Who we are
The Gemmological Association of Great Britain (herein referred to as Gem-A) is the world’s longest-running provider of gem and jewellery education. A UK charity, we can trace our lineage back to 1908 — that’s over 110 years of experience and expertise. It’s our mission to advance the understanding of gemstones through education, membership, engaging events and a community-driven approach to best practise. We also have a subsidiary company: Gemmological Instruments Ltd (herein known as Gem-A Instruments) that provide gemmological equipment for the trade.
As a data controller, we collect and use information about students, members and other customers in accordance with the General Data Protection Regulation (GDPR) 2018.
This privacy notice applies to Gem-A and Gem-A Instruments’ customers. The notice outlines how Gem-A and its subsidiary process your personal data.
Collection of your personal data
Gem-A collects data directly from you (e.g. from application forms, change of details forms, at events and via our website) and will create some data internally (e.g. when we assign you a student or membership ID or determine examination results). We may also collect some data from external sources. For example:
The reasons for collecting your personal data
Gem-A will process personal data only if it has a legal basis to do so. The lawful basis (or bases if applicable) for processing data is dependent on the purpose of collecting your data.
Gem-A uses the following lawful bases in its data processing activities:
Gem-A is a membership body and has a public duty to protect the interests of its members and members of general public. This includes, and is not limited to, the maintenance and publication of Members directory, Regulatory activities, Member investigations and Disciplinary actions.
If you enter or wish to enter into contractual relationship with Gem-A, (e.g. by enrolling on one of our courses), the company will collect your, and any third parties’, personal data to facilitate the provision of services or products. Gem-A will only collect the data that is necessary for the performance of a contract.
This includes, and is not limited to, Gem-A membership, course enrolments, examinations, career services, event attendance and other subscriptions.
Gem-A collects and processes your personal data, which is required to adhere to legal obligations. This includes, and is not limited to, providing information to personal law enforcement agencies, regulators, and statutory bodies.
Gem-A collects your data and processes it to satisfy its legitimate interest. Gem-A will contact you if you expressed interest in any of our services, such as educational course, membership subscription or if you have attended an event. Gem-A will also contact you to provide support, training or employment.
Some types of data will be processed if you requested Gem-A to process it for a specific purpose or provided Gem-A with your explicit consent, for example if you subscribe to one of our mailing lists.
Information Gem-A collects about you
From the time you first engage with Gem-A, we will collect, process and hold data about you.
The ways in which Gem-A uses your information:
Gem-A processes personal data in order to:
Gem-A also aggregates much of the data collected within its in-house data warehouse to allow reporting on student data:
Access to your personal data
Gem-A takes the safety of your data very seriously. We will use your data to answer and assist you with your enquiries, investigations or complaints that involve Gem-A’s members and students. Such matters may be sensitive in nature and Gem-A 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.
Sharing of your personal data
Gem-A shares your personal data with its subsidiaries and other third parties to fulfil its legal, public or contractual obligations. For example, Gem-A may share your data with the courier or delivery companies who will deliver Gem-A’s products to you, or with exam centres who administer your exams, Gem-A’s accredited teaching centres and Gem-A GAPP centres who provide you with teaching services, or other third party service providers or Gem-A’s processors. Certain information, such as your name and examination results, may be shared with your teaching providers (Accredited Teaching Centres and GAPPs), subject to obtaining your consent. Gem-A is required to publish customer information in its members’ directory and a register relating to gemmology accreditations. We may also include information of our graduates and members and affiliates (including names and the country that they are located in) on Gem-A’s website and within lists to be published within appropriate publications, such as The Journal of Gemmology or Gems and Jewellery, and similar overseas publications. Gem-A will share some of your information with Gem-A Instruments, its subsidiary, to enable you to receive discounts on your purchases. In addition, disciplinary hearings and outcomes may be made public. We may provide confirmation of your academic achievements with us to recruitment agencies, employers and educational or professional bodies to assist you in finding appropriate employment once qualified. Gem-A may provide data relating to verification of membership subscriptions, training undertaken and qualification details. Gem-A may need to disclose information it holds about you to legal authorities, professional advisers, other professional bodies, regulators or other third parties. The information will be disclosed in order to investigate complaints and disciplinary matters, to exercise or defend its legal rights or otherwise, where required by law.
Retention of your personal data
Gem-A retains your personal data for as long as necessary for the relevant purposes listed in the section ‘The way in which Gem-A uses your information’ in the section above.
We may also retain certain records for other legitimate purposes (and after your relationship with Gem-A has concluded), for the purpose of resolving any potential disputes, cross-checking future membership applications, and to comply with other retention and reporting obligations. The retention schedule is available at the bottom of this policy.
Communications and marketing
Communications to fulfil contractual obligations:
Gem-A will contact you during the course of your studies, and until your graduation, to keep you updated about the progress of your studies, our products, services or qualifications.
If you are a member you will receive regular updates and newsletters from Gem-A. You will also receive renewal notifications which will remind you about renewing your membership.
Communications on the basis of legitimate interest:
You will be contacted by the admin or membership team if you enquire about our courses, membership, or other products or services. If you are a prospective student Gem-A may contact you to send you application forms, information packs, prospectuses or recruitment materials. If you attended any of our events or studied with us, we may ask you to complete surveys and questionnaires, and send you invitations to Gem-A’s open day and other events. Gem-A will strive to keep you informed about its current affairs and will notify you of any changes to Gem-A’s products and services.
