Privacy policy - Medical Research Scotland

INTRODUCTION

Welcome to the Medical Research Scotland’s privacy policy.

Medical Research Scotland 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 when you:

visit our website (regardless of where you visit it from),
use our application management system, and
contact us.

This privacy policy is provided in a single-layer format. Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Medical Research Scotland collects and processes your personal data through your use of this website, including any data you may provide through this website when you use our application management system, take part in events we organise and/or when you contact us.

This website is not targeted at children and we do not knowingly collect data relating to children. We may process the data relating to children where secondary education students attend our events, in which case the data is collected and processed by the relevant school or local authority and shared with us for the purpose of that event only.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Scottish Hospital Endowments Research Trust, Scottish Charity Number SC014959 (otherwise referred to as Medical Research Scotland) is the controller and responsible for your personal data (collectively referred to as “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, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Scottish Hospital Endowments Research Trust, Scottish Charity Number SC014959 (otherwise referred to as Medical Research Scotland)

Email address: enquiries@medicalresearchscotland.org.uk

Postal address: c/o Turcan Connell, Princes Exchange, 1 Earl Grey Street, Edinburgh EH3 9EE

Telephone number: +44 (0) 131 659 8800

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on November 2018.

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.

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:

1. - Identity Data includes full name, date of birth, employment information (experience, position etc).
  - Contact Data includes telephone number, email and address.
  - 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.
  - Application and Award Data includes your username/log in details and password, applications made, reports submitted by you, and details of successful awards made to you.
  - Usage Data includes information about how you use our website.
  - Communications Data includes your preferences in receiving information from us, including promotion of events and activities, 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.

We do not collect any Special Categories of Personal Data about 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). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of an application with you, and you fail to provide that data when requested, we may not be able to process your application and/or provide grant funding.

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 Application Data by filling in forms, using our application management system or by corresponding with us by post, phone, email or otherwise.
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.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from Google Analytics, which is processed in a way which does not identify individuals;
We may obtain your Identity, Contact and Application information from your employer’s website, or research/medical institution’s website or other publically available source.
We may receive Identity, Contact and Application information from a mutual contact within the research/medical sector.

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:

1. - Where we need to perform the contract (grant application) we are about to enter into or have entered into with you.
  - 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 obligation.
  - Where we have your consent.

Generally, we only rely on consent as a legal basis for processing your personal data in relation to promotion of our events and other related information from us, where we do not process your personal data in this manner under any other legal basis. We will obtain your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to such emails at any time by contacting us. You also have the right to opt out of our processing of your data when we contact you on the basis of our legitimate interests.

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 using our contact details above 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
Grant Application and Award process (including reports) through our application management system or otherwise, and to manage this relationship we have with you, including liaising with The Daphne Jackson Trust, and publishing and sharing details of successful awards including applicant details both on our website and materials, and with External Third Parties.	(a) Identity (b) Contact (c) Application	(a) Performance of a contract with you (b) Necessary for our legitimate interests (furthering our charitable purposes and evidencing such activities)
Review Panel recruitment and reviewing process	(a) Identity (b) Contact (c)Information and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to conduct panel reviews of the applications to the requisite standard)
Our events, including invitations, attendance and post-event follow up, and where necessary, sharing your data with other event partners.	(a) Identity (b) Contact (c) Information and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (maintaining relationship with you, promotion of events that link with application/grant-giving process) (c) Consent (where you sign up directly)
Processing donations and Gift Aid (as appropriate)	(a) Identity (b) Contact	(a) Necessary to comply with a legal obligation
To respond to your queries when you contact us through our website or by email/telephone	(a) Identity (b) Contact	(a) Necessary for our legitimate interests (for running our charity, proper administration)
To administer and protect our charity and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) usage	(a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, communications, customer relationships and experiences	(a) Technical (b) Usage	(a) 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 communications strategy)

INFORMATION AND COMMUNICATIONS

We strive to provide you with choices regarding certain personal data uses, particularly around providing information and promotion of events.

