Research in Practice for Adults is a department of The Dartington Hall Trust, which is registered in England as a company limited by guarantee (company number 01485560) and a charity (charity number: 279756). Its registered office is located at The Elmhirst Centre, Dartington Hall, Totnes, Devon, UK TQ9 6EL.
Research in Practice for Adults is committed to protecting and respecting your rights. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, is used.
- Partner: an organisation with a contract with us permitting significant access to our services and content.
- Link Officer: an individual at a Partner organisation who acts as a primary point of contact (and a Data Controller under applicable law) during the paid contract.
- Record of Engagement: a Partner organisation's recorded activity, used for reporting to Link Officers to illustrate value for money during a paid contract.
- Individual Subscriber: an individual who subscribes to limited services and content.
- Public Account: a website profile created by an individual with no affiliation to a Partner organisation. This is a free use account with limited features.
- Data Controller: a person/organisation responsible for managing personal data under law.
- Data Processor: a person/organisation responsible for handling personal data under law.
- CRM: Customer Relationship Management software used to store customer information including personal data.
Data privacy law scope
For Public Accounts and Individual Subscribers, we are the Data Controller and Data Processor.
For Partner Membership we are Data Processor only: the role of Data Controller lies with the Partner.
If you are a Partner, your Link Officer is a Data Controller. They will administer users of our services at your organisation. Users with Partner membership should ensure they know the name of their Link Officer and contact them for advice as required about personal data.
We will collect basic personal data about you, including:
- Work address, phone number and email
- Job title, department and company
- Images (with consent)
- Video (with consent)
- Audio (with consent)
- Email correspondence and CRM notes
On occasions we may also need to collect and store special categories data that includes sensitive personal information about your health or medical conditions. We will collect this information from you to ensure we meet any statutory obligations and/or meet our duty of care to you.
Why we collect data
If you are a member or employee of a Partner organisation, or you have been nominated by a member organisation to have an account, we need your personal data to fulfil our contractual relationship. Without this information, it will not be possible to provide our services. We will not collect personal data that we do not need.
If you have created a Public Account we will only collect and use data you provide with your consent. This will be used to send communications that you have consented to receive.
Lawful basis for processing
Where a paid membership exists, we will process your personal data under the lawful basis of necessity for fulfillment of that contract.
Public Accounts where no money is exchanged; the lawful basis of processing is consent.
Change of purpose
We will only use your personal data for the purposes for which it is collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you to explain the legal basis which allows us to do so or request your consent.
Photography, video and audio
We capture photography, video and audio to deliver and promote our services. This data can contain personal information. All photography, video and audio recordings seek explicit consent from participants at the point of capture, which is kept on record. This includes parental consent where children and/or young people are involved.
Who processes my data?
All data we hold about you will be processed by our staff and approved third party contractors (sub-processors). Third party processors are required to take appropriate security measures to protect your personal data in line with our policies and act only under our instruction. They do not have permission to use your data for their own purpose without your prior consent. Details of third party processors can be found below.
Customer Relationship Management (CRM) system
The majority of customer personal data is held in our CRM. This contains basic personal data including:
- Job title
- Event attendance
- Email address
- Phone number
- Record of Engagement (for our website)
- Your employer
This data is held and retrieved to allow us to:
- Send non-marketing emails
- Manage your login details for our website
- Engage with you through our events (including understanding dietary requirements or special needs)
- Administer any contract/s that exist between us
- Understand your use of our website/s to fulfil a Record of Engagement.
Our website holds a minimum amount of personal data that is designed to permit authentication (logging in). All other personal data is held securely in our CRM.
A Record of Engagement is monitored though a privately hosted statistics package, Matomo. Matomo tells us which pages on our website you have used as an authenticated user, to fulfil our contractual commitments to Partners.
We retain no personal data on un-authenticated anonymous users.
We will only retain your personal information for as long as necessary to fulfil the purpose/s it was collected for, including satisfying any legal, accounting, or reporting requirements.