Communications for which we need your consent:
We will ask you to subscribe to one of our mailing lists, and give us consent to contact you for purposes of marketing. You can withdraw consent any time by unsubscribing from the mailing list. The button to unsubscribe is located at the bottom of every email you receive from us.
We will not pass your information on to third party marketers and we will not sell your information to any third party. We may use named third-party service providers to process and store user data.
Third-party service providers used by Gem-A for marketing purposes:
MailChimp is a marketing automation platform and an email service provider. We use this platform to communicate with our members and students, and to send newsletters to those that have signed up to receive them. We will collect your name, email address, membership/student number if necessary and, where possible, the country in which you are based. The country is used as a segmentation tool so that you can receive news and updates within your specific country. As a marketing tool, MailChimp will let us know if you have opened an email or if you have followed specific links through it.
You can unsubscribe from newsletter communications at any time.
Eventbrite is a ticketing and registration platform. The Eventbrite platform is used by Gem-A to register anyone that plans to attend Gem-A events.
By registering for a paid event you will provide financial information. We will also request information to identify you, such as your name and membership/student number. The information is stored within Eventbrite.
Google Analytics provides us with marketing analytics for our website. It creates a Gem-A cookie to collect data.
Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
You can opt-out of the creation of a user profile, Hotjar’s storing of data about your usage of our site, and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Gem-A will use your information in order to manage subscriptions to Gem-A’s publications The Journal of Gemmology and Gems and Jewellery. Members can contact Gem-A if they wish to change the format in which they receive such publications.
We may also use information that you explicitly provide to us when participating in Gem-A events, within internal and external publications to promote Gem-A in the public and for advertisement purposes. Gem-A will inform you when participating in public campaigns and will seek your explicit consent prior to using your information. Examples of these are campaign programmes or interviews undertaken during public events. Your image may also be captured incidentally when you attend Gem-A functions and we reserve the right to use these images in our marketing materials or campaigns.
Storage of your personal data
Gem-A’s main information systems are located within the European Economic Area (EEA) and are accessed by Gem-A’s administration team, which is located in London, United Kingdom. We process personal data within the EEA, but as part of our operations and service delivery, Gem-A may transfer data outside of EEA to its suppliers.
Other teams within Gem-A may need to access, use and store your data in certain circumstances for the purposes listed above, e.g. to notify you with updates to training or examinations, or to investigate incidents or complaints. If you are an overseas member or student, your information may be accessed by Gem-A’s national office in your country and records may be maintained locally (subject to local legislation).
Some of Gem-A’s processors, including service providers and technology vendors, may pass personal data outside of the EEA into jurisdictions where obligations and rights under privacy laws may vary. If this happens, we will always ensure that appropriate assurance checks and measures are put in place to protect your personal data. Our contracts with these service providers include industry standard assurances over the interaction with our data.
Keeping your data accurate and up to date
It is your responsibility to notify us of any change to your personal data, such as contact details, during your affiliation with Gem-A. You can always contact us to update your information.
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 endeavour to keep this notice up-to-date, and make reasonable efforts to contact and update those affected if the changes are substantial in nature.
Is Gem-A subject to the Freedom of Information Act 2000?
For the purposes of the Freedom of Information Act 2000 (FOIA) Gem-A is not listed as a ‘public body’ and therefore is not under a duty to comply with the provisions of the FOIA.
Individual’s rights included are listed below. Different rights are applicable in different circumstances.
If you want to exercise one of these rights please get in touch at:
Data Protection Officer
The Gemmological Association of Great Britain
21 Ely Place
London EC1N 6TD
Call: +44(0)20 7404 3334
|Gem-A Retention schedules||This schedule explains how long Gem-A will hold the information you provided|
|Activity||Nature of personal data held||Retention period||Authority|
|Enquiry about courses or membership||Name, contact details||6 months after an enquiry was answered||NA|
|Successful course application||Name, Contact details, details of the application, ULN, Financial information, Passport, Visa||6 years following the release of the exam results||HMRC & Home Office|
|Unsuccessful course application||Name, Contact details, details of the application||1 year after application was rejected||SI 2006/1031 ; SI 2003/1660; SI 2003/1661 Regulations accessible on www.legislation.gov.uk|
|Studies||IP and location data, details of study progress and other information obtained to provide service to students||6 years following the release of the last exam results||NA|
|Exam||Exam results, assessment results||Indefinitely||NA|
|Special data||Data relating to sensitive information such as health conditions||3 years after the last exam sitting||SI 2006/1031 ; SI 2003/1660; SI 2003/1661 Regulations accessible on www.legislation.gov.uk|
|Other||Student ID and name||Indefinitely||NA|
|Membership||Name, contact details, financial details||6 years following the date the membership lapsed||HMRC Notice 700/21|
|Membership ID||Membership ID and name||Indefinitely||NA|
|Event attendees||Name, contact details, address, financial information||6 years after the event date and the current year||HMRC Notice 700/21|
|Gem-A Instruments customers||Name, Contact details, financial information||Current financial year + 6 years||HMRC Notice 700/21|
|Contractors||Names, addresses, contact details||Current financial year + 6 years||HMRC Notice 700/21|
|Financial records including petty cash, expense reimbursement, records necessary for preparation of annual accounts including but not limited to sales and purchase records||Names, addresses, contact details||Current financial year + 6 years||HMRC Notice 700/21|