Programme One Privacy Policy

Introduction

Welcome to the [Programme One]’s privacy policy. Programme One is an initiative managed in partnership by [Goodman Masson and members] and is a not-for profit entity and is a registered company limited by guarantee which operates through this website and in person, with offices at [4th floor, 120 Aldersgate Street, EC1A 4JQ London]

Programme One respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1          IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how [Programme One] collects and processes your personal data through your use of this website, or when provided by email or other written correspondence, or in person to person dealings.

Programme One provides services aimed at [school leavers over the age of 16 and] adults  and we do not knowingly collect data relating to children under the age of 16.

CONTROLLER

[Programme One] is managed by different legal entities, details of which can be found here: https://www.programmeone.com/agency/members-and-partners/. This privacy policy is issued on behalf of the Programme One initiative and is referred to as [“Programme One”], “we”, “us” or “our” in this privacy policy.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights in relation to that personal data, please contact our data privacy manager:

Email address: info@programmeone.com

Postal address: 4th floor, 120 Aldersgate Street, EC1A 4JQ London

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy and our compliance with data protection laws under regular review. It is very 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 policy of every website you visit.

2          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 as follows:

  • Identity Data includes full name, title, date of birth and gender.
  • Contact Data includes your email address, your telephone number (mobile and/or landline), your home and/or office address.
  • CV Data : your educational background and schools, colleges, universities or other establishments attended, your qualifications and achievements or aptitudes, your hobbies or interests, languages spoken, your work history including current and previous workplaces, your sector interest and aspirations, whether or not you would like to take part on our mentorship programme.
  • Transaction Data includes details about payments to and from you and other details of requests made by you via our website or in person to be in contact with a potential employer or company or obtain mentoring or marketing or information about future events and opportunities.
  • 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.
  • Profile Data includes your username and password, requests made by you via our website or in person to be in contact with a potential employer or company or obtain mentoring or marketing or information about future events and opportunities, your interests, preferences, feedback and survey responses.
  • 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. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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 policy.

In some circumstances we will 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.

In the course of collecting your CV Data it is possible that we may collect Special Category Personal Data about you directly or indirectly (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 criminal convictions and offences. This Special Category Data is subject to additional protection under data protection laws and we are careful to observe those legal requirements in our collection and processing of personal data as well as our dealings with you and third parties.

IF YOU FAIL TO PROVIDE PERSONAL DATA

In order to provide you with our services, you will have to provide certain personal data. If you fail to provide that data when requested, or do not want us to retain your personal data, we may not be able to provide you with our services.

3          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 and CV Data by filling in forms or by corresponding with us over the website, by post, phone, email or in person. This includes personal data you provide when you
    • Fill out the candidate or employer/company forms on our website
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • request to join our mentoring programme;
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will 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. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy https://www.programmeone.com/agency/cookie-policy/ for further details.
  • Third parties or publicly available sources. We may receive personal data about you from third parties and public sources, such as Technical Data from analytics providers [such as Google based outside the UK] and search information providers [such as [NAME] based [inside OR outside] the UK].

We  may collect and process Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4          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 need to perform the services we have contracted with you to perform (or are about to contract with you to perform). 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.
  • 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. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
  • Where we need to comply with a legal obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending your personal data to third parties (as a candidate or as part of the mentoring programme or even for direct marketing purposes). You have the right to withdraw consent to marketing at any time by contacting us.

Where we process Special Category Personal Data about you.

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 register you as a new candidate

(a) Identity

(b) Contact

(c) CV

Performance of a contract with you (providing our services)

To process and deliver our services including:

(a) reviewing your CV and processing it

(b) liaising with potential employers or mentors on your behalf

(a) Identity

(b) Contact

(c) CV

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to provide feedback or further information about yourself

(c) updating you as to our services

(a) Identity

(b) Contact

(c) CV

(d) Profile

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business 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 business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) CV

(d) Technical

(e) Usage

(f) Profile

(g) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

We may use your Identity, Contact, Technical, Usage, CV 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have signed up for services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We request this in order to share your personal data  with our partners and external third parties who may be able to provide you with opportunities, employment, work experience schemes, holiday or vacation schemes, events or insight sessions. Our third parties have been selected to support our initiative and provide services that relate closely to our intiaitive’s goals.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us via email or telephone or by replying to our emails using the “unsubscribe” option (usually indicated at the bottom of each email). Please note that opting out or unsubscribing to our emails may mean we are unable to contact you  to provide our services in the fullest sense and may limit the services and information or referrals we are able to provide.

COOKIES

Our Cookie banner allows you to accept or refuse cookies in use on this website. 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. For more information about the cookies we use, please see https://www.programmeone.com/agency/cookie-policy/.

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.

Where we are relying on your consent to process your personal data, the purpose for use is set out in the request for consent and your consent applies only to the purpose, which we will respect.

5          DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties such as [ partners working with us in the Programme One initiative]
  • External Third Parties such as
    • ALETO Foundation, if you have requested to join the mentoring programme
    • Other recruitment agencies and partners of Programme One, who, acting as processors on our behalf, consider your CV and personal data in order to promote you as a candidate for employment or referral to other potential employers;
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services to our business.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based UK who require reporting of processing activities in certain circumstances.
    • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data (and any Special Category personal data included in it) 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.

6          INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK

7          DATA SECURITY

We have put in place appropriate security measures to keep your personal data (including any Special Category personal data ) securely and prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, at Programme One, 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 appropriate internal procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8          DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. This may mean we retain your personal data on our servers (for our internal records only) for up to seven years after our last contact with you, however we will usually remove your personal data from our active candidate lists after one year from the last time we hear from you.  We may retain your personal data for a longer period, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

9          YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 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 if you want us to establish the data’s accuracy, or where our use of the data is unlawful but you do not want us to erase it. If 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 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it, we may also retain the personal data subject to restricted use.

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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 could 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 could 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.