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Privacy Policy

This Policy describes how Advance HE will collect, use, and protect personal data about individuals and what rights these individuals have over their data.

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1 Purpose


1.1 Advance HE is a company limited by guarantee incorporated in England and Wales under company number 4931031 and a company limited by guarantee registered in Ireland no. 703150.
 

1.2 Advance HE is registered as a charity in England under charity number 1101607 and in Scotland under charity number SC043946, with its registered UK office at Innovation Way, York Science Park, York YO10 5BR and its registered Ireland office at First Floor, Penrose 1, Penrose Dock, Cork, T23 KW81, Ireland.
 

1.3 Contact us using our customer support page.
 

2 Scope
 

2.1 This Policy describes how Advance HE will collect, use, and protect personal data about individuals and what rights these individuals have over their data.
 

2.2 For the purpose of data protection legislation, which includes the Data Protection Act 2018; and the General Data Protection Regulation (Regulation (EU) 2016/679 (the “GDPR”)), or such replacement thereof in the UK, Advance HE is the "data controller".
 

2.3 This means that Advance HE is responsible for deciding how we collect, use and store personal data about an individual.
 

2.4 Advance HE is registered with the Information Commissioner’s Officer (ICO) under number Z8550188.


3 Definitions

Term Definition
Personal Data Personal data is information held about a particular person and is considered sensitive.
GDPR General Data Protection Regulation.
EEA European Economic Area.
ICO Information Commissioner’s Officer.
Legal Basis Law that allows Advance HE use individual’s personal data.

4 Legal Basis


4.1 Advance HE will only use an individual's personal data when the law allows us to do so, this is known as “legal basis”.


4.2 Advance HE identifies the following legal basis for the purpose of this Policy.

Legal Basis Definition
Consent An individual has given Advance HE their consent to process their personal data for the specific purpose that has been explained under this Policy. An individual has a right to withdraw their consent at any time, to do so, please contact Data.Protection@advance-he.ac.uk.
Contract Advance HE is required to use an individual’s data in order to deliver a contract. In addition to this, it is necessary to use data in order to take specific steps prior to entering into the contract.
Legal Obligation Advance HE uses an individual’s personal data to comply with the law.
Vital Interests Processing an individual’s personal data is necessary to protect an individual’s vital interests, or of another person.
Public Interest Using an individual’s personal data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law.
Legitimate Interests Processing an individual’s personal data is necessary to support a legitimate interest Advance HE, or another party has, only where this is not outweighed by an individual’s own interests.

5 Data Collected


5.1 Advance HE may collect and process the following data about an individual:


• Contact details, where they are provided to us.
• Information that are provided by filling in forms on our website at www.advance-he.ac.uk.
• Information provided when requesting information on Advance products and services, subscribing to email communications on our services, news from the sector, research, and reports, posting material or requesting further services.
• Advance HE may also ask for information when reporting a problem with our site.
• Advance HE may keep a record of correspondence if an individual contacts us.
• Advance HE may also ask for surveys to be completed to be used for research purposes, although there is no obligation to respond to them.
• Details of transactions an individual may carry out through our website and of the fulfilment of orders.
• Details of individual visits to our website including, but not limited to traffic data, location data, weblogs, and other communication data, whether this is required for our own billing purposes or otherwise and the resources that is accessed.
• Details of applicants to any of Advance HE job vacancies.
 

5.2 Further details on the personal data collected and how it is used depends on how an individual uses Advance HE services can be found in Appendix A.
 

6 Use of Data
 

6.1 Advance HE may use your data for:


• Customer care and for personalised communication of Advance HE services.
• To contact individuals for market research purposes.
• To create an individual customer profile (this may include data already provided to Advance HE, or which is generated by an individual’s use of Advance HE services, for example contact details, preferences, purchase history, app usage and online behaviour).
• Transmission of data to suppliers of Advance HE services, and we may share personal data between suppliers of Advance HE services where relevant.
• To ensure that content from our website is presented in the most effective manner for an individual and their computer.
• To provide an individual with information, products, or services that are requested from us or which we feel may be of interest.
• To carry out our obligations arising from any contracts entered between an individual and us.
• To allow individuals to participate in interactive features of our service, when chosen to do so.
• To notify individuals about changes to our service.
• To use information for reporting purposes.
• Advance HE may sometimes be obliged to disclose personal data by law such as by a regulator with appropriate power, or court order.
• Notification on job vacancies applied for.
 

