1. Purpose of this Privacy Statement
The purpose of this Privacy Statement is to explain what we do with your personal information, so that you can be satisfied that we are not doing anything you would not reasonably expect. It tells you about the following.
- How to contact us.
- What personal information we collect, how we collect it, what we use it for, and what lawful grounds we rely on to use it.
- With whom we share personal information.
- Whether we transfer personal information overseas.
- Whether you will be subject to any automated decision making or profiling.
- Cookies.
- Your rights in relation to the personal information we collect, including how to complain.
2. How to contact us
The Progress Educational Trust is the data controller in relation to your personal data. You can contact us via our website or by using the following contact details.
Address: Progress Educational Trust, 140 Gray's Inn Road, London WC1X 8AX, UK
Tel: +44 (0)20 7278 7870
Email: admin@progress.org.uk
The nature of the information we collect about you depends on the context in which this is provided and the nature of our relationship with you. For example, if you are a user of our website, we will make a record of your IP address and certain other information so that we can provide you with access to the website (see below for information about cookies). More detailed information is set out in the table in Appendix 1 below.
4. With whom do we share your personal information?
We only share your personal information with other parties in the following circumstances.
- If we have your express consent to share your personal information.
- Where we have engaged a supplier to process personal information on our behalf (for example, software and cloud platform providers such as Microsoft).
- If we are required by law to share your personal information.
We only engage suppliers to carry out work involving access to your personal information if we are satisfied that they have taken proper steps to protect it.
5. For how long do we keep your personal information?
We only keep your information for as long as we need it for the purposes for which we obtained it (or for any other similar, related purposes). Once we no longer need your personal information, we will destroy it securely. More information is set out in the table in Appendix 2 below.
6. Overseas transfers
We do not generally transfer personal information outside the UK. In the event that we share personal information with suppliers (for example, cloud platform providers) which are based outside the EU, Iceland, Lichtenstein and Norway (the European Economic area), we ensure to protect it by one of the following means.
- A decision by the EU as to the adequacy of the legislative arrangements of the territory in which the supplier is based.
- Incorporating EU standard contractual clauses into our agreement with the supplier.
- Ensuring that the supplier is subject to EU approved internal privacy rules.
- We have obtained your specific, informed consent to the transfer of the information, having made you aware of the risks involved in transferring personal information into a territory which is not subject to an EU-approved privacy framework.
7. Automated decision making and profiling
We do not carry out any automated decision making or profiling.
Cookies are small files which are stored on your computer, which are created when you use your browser to visit a website. Their usual purpose is to facilitate your use of a website and to enhance your user experience. They do this by keeping track of your movements within the website, by helping you to resume where you left off, and by remembering your registered login, theme selection, preferences, and other customisation functions. The website stores a file corresponding to the file that the cookies set in your browser. Cookies do not contain personal information, but can enable the website you visit to store information about pages you have looked at. For this reason, some websites use analytics cookies to compile aggregated information about sites you visit, and marketing cookies to provide you with targeted advertising content based on which webpages you have viewed. Analytics cookies and marketing cookies are often set by third parties (for example, Google Analytics).
The Progress Educational Trust uses both 'necessary' and 'unnecessary' cookies. 'Necessary cookies' are cookies which are essential to the functions of a website such as security, network management and accessibility. You may disable these cookies within your browser settings, but this is not recommended, as it may compromise the functioning of the website. 'Unnecessary cookies' include marketing cookies, analytics cookies and third-party cookies. We use analytics cookies to help us improve our website by collecting and reporting information on how you use the website. These cookies may remain active on your computer for two years after your most recent visit to our website. We do not use marketing cookies.
9. Social media
We do not control the use of your personal information by other websites which you visit. However, we do have social media accounts on platforms such as Facebook, Instagram, Twitter and YouTube, and we may occasionally ask one of these platforms to target our publicity campaigns towards people who are likely to be interested by virtue of things like locality, age, gender and interest.
As an information subject, you are entitled to exercise each of the rights set out below. Each of these rights is not necessarily available in every situation.
- Right of access
We are obliged, on request, to provide you with access to your personal information as well as information about what we are doing with it.
- Right to rectification
You may require us to rectify any inaccurate information we hold about you.
- Right to erasure
This is known as the 'right to be forgotten'. Under this right, you can ask us to erase your personal information. There are certain circumstances in which this right does not apply.
- Right to restriction
You can require us to place a restriction on our use of personal information we hold about you. This does not arise in all circumstances. It is most likely to arise where you have the right to require us to erase personal information about you but, for some reason, you do not want us to do this.
- Right to object
You can object to our use of your personal information. If we are relying on our legitimate interests, we can only then continue to use your personal information where we can demonstrate that our interest outweighs your rights. If we are using the information for direct marketing purposes, then we absolutely must stop using it for those purposes.
