data is collected and used for the purposes of arranging the event, and contacting attendees and speakers and providing reports.
LSC is funded by Membership Dues. This means that we collect data which is necessary to identify the client, take financial payment details, and complete all necessary financial and other records where you have provided a contact email address. We may use this to tell you about events, publications and other LSC activities that you may be interested in. You can update your preferences in regard to receiving such information at any time by contacting us at Info@LiberianShipowners.com or by unsubscribing to our emails.
Collecting, handling and sharing personal data
We are committed to ensuring that, when collecting personal data, we do this in accordance with the principles set out in the data protection legislation contained in the EU General Data Protection Regulation (“GDPR”), namely, that the data is:
- collected lawfully and fairly and with transparency;
- collected for a specific purpose;
- limited to what is necessary in relation to the purposes for which it is processed;
- accurate and kept up to date;
- kept in a form which permits identification of data subjects for no longer than necessary; and
- handled with appropriate security including protection against unlawful processing or accidental loss, destruction or damage.
In applying these principles, we collect most of the personal data we process directly from the individual concerned. Personal data held by us is processed by appropriate members of staff for the purposes for which the data was provided. We endeavor to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the secretariat of any significant changes to important information, such as contact details, held about them.
We do not otherwise share or sell personal data to other organizations for their own purposes.
Transferring personal data
Personal data may be stored and processed in the United States or any other country in which we, or associated third parties, maintain facilities. Should we need to transfer personal data, we will take all reasonable measures to ensure that it is transferred only to third parties that also comply with the GDPR.
The lawful basis on which we use personal data information
This section outlines the legal basis that we are relying on when handling personal data.
Legitimate interests
We rely on legitimate interests for most of the ways in which we use personal data. Specifically, we expect that the following uses will fall within our legitimate interests:
- Providing Secretariat services to Members of LSC;
- Representing and promoting the objects and interests of LSC Members;
- To give and receive information;
- Ensuring that all relevant legal obligations are complied with and to obtain appropriate professional advice and insurance.
Legal obligation
We collect data to comply with the registration and reporting requirements of applicable law. We will also process special category personal data or criminal records information in accordance with rights or duties imposed on us by law, including in connection with employment of staff, for example reference checks, welfare, insurance or pension plans; for legal and regulatory purposes (for example diversity monitoring and health and safety).
How long we keep personal data
We will retain your personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason.
Your rights over your personal data given to us
Under the EU GDPR you have the following rights over personal data given to us that we respect:
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Right of Access
You are entitled to be informed when we are processing your personal data and if we are to receive a copy of the personal information which we hold. You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals or information which is subject to legal privilege (for example legal advice given to or sought by us, or documents prepared in connection with a legal action).
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Right to Rectification
You are entitled to request that any incorrect data which we hold about you is corrected.
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Right to Erasure
You have the right to request the deletion of personal data which we hold about you, in certain circumstances for example where personal data is no longer necessary for the purpose which we collected it.
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Right to object
You have the right to object, under certain circumstances to us processing your personal data.
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Right to object to direct marketing
You have the right to object at any time to us processing your personal data for direct marketing purposes. If you object to such processing, we must discontinue all direct marketing without undue delay.
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Right to restrict the processing of your personal data
Under certain circumstances, for example, while a request to correct personal data is being processed.
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Right to data portability
In some circumstances you have the right to request that we transfer the personal information we hold on you to another organization in a machine-readable format. This applies only to information you have provided to us and which we process on the basis of your consent or for the performance of a contract.
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Right to withdraw consent
If our processing is based on your consent, you have the right to withdraw your consent to our processing of your personal data at any time. Such withdrawal does not affect the lawfulness of processing that took place prior to withdrawal. Please be aware however that we may have another lawful reason to process the personal data in question even without your consent. That reason will usually have been set out under this Privacy Notice (or elsewhere in data protection legislation), or may exist under some form of contract or agreement with the individual (e.g. an employment or personal contract, or because of membership of one of our associations).
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Complaints
You have the right to complain to the data protection authorities regarding our processing of your personal data.
Please note that we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
If you would like to access or amend your personal data, or have some objection to how your personal data is used, please make your request in writing to: info@liberianshipowners.com. . We will respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is 30 days in the case of straightforward requests for access to information.
Links to other websites
Our website contains links to other websites. These websites will have their own privacy policies and are not covered by this privacy policy which applies only to www.liberianshipowners.com.
Social media
LSC also operates the LinkedIn account for Liberian Shipowners’ Council Ltd. If you choose to interact with us on LinkedIn, we may have access to any posts or messages directed to us. We ask that you do not post any sensitive personal information on our social media platforms and if you do so we reserve the right to delete it.
Newsletters, circulars and advisories
As a Member of LSC, you will receive newsletters, circulars and advisories from Liberian Shipowners’ Council Ltd via Constant Contact. If you receive these messages and no longer wish to do so, you can unsubscribe at any time.
Automated profiling using personal data
We do not under any circumstances carry out any automated profiling of personal data.
We may update this privacy notice from time to time and where we do so we will amend the version date at the bottom of this notice.
If you do have any questions about our data protection policy or what we do with your information, you can contact us at info@liberianshipowners.com or +1.703.251.2493.
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Version date: 19 February 2020
Privacy Notice