6.2 Information held by or for public bodies can be subject to freedom of information requests.
 

6.3 Further details on the personal data collected and how it is used depends on how an individual uses Advance HE services can be found in Appendix A.
 

7 Artificial Intelligence and Data Processing
 

7.1 Advance HE will use Artificial Intelligence (AI) to support with the streamlining of manual processes throughout its operations.
 

7.2 Should Advance HE chose to use AI to process personal data, we will ensure that we continue to comply with the principles of data protection by design and default.
 

7.3 To do so, Advance HE will take a risk-based approach when considering the use of AI systems to process personal data. This will include:


• Assessing the risks to the rights and freedoms of individuals that may arise when using AI.
• Implementing appropriate and proportionate technical and organisational controls in order to mitigate these risks.
 

7.4 Should an individual’s personal data be used within an AI system, Advance HE will conduct the relevant risk assessment on the software to ensure there is sufficient controls in place to mitigate the risk.
 

7.5 Further details on the personal data collected and how it is used through AI can be found in Appendix A.
 

8 Cookie Management
 

8.1 For information specifically on cookies and tracking on our website, please see our Cookie Policy.
 

8.2 When first visiting Advance HE’s website, individuals will be presented with a cookie banner which allows them to make an informed choice about which types of cookies to accept on their device.
 

8.3 Individuals can also stop tracking at any time by using private browsing mode.
 

8.4 In addition to this, if an individual has consented to tracking cookies, some of their past browsing history on our website will also be available to help us more effectively engage.
 

8.5 Cookies are small text files that are placed on an individual’s device, such as computers, phones, or tablets, when viewing pages on Advance HE website.
 

8.6 These cookies allow Advance HE to track some of the individuals’ browsing preferences and optimise how website works.
 

8.7 While Advance HE are not actively looking to identify individuals using cookies, it may be possible for use to identify an individual or infer information about the individual.
 

9 Automated Processing of Data
 

9.1 When interacting with Advance HE, for example by booking onto a programme or event, submitting an application for accreditation, completing a web form, downloading content from our website or opening an email sent, we may keep a record of this information on our systems and use it to determine individual interests.
 

9.2 Advance HE automatically generates data from certain interactions which allows us to tailor our communications so that they are relevant to the individual and assists them in accessing the information and products that may be of interest.
 

9.3 We also use these sources of information to improve our site, services and products and assess our marketing performance. For example, if an individual has consented to email marketing, information is collected about when and if the email was opened and which links were clicked.
 

9.4 This information is used to assess the engagement and success of an email campaign.
 

9.5 Individuals can unsubscribe from our mailings at any time by updating their contact preferences here, from preferences page in My Advance HE Portal, or by clicking on the ‘unsubscribe’ link at the end an email received.
 

9.6 If an individual does not want us to use their data in this way, please let us know by emailing data.protection@advance-he.ac.uk.
 

10 Storage of Personal Data
 

10.1 The data that Advance HE collect may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
 

10.2 It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
 

10.3 Such staff maybe engaged in, among other things, the fulfilment of orders, the processing of payment details and the provision of support services.
 

10.4 By submitting personal data, an individual is agreeing to this transfer, storing, or processing.
 

10.5 Advance HE will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Policy.
 

11 Protection of Personal Data
 

11.1 Advance HE is committed to holding personal data provided to us securely.
 

11.2 Where personal information is held electronically, it is held on a computer system that is owned and controlled by Advance HE or such other third party appointed by Advance HE.
 

11.3 To keep individuals updated on latest sector news and products/services offered by Advance HE, we will store details, in both paper and electronic format.

11.4 Paper copies are held locally by Advance HE at its offices or securely by our staff or contractors. Sometimes we will make electronic copies of paper documents or type up information from them. These documents or information are then stored on our computer system.
 

11.5 All the information that is provided to us will be transmitted to and stored on our secure servers or the servers of such other third party who we may appoint from time to time to store information.
 

11.6 Where an individual has a password which enables them to access certain parts of our online service, they are responsible for keeping this password confidential and they are not to share a password with anyone.
 

