Last updated 24 May 2018
Welcome to the Rhodes Project’s privacy notice.
We respect your privacy and are committed to protecting your personal data. This privacy notice will explain how we look after your personal data when you contact us and tell you about your privacy rights and how the law protects you.
Please note there is a Glossary at the bottom to understand the meaning of some of the terms used.
Important Information and Who We Are
Purpose of this privacy notice
This privacy notice applies to citizens of the European Economic Area. Citizens of other countries are covered by a different set of privacy policies which you can inspect here.
This privacy notice aims to give you information about how the Rhodes Project collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us as a potential client or sign up to our newsletter.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
The Rhodes Project (“the Charity” or “we”) is the controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about it, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
Full name of legal entity: The Rhodes Project
Name of data privacy manager: Dr Jef McAllister
Email address: jmcallister@mcolaw.com
Postal address: The Pearce Building, West Street, Maidenhead, SL6 1RL, England
Telephone number: +44 (0) 1628 567 567, London Office: +44 (0) 20 3048 5959
If you are in the UK, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
This version was last updated on 24 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details. We have never had occasion to collect this in the past, but we include this provision in case we do in the future.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us. We have never had occasion to collect this in the past, but we include this provision in case we do in the future.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. The Rhodes Project investigates the lives and careers of female Rhodes Scholars, who have consented to participate and to share their data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
In some circumstances, we may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We may also collect information about your criminal convictions and offences if necessary (for example, if you are a job applicant for whom such a check is relevant).
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial or other Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Contact us as a Rhodes Scholar to participate in our research;
Communicate with us throughout your engagement with us;
Contact us as a potential employee, consultant, or collaborator;
Request marketing to be sent to you; or
Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy, below, for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers, such as Google based outside the EU; and
(b) search information providers such as LexisNexis based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay (based in the EU) and Authorize.net (based outside the EU].
Identity and Contact Data from publicly availably sources such as Companies House, Rhodes House and the Electoral Register based inside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we are conducting research to which you have consented.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We also rely on consent as a legal basis for processing personal data, such as periodic updates to participants in our research, which may involve sending marketing communications to you via email routed through third parties such as MailChimp. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To include you as a Rhodes Scholar in our research, some of which may be anonymized, as agreed |
(a) Identity (b) Contact |
Necessary for our legitimate interests (to conduct, analyze and present research about female Rhodes Scholars and related subjects). |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how others use our services) |
|
To administer and protect our activities and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our activities, provision of administration and IT services, network security and to prevent fraud) (b) Necessary to comply with a legal obligation |
|
To use data analytics to improve our website, services, marketing, client relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our outreach and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and outreach. We do not routinely collect data about a large number of people for marketing purposes as part of the Rhodes Project. However, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You may receive marketing communications from us – which so far have been updates about our work -- if you have requested information from us or agreed to participate in our research, and, in each case, you have not opted out of receiving those communications.
Third-party marketing
We will not share your personal data with any company outside the Charity for marketing purposes except (1) our supporting law firm, McAllister Olivarius, and (2) McAllister Olivarius’s sister firm, AO Advocates.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a part of the research project to which you have given consent.
Cookies
We use a number of different cookies on our website. If you do not know what cookies are, or how to control or delete them, we recommend you visit http://www.aboutcookies.org for detailed guidance.
Currently we show all users a warning to ensure they know that cookies are being used on the website. If you do not wish to retain our cookies you should either (1) not use this website; (2) delete the cookies after you leave the website; or (3) browse the website using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.)
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our research project. If such a change occurs, those in charge of the new entity may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
We have put in place procedures to deal with suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of 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 you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
Lawful basis
Legitimate Interest means the interest of the Charity in conducting and managing our activities to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties
INTERNAL THIRD PARTIES
Other firms in the McAllister Olivarius Group acting as joint controllers or processors who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
Service providers based in the EU and USA, who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the EU and USA, who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and the USA who require reporting of processing activities in certain circumstances.