1. Introduction
The website at http://www.START-project.org is a web-site providing information on GCRF START project activities. It is currently managed by Diamond Light Source Ltd (“Diamond”). Diamond is committed to protecting the privacy and security of your personal data.
This Notice describes how we collect and use your data and may be supplemented, in specific instances, by additional notices setting out in further detail how and why we use your personal data.
2. Who does this Notice apply to?
This Privacy Notice tells you how we will deal with the personal data of those individuals that Diamond engages with through the START-project.org website. The content of this Notice is not exhaustive. Instances may occur that fall outside of the areas covered in this document.
Diamond reserves the right, whilst acting fairly and reasonably, to take such measures as are necessary in each individual case.
3. Who is responsible for this Notice?
Diamond is the data controller for the information that we hold about you as a result of your interaction with START-project.org. We decide how to use your data and we are responsible for managing your personal data.
4. What is Personal Data?
Personal data is any information relating to an identified or identifiable individual and from which that individual can be directly or indirectly identified. It does not include information where your identity has been removed (anonymised information).
5. How will we process your Personal Data?
We will comply with data protection law by taking steps to ensure that the information that we hold about you is:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
6. What Personal Data do we collect about you?
The personal data that we expect to collect, hold and use about you is likely to include your name, email address and other personal data that will be specified in any contact that you make with us.
7. How do we collect your personal data?
We obtain the information directly from you.
8. How long will we process your information?
We will process your information for so long as is necessary for the purpose you have agreed to, this could for example be when you email us or as a START collaborator register for events.
9. Reasons and Purpose for processing your personal data
“Legitimate Interests” means Diamond’s interests in conducting and managing the GCRF START project, to enable us to give you the best service and the most secure experience. Examples of such processing include (but are not limited to) the following:
- Provide you with news related to the START project and its collaborators, specifically including (but not limited to) scientific achievements, events and proposal deadlines;
- Hosting data in the cloud;
- Your participation in events and other activities organised in support of START’s and Diamond’s objectives or the objectives of our collaborating partners;
- Communication between Diamond, START and the START collaborators;
- Reporting for Diamond and the START project;
- Business management and planning;
- Accounting and audits;
- Sharing your details with any of the members of the START collaboration for any of the purposes set out above;
- Publishing any blog posts you submit to us.
10. Sharing Data Outside Diamond with Third Parties
We may share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We currently share your personal data as follows:
Visitors to the START-project.org website
We use a third-party service, WordPress.com to host the website for START-project.org. WordPress.com is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. It is important to note that this functionality is not normally enabled on the START-project.org website.
For more information about how WordPress processes data, please see Automattic’s privacy notice. When someone visits START-project.org, we also use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This information is only processed in a way which does not identify anyone.
The website uses cookies. For more information about cookies set by WordPress.com please see: https://jetpack.com/support/cookies/.
Google Analytics also sets some cookies, for more information about cookies set by Google Analytics please see: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=en We use third-party services to deliver some online content; these include but are not limited to: YouTube, Vimeo, Twitter, and Facebook. For more information about how these third-party services process data, please see their respective privacy policies.
11. Transfer of your personal data outside the European Economic Area
There may be occasions when we transfer your personal data outside the EEA, for example, if we communicate with you using a cloud based service provider that operates outside the EEA or if we share your details with one of the members of the START-project.org collaboration outside the EEA. Such transfers will only take place if one of the following applies:
- The country receiving the data is considered by the EU to provide an adequate level of data protection
- The organisation receiving the data is covered by an arrangement recognised by the EU as providing an adequate standard of data protection (for example transfers to companies that are certified under the EU US Privacy Shield);
- The transfer is governed by approved contractual clauses;
- The transfer has your consent;
- The transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
- The transfer is necessary for the performance of a contract with another person, which is in your interests;
- The transfer is necessary in order to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent;
- The transfer is necessary for the exercise of legal claims; or
- The transfer is necessary for important reasons of public interest.
12. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13. Data Retention
We will retain your personal data so long as it is necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
14. Your Rights
It is important that the personal data we hold about you is accurate and current. Under certain circumstances, by law you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
In the limited instances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
15. Accessibility
We understand that there are differences amongst individuals in terms of the protected characteristics contained within the Equality Act 2010; i.e. age, disability, gender reassignment, marriage & civil partnerships, pregnancy & maternity, race, religion or belief, sex (gender) and/or sexual orientation. We therefore aim to deliver policies, procedures, notices and services which are efficient and effective, accessible to all, and which meet our stakeholders’ different needs. If you need any help to understand this document or require any appropriate support please contact us.
16. Amendments to this Notice
We reserve the right to update this Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
17. Who are the GCRF START collaborators?
The START collaborators are: Addis Ababa University, Ain Shams University, Cardiff University, Diamond Light Source, National Institute for Communicable Diseases, National University of Lesotho, North West University, Stellenbosch University, University of Cape Town, University of Limpopo, University of Oxford, University of Pretoria, University of Sheffield, University of Southampton, University of the Free State, University of the Witwatersrand.