- Right to data portability
You can ask us to transfer any personal information you have given us to another organisation. There are certain circumstances in which this right does not apply.
- Right to withdraw consent
Where our use of your personal information is based on consent, you are entitled to withdraw that consent at any time. We are obliged to make this easy for you to do, and we may not charge you a fee.
- Right to complain
You can complain to the relevant Supervisory Authority. In the United Kingdom, this is the Information Commissioner's Office. The relevant details are as follows:
Website: https://ico.org.uk/
Contact form: https://ico.org.uk/global/contact-us/
Complaints portal: https://ico.org.uk/make-a-complaint/
Helpline: +44 (0)30 3123 1113
Table showing what personal information we collect, how we collect it, for what purposes we use it, and on what lawful grounds we rely
| Information Subject | Personal Information | Collection Method | Purposes | Lawful Grounds |
|---|---|---|---|---|
| Website user. | IP address, time and duration of visit. | Through our website. | To facilitate the use of our website. | We have a legitimate interest in allowing individuals to use our website. |
| Subscriber to BioNews. | Name and email address. | Provided to us by the Information Subject (when subscribing to receive BioNews). | To enable us to circulate our newsletter, BioNews. | We have legitimate interest in circulating BioNews and we also rely on subscribers' consent. |
| Subscriber to the events mailing list. | Name and email address. | Provided to us by the Information Subject (either through subscribing to the mailing list or when registering to attend an event). | To enable us to manage and promote events. | We have legitimate interest in managing and promoting events and we also rely on consent. |
| Attendee at event. | Name and contact details. | Provided to us by the Information Subject (when registering to attend an event). | To enable us to facilitate and manage attendance at events. | We have a legitimate interest in facilitating and managing attendance at events. |
| Friend/donor. | Name, contact details, payment details, amount of donation. | Provided to us by the Information Subject. | To enable us to raise funds and involve people in furthering our objectives. | We have a legitimate interest in raising funds and encouraging participation. |
| Sponsor/grantor. | Name and contact details. | Provided to us by the Information Subject or their employer. | To enable us to raise funds. | We have a legitimate interest in raising funds and encouraging participation. |
| Speaker/panellist. | Name, contact details, CV, contributions. | Obtained online or provided to us by the Information Subject. | To enable us to organise events. | We have a legitimate interest in organising events. |
| Contributor to BioNews. | Name, contact details, CV, contributions. | Obtained online or provided to us by the Information Subject. | To enable us to further our objectives through publishing our newsletter, BioNews. | We have a legitimate interest in organising events and in publishing BioNews. |
| Employee. | Name and contact details, performance record. | Provided to us by the Information Subject (during application and onboarding). | Human resources/ management of our workforce. | This is necessary for the performance of our employment contracts. |
| Employee. | Name, address, national insurance number, date of birth, bank account details. | Provided to us by the Information Subject (during application and onboarding). | Payroll/tax. | This is necessary for the performance of our employment contracts. |
| Volunteer. | Name and contact details, performance record. | Provided to us by the Information Subject (during application and onboarding). | Human resources/ management of our volunteer workforce. | We have a legitimate interest in managing our volunteer workforce. |
| Employee. | Name and contact details, performance record. | Provided to us by the Information Subject (during application and onboarding). | Human resources/ management of our workforce. | This is necessary for the performance of our employment contracts. |
| Applicant for work and volunteering (successful). | Name, contact details, educational and employment history. | Provided to us by the Information Subject (during application). | Recruitment. | We have legitimate interest in recruiting volunteers. |
| Applicant for work and volunteering (unsuccessful). | Name, contact details, educational and employment history. | Provided to us by the Information Subject (during application). | Recruitment. | We have legitimate interest in recruiting volunteers. |
| Student. | Name, contract details, study history. | Provided to us by the Information Subject or their educational provider. | Training and education. | We have a legitimate interest in providing training and education. |
| Parliamentarian/ contact within government agency, other charity or professional body. | Name and contact details. | Obtained online or provided to us by other organisations, individuals or by the Information Subject. | Raising awareness and campaigning for change. | We have a legitimate interest in raising awareness and campaigning for change. |
| Category of data subject (function) | Category of personal data | Retention period | Reason for retention period |
|---|---|---|---|
| Employees (human resources). | Name and contact details; performance record. | Seven years from termination of employment, in addition to which their name – plus a biography and headshot photo (the latter will be removed on request) – may remain on our website indefinitely. | HMRC and accounting; legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person after termination of employment; to enable us to document our organisational history on our website. |
| Employees (payroll). | National insurance number; date of birth; bank account details. | Seven years from termination of employment. | HMRC and accounting. |
| Patrons, Trustees and Advisers. | Name and contact details. | Seven years from termination of role, in addition to which their name – plus a biography and headshot photo (the latter will be removed on request) – may remain on our website indefinitely. | Legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person in future; to enable us to document our organisational history on our website. |
