Data protection notice - Russia

Why a general privacy notice?

When the Association of Chartered Certified Accountants and its affiliated entities (together 'ACCA', 'us' or 'we') collects your information, we are required by law to be fair in notifying individuals on how their information will be managed and to inform them of their rights. But more than that, we want to be transparent, open and ethical in our practices.

This data protection notice provides information on how we use data subjects’ personal data relating to our prospective and existing customers, our partners and other individuals we do business with (also referred to in this notice as 'you'), including:

  • ACCA members, affiliates, registered students and potential students
  • subscribers to ACCA magazines and other publications
  • representatives from employers of students and members
  • representatives of partner organisations and service providers
  • registrants for continuing professional development training courses or other events
  • donors and lenders as part of our benevolent fund
  • complainants and enquirers.

A list of ACCA affiliated entities relevant to this notice and their activities is set out in the appendix to this notice.

We have a separate Privacy Notice for our staff, employees and those wishing to become our employees, which can be accessed at the time of applying to ACCA.

I’ve been redirected here from another privacy notice. Why?

We try and give you all the information you need at the point of collection, in tailored privacy notices specific to the product or service you want to take up. 

However, it is sometimes impossible to give you all the information in a small space, or to tell you everything in as much detail as you may want.  In that case we redirect you to this longer notice, which outlines a more general approach to privacy (but will not hold specifics for the product or service), which you may read at your leisure.

This is a bit much. Can you shorten it?

We try to use plain language throughout the next sections, but there is a lot of detail to communicate, which is however important for you to understand.

If you want a more principle based approach to our general intention surrounding privacy, you should read our privacy promise and you can always navigate directly to the part or question of your interest directly.

Why does ACCA hold information on me?

We will only process personal data where we have a lawful basis to do so.

The basis for processing your personal data will vary depending on the activity we collected it for. In some occurrences, we may have more than one lawful basis for processing.

The information below summarises the basis on which we process personal information.

A summary of the legal basis used by ACCA are:

  • Contract: ACCA processes personal data which is necessary for the performance of a contract to which you may be a party to, or may want to enter, or may be a guarantor or beneficiary. This includes, but not limited to, ACCA membership, examinations, career services and subscriptions.
  • Legal obligation: ACCA processes personal data which is necessary to comply with its legal obligations. This includes, but not limited to, providing personal information to the authorized regulators, law enforcement agencies and statutory bodies.
  • Legitimate interest: ACCA processes personal data in order to exercise its rights and protect its legal interests as a professional association and regulator of Chartered Accountants. This includes, but is not limited to responding to general enquiries, supporting our students, members and partners, and improving our services relating to their Continued Professional Development, training and employment.
  • Litigation: ACCA processes personal data in order to protect its interests and respond to third parties claims in the competent courts.
  • Consent: ACCA processes personal data where you have provided your consent to do so.

Administration of studentship and membership records
We will hold personal data relating to members, affiliates and registered students in order to administer membership or studentship with ACCA and comply with our regulatory obligations. In certain cases, it is also voluntary for members, affiliates and registered students to provide us with details of ethnic origin, in order for us to review equality or opportunity of treatment.

Training and examinations
We will use your information to administer courses and exams and to monitor the pass rates and performance of learning providers, as well as ACCA students. We may use sensitive (information related to special categories of personal data, like health, ethnic origin, religious, philosophical and political views and convictions) information to determine your eligibility for special accommodations in order to provide you with assistance as part of the examinations and to comply with various equality and disability legislations. Please note that some examinations may be taken electronically and therefore may require the collection of additional information for the purpose of electronic processing.

ACCA Exchange
This is a service offered to employers and learning providers. It enables them to upload details of the ACCA students whom they employ and/or are training, and monitor examination status and results. ACCA requires such employers and learning providers to obtain your consent before including your details on this service.

ACCA Learning Community
We will use your personal data to validate your registration to ACCA’s learning community services.

Continuing Professional Development (CPD) and other courses
ACCA offers CPD training courses and other training events, online or offline, for both members and non-members and we will need your information, in order to administer such courses. We will use your information to establish and validate your work experience as part of your progression to membership.

ACCA Connect
We will use your information to respond to enquiries and assist you with your request. Your communications with ACCA, including online, by email, text message (SMS), via ACCA's customer contact centre (or otherwise) may be recorded and retained for training and record-keeping purposes. Records may be used to monitor the quality of the assistance given and to verify the matters discussed.

If you post or interact with us via social media, we may use your information, in order to contact you in relation to the query, we will not use this for the purpose of further marketing or communications, unless you give us your consent to do so. We may share information with our suppliers in order to assist you.