Personal data is disposed of by Research in Practice for Adults:
- When an individual verbally exercises their right to erasure and that request is not refused by Research in Practice for Adults.
- 2 year(s) after the last interaction by Research in Practice for Adults with an individual (including Public Accounts and non-activated accounts).
- If an individual or Partner organisation leaves Research in Practice for Adults, their data will no longer be processed, but may be retained for 3 year(s) following such date.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Third party data processors
We work with third party data processors. These organisations help us to fulfil our obligations as a service provider and are themselves subject to their own policies as under law. These organisations include:
- Email services
MailChimp. The Rocket Science Group, LLC 675, Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 U.S.A.
- Online internal team communication tool
Slack. Yalding House, 6th Floor, 152-156 Great Portland St, London, W1W 6AJ U.K.
- Online surveys
SmartSurvey Ltd. Basepoint Business Centre, Oakfield Close, Tewkesbury, Gloucestershire, GL20 8SD U.K.
William Pollard & Co Ltd. Oak House, Falcon Road, Exeter, Devon, EX2 7NU U.K.
- Video conferencing, hosting and webinars
Adobe Systems Europe Ltd. Market House Maidenhead SL6 8AG U.K.
Vimeo, Inc. 555 West 18th Street, New York, New York 10011 U.S.A.
- Website development and hosting technology
AB Multimedia Limited. Registered Office: 9 Richmond Road, Exeter, EX4 4JA U.K.
Research in Practice for Adults reserves the right to change or add to any third-party processors used in providing our services. Changes will be noted in this policy.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In the physical world
Our paper records are minimal but can include printed contracts, printed event information and other small sources of data used in day-to-day office activity. Personal data held on paper is digitised and the paper is destroyed as soon as possible.
We operate a clear desk policy, have a secure building, use a standard cross-shredder and use a regular secure document disposal service.
We use standard cloud servers for our technology, which can be in data centres in other locations apart from the UK. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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.
All websites (including CRM) are hosted on industry standard secure servers where access to personal data is encrypted behind authentication. Passwords for accessing the encrypted data are themselves encrypted and stored in the Dartington Hall Trust network behind a full network permissions set up by Dartington Hall Trust ICT.
User connection when accessing the website and CRM is encrypted through the appropriate use of certificates.
Ensure ongoing confidentiality, integrity, availability and resilience
All websites (including CRM) are backed up daily on a four-week rolling cycle. This permits availability to restore with minimal risk of data loss. Data is stored in industry standard databases with root admin security and are spread across multiple data centres in the EU and UK for full redundancy.
Restore in a timely manner after an incident
We have a procedure in place allowing for disaster recovery which includes 'Major Critical Incident' which permits continuity of the business with minimal data loss risk.
Testing the effectiveness of the security
Our web applications are occasionally subject to Penetration Testing by a consultant and issues are addressed.
Adherence to code of conduct
Employees are required to adhere to a Dartington Hall Trust code of conduct in relation to electronic systems. Our Staff have received training in General Data Protection Regulations.
Ensuring strict adherence from our contractors (third-party data processors)
We use approved contractors to build our websites (including CRM). These contractors are subject to strict rules about data access and handling and have access to our servers.
Where possible and practical, third-party contractors (processors) are guided by our staff directly and are subject to Non-Disclosure Agreements where personal data protection is concerned. Contractors are expected to run their own physical and technical security to a high standard and have full insurances. We have visited the offices of our contractors and are satisfied that they meet good standards of data security.
Your rights of access, correction, erasure and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and up-to-date. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. You may also request for supplementary information to be added to your information where relevant and appropriate.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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 information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us. 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 information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In circumstances where you may have provided your consent to the collection and use of your personal information for a specific purpose, you have the right to withdraw your consent for that processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose/s you originally agreed to, unless we have a legitimate basis for doing so in law.
We have appointed our Company Secretary as the data protection lead to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Chris Moores. You also 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.