| Volunteers. | Name and contact details; performance record. | Seven years from termination of voluntary employment, in addition to which their name – plus a biography and headshot photo (the latter will be removed on request) – may remain on our website indefinitely. | Legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person in future; to enable us to document our organisational history on our website. |
| Applicants for work and volunteering (successful). | CV with cover letter; name; contact details; notes by interviewers. | Seven years from termination of employment/voluntary employment, in addition to which their name – plus a biography and headshot photo (the latter will be removed on request) – may remain on our website indefinitely. | Legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person after termination of employment/voluntary employment; to enable us to document our organisational history on our website. |
| Applicants for work and volunteering (unsuccessful). | CV with cover letter; name; contact details; notes by assessors. | CV with cover letter deleted within one year of notification of unsuccessful application; name, contact details and notes by assessors kept for three years after notification of unsuccessful application, with immediate deletion upon request. | To enable us to respond to any queries from the applicant; to notify the applicant of different opportunities for work or volunteering that arise at our charity in future. |
| Guest contributors to BioNews. | Name; contact details; organisation (if applicable); contributions; performance record. | Indefinite with immediate deletion upon request, in addition to which their name and organisation may remain on our website indefinitely. | Legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person in future; to enable us to document our organisational history on our website. |
| Students applying for the BioNews Writing Scheme (successful). | Name; contact details; study history; notes by assessors; performance record. | Three years from conclusion of participation in the Writing Scheme, in addition to which their name – plus a biography and headshot photo (the latter will be removed on request) – may remain on our website indefinitely. | Legal claims; to enable us to attribute authorship of BioNews articles on our website; to enable us to pass on queries received in response to articles; to enable us to commission BioNews articles from this person after conclusion of participation in the Writing Scheme; to enable us to document our organisational history on our website. |
| Students applying for our Writing Scheme (unsuccessful). | Name; contact details; study history; notes by assessors. | Deletion within three years of notification of unsuccessful application, with immediate deletion upon request. | To enable us to respond to any queries from the applicant; to notify the applicant of the next intake date for the Writing Scheme so that they can reapply if they wish. |
| Readers posting public comments under BioNews articles on our website. | Username and comment(s) posted. | Indefinite unless deleted by us at our discretion. | Legal claims; to enable us to moderate comments at our discretion; to enable commenters and the author(s) of the relevant BioNews article to respond to one another in subsequent comments. |
| Subscribers to BioNews. | Name; email address; whether an email was opened; whether a hyperlink in the email was clicked on. | Indefinite with immediate deletion upon request. | To enable us to send BioNews to subscribers; to measure the performance of email campaigns. |
| Subscribers to our events mailing list. | Name; email address; whether an email was opened; whether a hyperlink in the email was clicked on. | Indefinite with immediate deletion upon request. | To enable us to send email notifications of events; to measure the performance of email campaigns. |
| Subscribers to our general mailing list. | Name; email address; whether an email was opened; whether a hyperlink in the email was clicked on. | Indefinite with immediate deletion upon request. | To enable us to send email notifications of the charity's activities; to measure the performance of email campaigns. |
| Speakers and panellists at our public events. | Name; contact details; CV; contributions. | Contact details indefinite with immediate deletion upon request; written records of event contributions indefinite. | To enable us to organise and manage events; to enable us to document public events; to enable us to document our organisational history on our website. |
| Speakers, panellists and attendees at public events that are audiovisually recorded. | Audiovisual recordings of contributions and/or attendance in online videos or podcasts. | Indefinite. | If and when our public events are audiovisually recorded, this is announced clearly at the beginning of the event; attendees are asked to speak to our staff if they do not wish to be seen and/or heard in the recording, and we act upon their wishes; once these recordings are edited, finalised and published, it is impractical to re-edit them or to withdraw them from circulation. |
| Donors and Friends of PET. | Name; contact details; payment details; amount of donation. | Seven years from date of last donation. | HMRC and accounting; to enable us to thank donors; to enable us to circulate the Friends of PET newsletter. |
| Sponsors, grantors and organisations commissioning our services. | Name and contact details. | Seven years from date of last payment, in addition to which an organisation's name – plus a logo (although this will be removed on request) – may remain on our website indefinitely. | HMRC and accounting; public transparency; to enable us to approach organisations for further support in future; to enable us to document our organisational history on our website. |
| Parliamentarians; contacts within government agencies, other charities and professional bodies. | Name and contact details. | Indefinite with immediate deletion upon request. | To collaborate with people who have professional interests in our field, and to contact them if something relevant to their interests occurs. |
| Website users. | Information about visits to and use of this website (including the device used to access the website, an IP address, a geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths). | Indefinite. | To measure the performance of our website on an ongoing basis and make informed changes and improvements to it. |
