Privacy notice

Privacy notice

This is the privacy notice of The Global Skills Project.

The Global Skills Project is a not-for-profit organisation registered in the UK (company registration number 07881225).

The Global Skills Project will be referred to as ‘we’ or ‘us’ from now on in this privacy notice.

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

Except as set out below, we do not share, sell, or disclose to third parties, any information collected through our website.

How we obtain personal data

The information we process about you includes information:

– you have directly provided to us

– that we gather from third party databases and service providers

– that we collect as a result of monitoring how you use our website or our services.

Types of personal data we collect directly

When you use our services, we ask you to provide personal data. This can be categorised into the following groups:

– personal identifiers, such as your first and last names, your title and your date of birth

– contact information, such as your email address, your telephone number and your postal address for communication

– records of communication between us including messages sent through our website, email messages and telephone conversations.

Types of personal data we collect from your use of our website

By using our website, we process:

– technical information about the hardware and the software you use to access our website, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system

– usage information, including how often you use our website, and the pages of our website that you visit

– how you wish to communicate with us; and responses and actions in relation to your use of our website.

Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

The bases on which we process information about you

The law requires us to determine under which legal basis we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant, then we shall immediately stop processing your data.

Information we process with your consent

When you browse our website or ask us to provide you more information about our services, you provide your consent for us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at [email protected]. However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

– whether the same objective could be achieved through other means

– whether processing (or not processing) might cause you harm

– whether you would expect us to process your data, and whether you would consider it reasonable for us to do so.

For example, we may process your data on this basis for the purposes of:

– improving our services

– record-keeping for the proper and necessary administration of our services

– responding to unsolicited communication from you to which we believe you would expect a response

– preventing fraudulent use of our services

– exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property

– insuring against or obtaining professional advice that is required to manage organisational risk

– protecting your interests where we believe we have a duty to do so.

Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal data.

Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

Information obtained from third parties

Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.

No such information is personally identifiable to you.

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses cookies. They allow information gathered on one web page to be stored until it is needed for use at a later date.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

– to track how you use our website

– to record whether you have seen specific messages we display on our website.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address.

We use this information in aggregate to assess the popularity of the webpages on our website. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally.

Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

Delivery of services using third party communication software

With your consent, we may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Teams) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations.

If you have any concerns about using a particular piece of software for communication, please tell us.

Data may be transferred outside of the UK

Our website is hosted in the UK.

We may also use third party providers to deliver some of our services, such as externally hosted software, and this may involve the transfer of personal data outside of the UK.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards.

These safeguards include contracts approved for use in the UK which give personal data the same protection it has in the UK or other equivalent measures as required.

Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

– to provide you with the services you have requested

– to comply with the law

– to support a claim or defence in court.

Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

If you wish to make a complaint

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

Compliance with the law

Our privacy notice complies with the UK General Data Protection Regulation and the Data Protection Act 2018.

Review of this privacy notice

We shall update this privacy notice from time to time as necessary.