How we look after personal data that we collect from you or that you provide to us
Oxford Policy Management Limited (“OPM”, ”we”,”us”,”our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data that we collect from you or that you provide to us and tell you about your privacy rights and how the law protects you. This version was last updated on 2 May 2018 and historic versions can be obtained by contacting us. The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until after 25 May 2018 as we are still working towards getting our systems ready for some of these changes. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how OPM collects and processes your personal data which may be collected through a number of ways including:
- your use of our website;
- subscription to our newsletters, publications or communications;
- through your work with us;
- through participation in surveys;
- when you apply to work with us.
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.
Oxford Policy Management Group (“OPM Group”) is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the OPM Group so when we mention “OPM”, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the OPM Group responsible for processing your data which will be acting as the controller of your personal data. Oxford Policy Management Limited is the controller and responsible for this website. 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 this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
By post: Data Privacy Manager Oxford Policy Management Limited Level 3, Clarendon House 52 Cornmarket Street Oxford OX1 3HJ United Kingdom By email: firstname.lastname@example.org
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 your personal data
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, so that we can update our records.
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.
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 depending on the transaction. We have grouped these kinds of personal type together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, job title and place of work;
- Contact Data includes personal address, email address and telephone numbers, business contact details, emergency contact details (where you apply to work with us);
- Financial Data includes bank account and payment card details;
- Transaction Data includes details about payments to and from you;
- 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;
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
- Biographical Data includes survey responses, any information you might provide to us in your application, curriculum vitae or in your interview and more generally, as part of the recruitment process, for example, test results, health questionnaires, proof of identity and professional qualifications and information that we may collect from you or from background check providers or referees;
- Behavioural Data includes details regarding your behaviour and preferences, hobbies and interests.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. We do not collect any Special Categories of Personal Dataabout 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 and criminal convictions and offences) unless;
- you have applied to work with us; or
- have provided that information as part of a survey.
Special Categories of Personal Data will be stored and processed in accordance with relevant legal requirements.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you but we will notify you if this is the case at the time. In particular if you fail to provide information when requested which is necessary for us to consider your application we may not be able to take your application further.
We use different methods to collect data from and about you including through: Direct interactions.You may give us your personal data by filling in forms or by corresponding with us or otherwise dealing with us. This includes personal data you provide when you:
- create an account on a website;
- subscribe to our newsletters, publications or communications;
- request information to be sent to you;
- apply to work with us;
- complete a survey; or,
- give us some feedback.
- Analytics providers and search information providers, such as Google based outside the EU;
- Providers of technical, payment and delivery services;
- Publicly availably sources such as Companies House;
- Recruitment agents;
- Disclosure and Barring Service in respect of criminal convictions;
- Named referees in connection with a job application;
- Background check providers in connection with a application to work with us as a consultant or employee including due diligence checks;
- Providers of psychometric testing in connection with a job application.
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 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.
- Where we need to perform any contract we are about to enter into or have entered into with you.
- Where we have your consent. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. 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 administer and protect our business (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||(a) Identity (b) Contact (c) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how the public understand our services, to develop them, to grow our business and to inform our strategy)|
|To provide newsletters and other project related information and marketing and to share with our client for the same purpose.||(a) Contact (b) Marketing and Communications Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (for our marketing purposes and in order to develop our products, services and grow our business) (c) Consent|
|To improve our website, services, marketing, and relationships||(a) Technical (b) Usage (c) Behavioural||Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our strategy)|
|As part of our recruitment process which includes assessing your suitability for a role, carrying out background and reference checks, keeping records and complying with our legal or regulatory requirements||(a) Identity (b) Contact (c) Biographical (d) Behavioural||(a) Necessary for our legitimate interests (to grow our business and to inform our structure). (b) Performance of a contract with you|
|To provide services to clients, to gain additional work and to provide you with further opportunities if you are working with us.||(a) Identity (b) Contact (c) Biographical||(a) Necessary for our legitimate interests (to grow our business and to inform our structure). (b) Performance of a contract with you.|
|For security purposes||(a) Identity (b) Contact (c) Financial (d) Usage (e) Technical||(a) Necessary for our legitimate interests (for security purposes and to protect our business) (b) Necessary to comply with a legal obligation|
|To enable you to complete a survey||(a) Identity (b) Contact (c) Biographical (d) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to grow our business, as part of projects that we are involved in and to inform our strategy)|
How we use Special Categories of Personal Data in Recruitment
We will use your particularly sensitive personal information (Special Categories of Personal Data) where you apply to work with us in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment and selection process;
- We will use information about your race or national or ethnic origin, religious, sexual orientation to ensure meaningful equal opportunity monitoring and reporting; and
- Depending on the role you are applying for, we will collect and process information about criminal convictions.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You can exercise your right to unsubscribe from marketing material at any time by contacting us at email@example.com.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any other transaction which we will continue to use, provided we have a lawful basis to do so.
We will get your express opt-in consent before we share your personal data with any company outside the OPM Group for marketing purposes.
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.
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.
- Companies within the OPM Group
- External third parties as follows:
- Service providers who provide IT and system administration services;
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and security advisers;
- Sub-contractors who are providing services to us in relation to services we provide to our clients;
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- Third parties for the purposes of processing an application to work with us such as organisations for due diligence purposes or providers of testing services and recruitment agents;
- Clients or potential clients for marketing purposes or where you apply to work with us;
- For the purposes of the prevention or detection of offences and/or the apprehension or prosecution of offenders, we may share information that we collect with the Police, other public or private sector agencies, governmental or representatives bodies, in accordance with relevant legislation, including public authorities, insurance companies, finance companies and/or other agencies;
- There are circumstances where the law allows or requires OPM to disclose information (including Special Categories of Personal Data) that we may hold about individuals where they consent or not. These are:
- When required by law;
- Protecting vital interests of an individual;
- Conducting legal proceedings;
- Obtaining legal advice or defending legal rights;
- Maintaining equal opportunities.
- Shareholders’ details may be disclosed as required under disclosure requirements mandated by regulators across the globe.
- 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 notice.
We require all third parties we engage as processors 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.
We share your personal data within the OPM Group. This will involve transferring your data outside the European Economic Area (EEA).Some of the external third party service providers that we engage as processors are based outside of the EEA. Where we share your personal data outside of the EEA to such providers or within the OPM Group, we will ensure a similar degree of protection is afforded to it and will abide by data protection laws with regard to such a transfer and ensure that there are appropriate safeguards in place or that the transfer is to a country deemed by the European Commission to provide an adequate level of protection for personal data. This does not apply where you apply or agree to work with us on a project based outside the EEA as explained below. If you apply to work with us on a project based outside the EEA, your personal data may be provided to our staff, consultants, suppliers, clients and other organisations working with us on the project and who are located in countries outside of the EEA where standards of data protection are not as stringent as those that apply within the EEA. Such transfer shall be necessary for the purpose of securing the relevant contract, for considering your application or for our proposal to be considered by a client. If we do this we will give you information prior to the transfer and will not do without your knowledge. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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. In the case of an application for a vacancy submitted using an OPM site, we will retain your information for six months from the advertised closing date after which it will be destroyed unless you request otherwise. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below. 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 or any processing that we are carrying out under another lawful basis. 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. Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below. 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 respondWe 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.
LAWFUL BASIS 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. 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.