11.7 Unfortunately, the transmission of information via the internet is not completely secure.
 

11.8 Although we will do our best to protect personal data, we cannot guarantee the security of data transmitted to our website; any transmission is at the individual’s own risk.
 

11.9 Once we have received information, we will use strict procedures and security features to try to prevent unauthorised access.
 

12 Sharing Personal Data
 

12.1 As with most organisations, Advance HE uses service providers to support in the delivery of services and to keep an individual’s personal data secure.
 

12.2 When Advance HE uses service providers, it is necessary that personal data is shared with them.
 

12.3 When using a service provider, Advance HE will ensure that it relies on legitimate interests to do so and ensures there are agreements in place with all service providers that oblige them to protect an individual’s personal data and that they can only process the data based on the instructions.
 

12.4 Where the data is transferred outside of the UK, Advance HE will make sure that data is given the same level of protection, either through that country having a comparable data protection standard (Adequacy), or by using another safeguard such as an enhanced contractual agreement (IDTA).
 

12.5 Sometime, Advance HE may be legally obliged to supply copies of personal information to other organisations. Advance HE may not always be able to tell the individual that we have shared information in this way, however Advance HE will ensure that this is only shared in accordance with the law.
 

12.6 Further details on how individuals’ personal data is shared in appendix B.
 

13 Retention of Personal Data
 

13.1 Advance HE will only retain personal data for as long as necessary to fulfil the purposes we collected it for.
 

13.2 To determine the appropriate retention period for personal data, we consider:


• The amount, nature, and sensitivity of the personal data.
• The potential risk of harm from unauthorised use or disclosure of personal data.
• The purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

13.3 Advance HE will ensure that our suppliers and selected third parties with whom we share personal data with, in accordance with this Policy, will delete personal data when they no longer require it.
 

14 Links to other Sites
 

14.1 Advance HE’s website may, from time to time, contain links to other websites.
 

14.2 If these links are followed to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
 

14.3 Please check these policies before submitting any personal data to these websites.
 

15 Duty to Inform of Changes
 

15.1 It is important that the personal data we hold about an individual is accurate and current.
 

15.2 Please keep us informed if personal data changes during the relationship with us.
 

16 Personal Right to Personal Data
 

16.1 Under certain circumstances, by law an individual has the right to:


• Request access to their personal data (commonly known as a “data subject access request”). This enables an individual to receive a copy of their personal data held by Advance HE and to check that we are lawfully processing it.
• Request correction or ratification of the personal data that Advance HE hold about the individual. This enables them to have any incomplete or inaccurate information we hold about them corrected.
• Request erasure of personal data. This enables individuals to ask Advance HE to delete or remove personal data where there is no good reason for us continuing to process it. Individuals has the right to ask us to delete or remove personal data where they have exercised their right to object to processing.
• Object to processing of personal data where we are relying on a legitimate interest (or those of a third party) and there is something about an individual’s particular situation which makes them want to object to processing on this ground. They also have the right to object where we are processing their personal data for direct marketing purposes.
• Request the restriction of processing of individuals personal data. This enables them to ask us to suspend the processing of personal information about them, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of personal data to another party.
• Request to be informed about how an individual’s personal data is used.
 

16.2 If individuals want to review, verify, correct or request erasure of their personal data, object to the processing of their personal data, or request that we transfer a copy of their personal data to another party, please contact the data protection team at data.protection@advance-he.ac.uk and Advance HE will aim to exercise these rights within one month.
 

16.3 Individuals will not have to pay a fee to access their personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if their request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

16.4 Individuals have the right to complain to the Information Commissioner (http://www.ico.gov.uk/) if there are any concerns in respect of the handling of personal data by Advance HE.
 

17 Additional Information Advance HE May Need
 

17.1 Advance HE may request specific information from individual to help us confirm their identity and ensure their right to access the information (or to exercise any of their other rights).
 

17.2 This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
 

18 Review of Policy
 

18.1 This Privacy Policy may change from time to time. Please check back regularly to ensure they have the latest information.
 