We may use your Identity, Contact and Application Data to form a view on events, other research grants and/or other related information we think you may want, or what may be of interest to you. We also use this information to consider whether you would be willing and appropriate to join a Review Panel. You can opt out of receiving this information at any time by letting us know.

You may receive information and communications from us if you have attended an event previously, been awarded a grant from us, or are known to us within the research/medical/scientific sector, and you have not opted out of receiving such information.

THIRD-PARTY COMMUNICATIONS

We will not send you any direct third party marketing unless we have your consent. As noted above, on the basis of legitimate interest, we may send you information on events, other research grants and/or other related information from within the research/medical/scientific sector which we believe may be of interest to you and this information may be from a third party. We will not share your information with the third party.

OPTING OUT

You can ask us to stop sending you promotional communications by contacting us at any time.

Where you opt out of receiving these promotional messages, this will not apply to personal data provided to us as a result of an application or donation made by you.

COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

Cookie name	Purpose
AWSELB	Our website uses a “load balancer” to direct web page requests to multiple servers. This cookie ensures that a visitor always gets directed to the same server, which ensures correct website behaviour.
_ga, _gat, _gid	These cookies are set and used by Google Analytics (as described above).
wfvt_, wordfence_verifiedHuman	Our website uses “Wordfence” , a security plugin. These cookies help it distinguish between malicious visitors to the website and genuine people.
_cfduid	Our website uses “Cloudflare” , a performance and security system. This cookie helps it determine trusted visitors to the website.
PHPSESSID	Users of the application management system may see this cookie, it is used to allow a user to log in and stay logged in for a period of time. It is essential for the function of the application management system.

Cookies can be disabled using the “Cookie Control” tool in the bottom-left of the website. Web browsers also offer control over cookies through the browser settings, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

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.

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 Purposes for which we will use your personal data above.

1. - External Third Parties as set out in the Glossary.
  - Specific third parties such as the Daphne Jackson Trust (in relation to specific applications and grants), Amazon Web Services (in relation to data centre services) and third party hosts or organisers of our events (who may need your personal data as part of the event organisation for purposes such as health and safety, and licensing).
  - Third parties to whom we may choose to transfer or merge with our charity. If a change happens to our charity, then the new Trustees 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 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

Currently, we do not transfer your personal data outside the European Economic Area (EEA).

In the event that we engage a Data Processor to provide services to us which involves a transfer of your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. - 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

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.

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.

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.

Specific retention periods:-

1. - All applications, grants, awards and reports (charitable activities in furtherance of our charitable purposes) will be permanently held for historical, scientific and analytical purposes;
  - Details of the Review Panel members will be held for 3 years after the individual’s resignation, and
  - Events, attendees, speakers and event organiser personal data permanently held for historical purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

1. - Request access to your personal data.
  - Request correction of your personal data.
  - Request erasure of your personal data, where we are not required to process it under a legal obligation or performance of a contract.
  - Object to processing of your personal data, where we are relying on your consent and our legitimate interest.
  - Request restriction of processing your personal data, where we are relying on your consent and our legitimate interest.
  - Right to withdraw consent, where the lawful basis relied on is consent.

If you wish to exercise any of the rights set out above, please contact us using our contact details above.

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.

COMPLAINTS

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.

10. GLOSSARY

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means where we have your genuine, positive affirmation to process your personal data for the specific purpose we sought your opt-in consent. Consent can be withdrawn at any time by contacting us.

THIRD PARTIES

EXTERNAL THIRD PARTIES

1. - Service providers acting as processors based Scotland with its data centre in the Republic of Ireland who provide IT and system administration services.
  - Professional advisers acting as processors and/or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide legal, investment, insurance, accounting and audit services.
  - HM Revenue & Customs, regulators and other authorities acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  - Specific medical research organisations, interested parties and stakeholders.
  - Mass mailing administrators acting as processors who provide mass mailing services.

YOUR LEGAL RIGHTS

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 in the following scenarios:

1. - If you want us to establish the data’s accuracy.
  - Where our use of the data is unlawful but you do not want us to erase it.
  - 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.
  - 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. 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.