Communications (including marketing)
Subject to your prior explicit consent we may use your information for marketing purposes and to send you relevant communications about our qualifications, our products and services and any other relevant events. We may use your contact details to send you registration or information packs, learning support and recruitment materials, surveys, questionnaires, invitations regarding ACCA-based consultations, details of ACCA courses and events or to notify you of any updates and changes to ACCA's products and services.

You will have the right to withdraw your consent for these at all times, and we will make this process as easy as possible.

We also use your information for custom audience social media campaigns, such as information about student exam dates, member subscription deadlines and other key events. This allows us to present you with the most relevant information to yourself across all our channels.

ACCA may also carry out mailings on behalf of third parties (without disclosing your details to such third parties), subject to obtaining your consent. Consent may be requested on your ACCA registration form or separately by ACCA. Please let us know if you do not wish to receive (or wish to change the way in which you receive) any of the above materials (see How do I get a copy of my data or update my preferences? below).

We will not pass your information on to other marketing providers and we will not sell your information to any third party.

Publications
We will use your information in order to manage subscriptions to ACCA's publications, including Accounting & BusinessAccounting LinkFinance MattersStudent Accountant, and Teach Accounting magazines. Please contact ACCA if you wish to change the format in which you receive such publications, e.g. electronically or in hard copy (see How do I get a copy of my data or update my preferences? below).

We may also use information, which you explicitly provide to us when participating in ACCA campaign programmes, within internal and external publications to promote ACCA in the public and for advertisement purposes. We will always inform you when participating in public campaigns and will seek your explicit agreement prior to using your information. Examples of these are ambassador and leadership campaign programmes or interviews undertaken during public events.

Professional conduct
We will use your information for the purpose of enquiries, investigations and complaints relating to members and registered students (or prospective and former students). Such matters may be sensitive in nature and ACCA restricts internal access to information to those teams responsible for investigating and resolving the relevant matters. However, please be aware that disciplinary hearings and outcomes may be made public.

Regulation of firms
We will use personal information of nominated individual representatives of firms and other organisations as part of our regulatory activities, including monitoring purposes.

Partner relationship management
We will use personal information of nominated individual representatives of firms and other organisations as part of our partner relationship management activities, including accreditation and approved employers and learning partner’s applications.

Benevolent Fund 
Certain additional information may be collected from members and dependants, who are beneficiaries of the ACCA Benevolent Fund. More information on use and disclosure of your data will be provided to you if you apply for the Fund.

Simpson Scholarship Fund
Certain additional information may be collected from existing students, who are applying to the Simpson Scholarship Fund. When you apply we will use this information to assess your eligibility for assistance with exam and student subscription fees. More information on use and disclosure of your data will be provided to you if you apply for the scholarship Fund.

What type of personal data will ACCA collect about me?

We process information relevant to the above reasons and/or purposes. This information may include:

  • personal details
  • contact details and preferences
  • payment details
  • family, lifestyle
  • photographic ID
  • membership details
  • details of complaints
  • financial details
  • education and employment details.

Details may include name, contact details, membership ID numbers, nationality, date of birth, dates of affiliation, membership or fellowship, and details of exam sessions, including course results, payments, queries and complaints.

We also process sensitive classes of information (special categories of personal data) that may include:

  • social circumstances
  • physical or mental health details
  • racial or ethnic origin
  • criminal records.

For processing of such information we will ask you to provide written consent in accordance with applicable requirements.

Details may include medical certificates, proof of income and details of supporting mitigating circumstances.

IP addresses
If you visit our website, we collect information about the Internet Protocol (IP) addresses of your device used to access the site which helps us monitor the level of activity and the service we provide. For more information, please see our website cookies notice.

 

How will ACCA collect the information?

We will carry out the following operations on your personal data with the use of both automatic and non-automatic means of data processing: collection, recording, systematization, accumulation, storage, adaption, alteration, retrieval, extraction, transfer (provision, access), depersonalization, blocking, deletion, destruction.

We will collect data directly from you (for example from registration forms, change of details forms, at fairs and events and via our website) and will create some data internally (e.g. when we assign you an ACCA ID or determine examination results).

Where we collect information, whether that be via websites, telephone, or manual forms we will provide at the point of collection a more tailored and specific privacy notice pointing out the relevant information for that product or service and justifying why the collection is necessary.

We may also collect some data from external sources. For example:

  • Employers and learning providers may provide ACCA with relevant information on members and students employed by and/or training with them, including where they are registering you for a course
  • ACCA's service providers (e.g. examiners and invigilators) will send ACCA information relevant to the service they are providing
  • The general public may provide information to ACCA in relation to complaints and/or investigations.

ACCA ensures security and confidentiality of your personal data while processing. In particular, we take the following measures:

  • appointment of the data protection officer
  • implementation of internal policies
  • ensuring security of premises where personal data is processed.

How do I keep my information up to date and accurate?

