- Data controller: The John Smith Trust.
- How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us or applying to participate in one of our fellowship programmes),
- from your use of our website, using cookies and similar technologies, and
- from third parties.
- Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), your residential address, country of origin, profession and career information, employer and employment history, your reasons for applying to our programmes and other application information, information we receive from your referees, ethnic origin, race and religion, and medical information.
- How we use your information: for administrative and charitable purposes (particularly to contact you and process applications you make on our website), to improve our charity and website, to fulfil our contractual obligations, to provide and administer the fellowship programs we offer, to advertise our program, to analyse your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only to the extent necessary to run our charity, to our service providers and charitable partners, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
- Do we sell your information to third parties: No
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a charity). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
- Transfers of your information outside the European Economic Area: we transfer your information outside of the European Economic Area. Where we do so, we will ensure appropriate safeguards are in place, including the use of standard contractual clauses (SCCs), and the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
- Use of automated decision making and profiling: we do not use automated decision making or profiling.
- Your rights in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- to complain to a supervisory authority
- Sensitive information: we collect what is commonly referred to as ‘sensitive information’. For more information, please see the main section below entitled Sensitive Information.
- Our details
The data controller in respect of our website is The John Smith Trust (charity registration number: 1174898) of 22 Bramshill Gardens, London, NW5 1JH. The data controller is the person which determines the purposes and means of processing your information. You can contact the data controller by writing to Office 4, 219 Kensington High Street, London, England, W8 6BD or sending an email to firstname.lastname@example.org.
- How we collect or obtain information about you
Information collected from you
We collect information about you when you provide it to us, such as through your use of our website and its features, when you contact us directly by email, phone, in writing, or via social media, when you apply to join one of our programmes, when you use any of our other websites or applications or any other means by which you provide information to us. The type of information we collect about you includes information such as:
- your name;
- your email address;
- your address;
- your phone number;
- your IP address;
- information about your device (e.g. device and browser type);
- information about how you use our website (e.g. which pages you have viewed, the time you viewed them and what you clicked on);
- information about your mobile device (such as your geographical location);
- country of origin;
- profession and career information;
- job title;
- employment history;
- your reasons for applying to our programme;
- other information you provide in your application;
- ethic origin and race;
- religion; and
- medical information you provide to us (such as dietary requirements and any disability information).
Information received about you from third parties
We do receive information about you from third parties. The third parties from which we receive information about you will generally include the referees you provide when you make an application to our programme.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Cookies are data files which are sent from a website to a browser to record information about users of a website.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so may impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org
We use Google Analytics on our website to understand how you engage and interact with it. For information on how Google Analytics collects and processes data using cookies, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics tracking by visiting: http://tools.google.com/dlpage/gaoptout
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we may obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, business directories, media publications, social media, and websites (including your own website if you have one).
Legal bases for processing
Where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard, such as the screening of applicants for our fellowship programmes. For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
In certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
- How we use your information*
We will use your information for one or more of the following purposes. The legal basis on which we use your information is set out and explained after each purpose:
Administrative and charitable purposes
- Improving our website and charity, including personalising our website and services for you and other charity beneficiaries. This is necessary for our legitimate interest of better understanding our other beneficiaries’ preferences and tailoring our website, products and services to their needs, preferences and desires.
- Protecting our charity and our charitable interests, including for the purposes of credit and background checks, fraud and website misuse prevention and debt recovery. This is necessary for our legitimate interests of preventing criminal activity such as fraud or money laundering, for ensuring that our website and services are not misused. Where we carry out credit and background checks, we will only carry out such checks to the extent that we are permitted or authorised by law to do so and to the minimum extent necessary.
- Communicating with our charity advisors and legal representatives. This is necessary for our legitimate interests of obtaining legal or professional advice. In such circumstances, we will only share your information where it is necessary to do so, to the minimum extent necessary, subject to appropriate confidentiality restrictions and on an anonymised basis wherever possible.
- Sharing your information with third parties which are either related to or associated with the running of our charity (including to third parties who assist in the administration of our fellowship programme from time to time) such as our partners, insurers, affiliates, associates, suppliers, independent contractors, email providers IT and web development service providers. We will share your information with these parties where it is necessary for our legitimate interest of running and managing our charity effectively, fulfilling our contractual obligations (e.g. to our insurers) or for our own direct marketing purposes. Where you enrol on one of our fellowship programmes, we may also need to share your information with such third parties in order to administer this program. Where we share your information with such third parties, we will do so strictly on a need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymised basis as far as possible and only to the extent strictly necessary for any of these purposes. In particular, we share your personal information with the British Group of the Interparliamentary Union and other session providers. We also shared your information with British embassies in your country of origin or country of residence..
- Ensuring physical, network and information security and integrity. This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, preventing malware, viruses, bugs or other harmful code, preventing unauthorised access to our systems, and any form of attack on, or damage to, our IT systems and networks.
- In connection with disclosure requests and in the case of a charity reorganisation, whether actual or potential. This is necessary for our legitimate interests of selling and/or ensuring and promoting the success of our charity. Where we share your information with a prospective purchaser or seller, we will do so on a strictly need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymised basis as far as possible and only to the extent strictly necessary for any of these purposes.
- To send you marketing communications. This is necessary for our legitimate interest of direct marketing and promoting our charity. Where we are required by law to obtain your consent to market to you, however, the legal basis on which we process your information will be your consent rather than our legitimate interests.