18.2 Advance HE will review this Policy on a biennial basis.
 

19 Data Protection Officer
 

19.1 The following are contact details for Advance HE’s Data Protection Officer.
 

Post:
Data Protection Officer
IC 1.25, Innovation Centre
Innovation Way
York Science Park
York
YO10 5DG
 

Email:
data.protection@advance-he.ac.uk
Phone:
+4420 3870 6011
 

20 Complaints
 

20.1 If an individual is unhappy with any aspect of this Policy, or how their personal data is being processed, please contact data.protection@advance-he.ac.uk in the first instance, then the Data Protection Officer. If the individual is still not happy, they have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
 

Post:
Information Commissioner’s Officer
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Email:
casework@ico.org.uk

Phone:
+44303 123 1113
 

By Live Chat:
https://ico.org.uk/global/contact-us/live-chat
 

Appendix A: Collection and Use of Information

I am just browsing your website.

If you are just browsing the website, Advance HE may collect your data using cookies (section 6) or other tracking technology.

I have submitted a contact us form or used the EDI Advice Service.
 

Purpose of Data Used Type of Data Used Legal Basis
Processing and responding to contact us query. Name, Email address, Customer Support Number, Institution / Organisation Name, Type of Support Needed Legitimate Interest / Consent
Processing and responding to EDI query. Name, Email address, Institution / Organisation Name, Job Title, Job Category, Type of Support Needed Legitimate Interest / Consent

I am a user of your service.

Purpose of Data Used Type of Data Used Legal Basis
Process membership application and create an individual customer profile. Name, Address, Email Address, Phone Number, Institution Details Consent / Contract
Administration of your account / membership (including individual customer profile) Name, Address, Email Address, Phone Number, Institution Details, Details of Services Used, Profile Preferences, App Usage Details Consent / Contract
Providing our consultancy services. Name, Address, Email Address, Phone Number, Project Specific Data Consent / Contract
Sending Customer Evaluation Survey. Name, Email Address, Name of Institution Consent / Contract
To send you information on related products or services. Name, Email Address Consent
To use for internal reporting purposes. Name, Name of Institution Consent
To notify you about changes to our services. Name, Email Address Consent
To contact for market research purposes. Name, Email Address Consent

I am a panellist or independent assessor.

Purpose of Data Used Type of Data Used Legal Basis
To send you applications for review. Name, Address, Email Address, Phone Number Consent / Contract
To pay you. Name, Address, Bank Details, Email Address Consent / Contract

I have booked to attend an event.

Purpose of Data Used Type of Data Used Legal Basis
Processing your booking. Name, Email Address, Address, Phone Number, Job Title, Payment Details Consent / Contract
Sending Customer Evaluation Survey. Name, Email Address, Name of Institution Consent

I have submitted a job application.

Purpose of Data Used Type of Data Used Legal Basis
Processing your application. Name, Email Address, Phone Number, Current Job Title, Current Employer, CV, Disability Status (if provided), Reasonable Adjustment Needs (if provided), Equality and Diversity Details (if provided) Consent
Sifting Candidates. CV Consent
Inviting to and conducting interviews. Name, Email Address, CV, Interview Notes Consent

I am an Associate.

Purpose of Data Used Type of Data Used Legal Basis
Processing application / Generating reports around allocation of work and delivery capacity Name, Email Address, Phone Number, Current Job Title, Current Employer, CV, Disability Status (if provided), Reasonable Adjustment Needs (if provided), Equality and Diversity Details (if provided) Consent / Contract Legitimate Interest
To contact you regarding opportunities to work with us Name, Email Address, Phone Number Consent / Legitimate Interest
To contact you regarding product and / or project development opportunities Name, Email Address, Phone Number Consent / Legitimate Interest
To help with administration and logistics around development and delivery of your work Name, Email Address, Phone Number Consent / Legitimate Interest

I have attended a Zoom meeting.

Purpose of Data Used Type of Data Used Legal Basis
Questions may be asked during Zoom meetings, requesting for answers to be inputted in the chat. StreamAlive (AI system) will pick up key words from the chat box and convert into presentational slides that will be anonymous and circulated after the Zoom event. On occasion, there may be questions that will drive personal data information. Race, Ethnic Origin, Political Origin, Religious / Philosophical Belief, Sex Life, Sexual Orientation Explicit Consent (Individuals will have the option whether to comment within the chat)