We take measures for keeping your personal data up to date and accurate. You may inform us of any changes to your contact details during your studentship or membership with ACCA and courses which you attended for satisfying ongoing CPD requirements. We endeavour to provide self-service where possible, so you can review and update your own information at your leisure via myACCA portal.

If you don’t have a myACCA portal account you can always contact us via our contact centre to update your information.

Will my data be given to anyone else?

Service providers
ACCA uses a number of third-party service providers in order to carry out the activities described above, for example, to send you mailings or operate or administer exams. ACCA requires such service providers to use your personal data only for the purpose of the relevant service.

Joint scheme partners & other professional bodies
In some countries, ACCA operates joint qualification schemes with third parties. Both ACCA and the joint scheme and other professional bodies will need to share information with each other in order to operate the scheme.

Event sponsors
ACCA may organise events, such as webinars, CPD sessions, conferences and career fairs which may be sponsored by other organisations or partners, and in order to administrate these events we may share your personal information with these sponsors.

Oxford Brookes partnership
When becoming an ACCA student, you are automatically registered for the 'Oxford Brookes' BSc degree as a benefit to your studies. We therefore share information with Oxford Brookes University. For further information, visit our Oxford Brookes BSc in Applied Accounting programme section.

For more details on how Oxford Brookes use your personal data, pleaserefer to their privacy policy.

ACCA Exchange partners
Certain information, such as your name and examination results, will be shared with employers and learning providers who receive this service, subject to obtaining your consent.

Learning provider results service
Some learning providers subscribe to an ACCA 'results service' under which they may access examination results of the students they have trained in order to monitor their pass rate performance. Your learning provider is required to inform you separately if they use your data in this way. Other learning providers may be provided with your student results, where you have given them your consent to do so.

Continuing Professional Development (CPD) accredited employers
ACCA may liaise with employers who are accredited for CPD purposes to verify your employment with them and/or to validate their accreditation as a CPD provider.

Approved Employers
If you are employed by an organisation, which is a member of ACCA's approved employer scheme, ACCA may liaise with your employer and provide relevant details, in order to validate your experience records or give you the opportunity to receive additional member benefits (e.g. training courses). Employers may be provided with your student results, where you have given them your consent to do so.

General public
ACCA is required to publish customer information in its members' directory and a register relating to accountancy accreditations. We may also include details of our affiliates and members (including names and the country that they are located in) within lists to be published within appropriate publications, such as Accountancy Age and the Financial Times in the UK, and similar overseas financial and accountancy publications. In addition, disciplinary hearings and outcomes may be made public.

Verification of details and employment assistance
If you are a student, affiliate or a member, subject to obtaining your consent, we may provide relevant details to recruitment agencies, employers and educational or professional bodies (e.g. other accountancy bodies) for the purposes of assisting you to find appropriate employment once qualified. We will also provide information relating to verification of membership, training and qualification details.

Professional advisers, regulatory and legal authorities
ACCA may disclose your personal data to its professional advisers, legal authorities, other professional bodies, other regulators or other third parties, in order to investigate complaints and disciplinary matters, to exercise or defend its legal rights or otherwise, where required by law.

How long will my data be held for?

We will retain your details for as long as they are needed for the relevant purposes listed in the section Why does ACCA hold information on me? above.

We may also retain certain records for other legitimate reasons (including after your relationship with ACCA has ended), for example to resolve any potential disputes, cross-check against future membership applications and to comply with other reporting and retention obligations.

For more details on how long we keep your data for, you can review our data retention schedule:

Data retention schedule

 

Retention period
(minimum)

Retention period
exception 

For students, affiliates and members (active and regulated) 

 

 

Case resulting in a regulatory or disciplinary finding:
* summary of closed case

7 years after death or
100 years after birth 

 

Case resulting in a regulatory or disciplinary finding:
* any other documents: Committee notes, hearing transcripts etc.

Closure of case + 7 years

Immediate deletion if
related to Rehabilitation Act 1974 Order 

Investigations but no sanctions including Rest on Files (RoF)
and closed at assessment stage 

Closure of case + 5 years

 

Preliminary enquiries but no investigation

Decision + 1 year

 

Practicing activities: monitoring 

7 years after death or 100 years after birth   


No deletion if firm or any of the principals monitored within it at any time is still active. 
 
In line with case timeframes if documentation (e.g. monitoring reports) relate to a case

Granting a certificate or authorisation to practice 

7 years after death or
100 years after birth 

 

General student records (e.g. transcripts & exam etc.)

7 years after death or
100 years after birth 

 

General affiliate records (e.g. Professional Experience Records) 

7 years from last Professional Experience Records (PER)
submission 

 

General member records except certificates (e.g. CPD records etc.)