Advertising and analytical purposes
- Providing statistical information to third parties such as Google Analytics. This is necessary for our and third parties’ legitimate interests of processing information for research purposes, including market research, better understanding our respective charity beneficiaries, and tailoring our respective programmes to their needs.
- Displaying advertisements to you and analysing the information we receive in relation to those advertisements. This is necessary for our own and for third parties’ legitimate interests in direct marketing and advertising our and their programmes and services respectively, and for research purposes.
Legal and enforcement of legal rights
- Enforcing our legal rights. This is necessary for our legitimate interest of protecting our charity and enforcing our contractual and other legal rights.
- Indicating possible criminal acts or threats to public security to a competent authority. This is necessary for our legitimate interest of promoting the success of our charity, preventing crime, for compliance with a legal obligation to which we are subject, in the general public interest or for the legitimate interests of governmental bodies and competent authorities that prevent crime.
- In connection with any legal or potential legal dispute or proceedings. This is necessary for our legitimate interest of promoting and ensuring the success of our charity, resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law.
- Complying with laws, regulations and other legal requirements. We may need to use and process your information in order to comply with legal obligations to which we are subject. For example, we may require your information pursuant to a statutory obligation to conduct anti-money-laundering checks or to disclose your information to a court following receipt of a court order or subpoena. We may also need your information to comply with ongoing legal obligations, such as tax laws and regulations to which we are subject (where you have applied to join one of our programmes for example).
The processing of your information to comply with legal obligations to which we are subject applies to legal obligations of other countries where they have been integrated into the legal framework of the United Kingdom, for example in the form of an international agreement which the United Kingdom has signed. Where the legal obligations of another country have not been so integrated, we will process your information to comply with such obligations where it is in our legitimate interest to do so.
Use of your information only where we have your consent
Where we process your information on the basis of your consent, you can withdraw your consent to such processing at any time by emailing us at email@example.com or writing to us at 22 Bramshill Gardens, London, NW5 1JH.
* This list of purposes for which personal information may be used sets out the most common uses of personal information by a business. You should delete or add to this list as appropriate. However, in general, you may only process personal information for a limited number of purposes, and the most commonly used purposes are: (i) in order to perform a contract with the individual; (ii) for your legitimate interests as a business; or (iii) for compliance with a legal obligation. If you cannot process the personal data in question on one of these grounds, you will require the individual’s explicit consent to process their data, and such a purpose should be included in the following section beginning “We may process your personal information for the following purpose(s) where we have your consent to do so”.
- How long we retain your information
Programme Information for successful applications: when you participate in our programmes, we retain the information you provide in your application for six years following the end of your programme for the purpose of handling any claims that might be made in connection therewith. After this period, we will delete all of your personal information apart from some basic information for alumni, marketing and record keeping purposes such as your name, email address and country of origin.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for three (3) years, after which point we will delete your information.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Application Information if you are not successful: If you apply to one of our programmes and are not successful, we will retain your application information for a further three years from the date that we notify you of the outcome of your application.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).
- How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website;
- only transferring your information via closed system or encrypted data transfers; and
- use of two-factor authentication for access to cloud-based information.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
- Transfers of your information to other countries and safeguards used
We may need to transfer your information outside of the country in which we collected or obtained it, including outside the European Economic Area or to an international organisation from time to time. Where we transfer your information outside the European Economic Area, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your information to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following safeguards:
- data protection policies adhered to by the data controller and other companies and entities within our corporate group from time to time, which comply with applicable laws, known as “binding corporate rules” or “BCRs”;
- standard data protection clauses adopted by the European Commission or adopted by the Information Commissioner’s Office and approved by the European Commission in accordance with relevant law;
- a code or codes of conduct produced by an association or other body approved by the Information Commissioner’s Office;
- an approved certification mechanism (such as the EU-US Privacy Shield); or
- where authorised by the Information Commissioner’s Office, contractual clauses between the data controller or processor and the data controller, processor or recipient of the information in the third country or international organisation.
You can access these safeguards by emailing firstname.lastname@example.org.
- Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 22 Bramshill Gardens, London, NW5 1JH or sending an email to email@example.com:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
- the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/ for the ICO.
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
- Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to 22 Bramshill Gardens, London, NW5 1JH, or sending an email to firstname.lastname@example.org.:
- to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an email to email@example.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://johnsmithtrust.org/cookies.
- Consequences of not providing your information to us
Where you wish to join one of our programmes, we require you to provide the necessary information in order to process your application and to enrol you on such program. We may also require your information pursuant to a statutory obligation (in order to process a temporary visa application, for example).
If you do not provide your information, we will not be able process your application or enrol you on our program.
- Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We process sensitive personal data in connection with the administration of our programmes on the basis of your explicit consent to do so. In particular, we process any medical information relating to you which is relevant (e.g. if we have to make any special arrangements) during the course of running our programmes. This may include information about disabilities, dietary requirements, allergies and anything else you inform us of.
We also process information about your ethnic origin, race, religion and other background information of a sensitive nature, as well as political information relating to your country of origin. We process this information for equality and diversity reasons and to monitor the levels of representation across different groups and demographics from your country of origin within our fellowship programmes.
Except as set out above, we do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit any other sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
- Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to firstname.lastname@example.org.
- California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals.
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