7 years from the last Continuous Professional Development (CPD) submission 

Member applications & certificates
7 years after death or 100 years after death 

 

Former students, affiliates and members (previously regulated)
Any termination of relationship except death and sanction, i.e. Resignation 

 

 

All records

End of relationship +
15 years

7 years after death or
100 years after birth for transcripts & exam & basic personal profile

In line with case timeframes if documentation (e.g. monitoring reports) relate to a case

 

Other individuals (non-regulated) 

 

 

Individuals who ACCA has a service contract with such as suppliers, markers, examiners, content providers, independent assessors etc.

End of contract + 7 years

If their information relates to Governance, as long as the case they relate to

All records belonging to an individual who has shown interest about becoming a prospective student 

Registration of interest date or first date of contact + 2 years 

 

All records belonging to an individual who started an application to become a student but has not fully completed or submitted it.

2 years after started but not submitted application 

 

All records belonging to an individual  who applied to become a student but  has been rejected

Date of rejection + 7 years

 

All records belonging to an individual who applied to become a student but their application for membership is on-hold 

Date of the on-hold + 7 years

 

How will ACCA keep my data safe?

ACCA has implemented technical, physical and organisational security measures and safeguards to protect the confidentiality, integrity and availability of personal data against unauthorised or unlawful processing of personal data, accidental loss, destruction or damage, accidental, unlawful or unauthorized access, copying, damage, destruction, disclosure, distribution, manipulation, modification, processing, use, reuse, interception, or transmission.

This includes physical and electronic security measures, as well as other organisational measures such as appropriate training, access control, the use of, firewalls, intrusion detection systems, encryption, locking file cabinets, current revisions of all software releases and all software patches and other appropriate physical and electronic security mechanisms.

ACCA security approach is aligned to globally recognised standards and frameworks such as the ISO27001 standard, NIST, Cyber essentials, Cloud security principles standards and the Microsoft cloud adoption framework.

What about our website?

For information about cookies used on our website, please see our website privacy and cookies notice.

Is ACCA subject to the Freedom of Information Act 2000?

ACCA is not listed as a 'public body' for the purposes of the FOIA and therefore is not under a duty to comply with the provisions of the FOIA.

What rights do I have?

Individual’s rights are qualified (meaning they may not have these rights at all times, or in all circumstances), but generally speaking, individual’s rights include:

  • the right of access or to obtain a copy of their information
  • the right to correction or updating
  • the right to complain (to both the ACCA and the regulator)
  • the right to object, block or put on hold processing
  • the right to be compensated for damage or distress
  • the right to withdraw consent at any time
  • rights related to automated decision making (machine based judgements).

If you want to exercise one of these rights please get in touch at:

ACCA
Privacy Office
Corporate Assurance
The Adelphi
1-11 John Adam Street
London
WC2N 6AU

Alternatively, you can email privacy@accaglobal.com, or call +44 (0)141 582 2000.

How do I get a copy of my data or update my preferences?

We try and provide a self-service style of service, or login to your account and review and update your own information or alternatively you can call our contact centre.

Before providing you with your personal data, we may require confirmation of your identity or further information about the data requested to assist ACCA to locate your personal data.

Please also let us know if you believe any data we hold to be inaccurate or if you have other concerns about our use of your personal data.

These rights are subject to certain exemptions which may apply, for example, in relation to some professional conduct matters and accessing examination scripts.

You can update your contact details and options for receiving publications and communications via myACCA or by contacting ACCA's contact centre.

Who can help me if I have a query?

For more information, or for further assistance with a more detailed enquiry, or if you want to exercise your rights, please contact privacy@accaglobal.com

Will ACCA's position change?

From time to time we will review this document, when we make substantial changes to our processes or procedures and systems, or if laws and regulations change.

We will update the notice here, and make reasonable efforts to contact and update those affected if the changes are substantial in nature.

<Date of last revision – June 2018 >

Appendix to ACCA's data protection notice ACCA affiliated entities

  • Association of Chartered Certified Accountants: Professional accountancy body and main operating and membership entity
  • Certified Accountant (Publications) Limited: publishes Accounting & Business magazine
  • Certified Accountants Educational Trust: publishes Student Accountant and Finance Matters magazines
  • Certified Accountants Educational Projects Ltd: manages sharing of information for marketing purposes
  • The Chartered Certified Accountants' Benevolent Fund: Registered charity which helps ACCA members and family in times of need and distress (this refers to both the unincorporated trust and the charitable company of the same name)
  • The Association of Authorised Public Accountants: Professional accountancy body for its members
  • ACCA National Offices (overseas companies, branches, representative and liaison offices)
  • The Simpson Scholarship Fund: Registered charity which provides funding to ACCA students to support subscription and exam fees
  • ACCA Ventures Ltd: provides online tuition content through partner organisations

In the event of any inconsistencies between the English version and the version of this notice in any other languages, the English version shall prevail.