Privacy Policy
Using your Personal Information
Who we are
Led by Swansea University in partnership with Bangor University, the ION leadership project is backed by the European Social Fund to raise skills and drive forward productivity and turnover in small and medium sized enterprises (SMEs) as well as in larger companies.
Swansea University is an educational organisation established under Royal Charter and a registered charity with charity number 1138342, with its administrative office at Singleton Park, Swansea SA2 8PP. Swansea University ("We") are committed to protecting and respecting your privacy.
Identity and details of the data controller
Swansea University is the Data Controller and is committed to protecting the rights of individuals in line with the Data Protection Act 1998 (DPA) and the new General Data Protection Regulation (GDPR).
Swansea University has a Data Protection Officer who can be contacted through dataprotection@swansea.ac.uk
This document (together with our terms of use and any other documents referred to on it) provides an explanation of why we collect personal data as part of the ION Leadership project, how we process it and the steps we take to ensure data security at all stages.
All data collected through the project is processed and stored in accordance with the DPA 1998 and the GDPR.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
personal information we collect from you when you apply for the ion leadership programme
We collect the following personal information from you when you apply to take part in the ION Leadership programme:
- Name of applicant
- Business name
- Job role
- Contact telephone number and email address
- Home and business addresses
- Date of birth
- National Insurance number
- Language preference and competency levels in the Welsh language
- Highest educational qualification
- Right to work in the UK
- Gender
- Single adult household
- Care / childcare responsibilities
- Employment status
- Risk of housing exclusion
We also collect the following sensitive personal information:
- Ethnicity
- Disability
- Health conditions
- Number of dependent children
- Migrant status
Personal information we collect about you when you attend the ion Leadership Programme
In the event that you are accepted onto the training programme, the following additional personal information is collected: Evidence of:
- Right to work and live in the UK
- Evidence of employment
- Proof of home address
- Proof of work address
- Proof of qualifications
If you attend an overnight residential course the following additional personal information is collected:
- Name, address and telephone number of next of kin
- GP’s name and telephone number
- Any medical conditions or allergies
As part of the delivery of the ION Leadership training, the following additional information may be collected on:
- behaviours;
- competencies; and
- interests
Other personal information we may collect about you
We may also collect and process the following personal information about you when you subscribe to services we may offer from time to time on our website, if you report a problem with our site, or if there is an exchange of business cards at events or meetings:
- Name
- Business name and address
- Email address
- Telephone number
In addition we automatically collect the following information about you on each visit to our site:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Why do we collect personal information on you at application and service delivery and how do we use it?
We collect the personal information you provide us at application and during training delivery for the following reasons:
- To evaluate your eligibility for the ION Leadership programme according to funding compliance requirements and the programme’s approval process;
- To research, monitor and evaluate the effectiveness of the programme at operational management and governance boards and as part of the programme’s external evaluation to research and assess the programme’s effectiveness, delivery, outputs and impacts on you and your enterprise, in line with funding requirements;
- To report to the Welsh Government’s Welsh European Funding Office (WEFO) and the European Commission (European Social Fund) for regulatory monitoring, claim and audit purposes;
- To deliver optimal training and support to you;
- For health and safety reasons on attendance at residential courses.
Why do we automatically collect personal information on you when you visit our website?
We use information held about you in the following ways:
- to administer our site and for internal operations, including troubleshooting;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
What is our legal basis for processing your personal data?
For personal information collected during application and delivery of the ION Leadership programme of training processing is necessary for the performance of a contract with you as the data subject. Applicants must agree to the terms and conditions specified in our online application form to proceed with their application and be accepted onto the programme.
The University is also required to process special category data in line with obligations in the field of employment and the requirements of Welsh Government’s Welsh European Funding Office (WEFO) and European Commission (European Social Fund) for regulatory monitoring, claim and audit purposes as deemed necessary for reasons of substantial public interest (Articles 9(2)(b) and (g).
In other cases personal data is collected and processed with consent. Any personal data not required for the fulfilment of the contract will not be collected or processed without your consent.
Some processing may be necessary for the purpose of the legitimate interests pursued by the University or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Recital 47 of the GDPR acknowledges that processing personal data for direct marketing purposes may be regarded as carried out for a legitimate interests assessment, this has been carried out to ensure your personal data is used appropriately and in ways you would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing.
Who receives your personal information?
Information is made available to personnel requiring access in limited circumstances for the reasons outlined above. These include:
- ION Leadership project staff and other University administrative staff;
- ION Leadership governance and management boards;
- External advisers and contractors directly engaged with the ION Leadership programme;
- The Welsh European Funding Office and the European Commission ESF;
Personal information automatically collected on visit to our website may be shared with:
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Other circumstances in which we may disclose your personal information to third parties are:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of ION leadership, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
Data Protection legislation requires us to keep your information secure. This means your confidentiality will be respected, and all appropriate measures taken to prevent unauthorised access and disclosure. Only members of staff and contracted specialists who need access to relevant parts or all of your information will be authorised to do so. Information about you in electronic form will be subject to password and other security restrictions, while paper files will be stored in secure areas with controlled access.
Some information is collected through the use of surveys using the Qualtrics online tool. Qualtrics stores European customer data on its servers in the US. To facilitate its customers' compliance with European personal data export requirements Qualtrics has certified under the EU-US Privacy Shield Program. (Qualtrics’s privacy policy is available at https://www.qualtrics.com/privacy-statement).
The data we collect will be held for the duration of the ION Leadership project and for a reasonable period of time upon its conclusion to comply with regulatory audit (specified by WEFO / State Aid) and document retention requirements. Data will be stored to 2030.
Your rights
You have a right to access your personal information, to object to the processing of your personal information, to rectify, to erase, to restrict and to port your personal information.
Please note however that objecting to the processing of your personal information provided as part of the application or delivery process is likely to affect your eligibility for the programme and our ability to enter into a contract with you to provide services.
If you have provided consent to ION Leadership to process any of your data, then you also have the right to withdraw that consent, as a delegate the information you provide will be kept until 2030 and cannot be erased before this date.
Please visit the University Data Protection webpages (http://www.swansea.ac.uk/the-university/world-class/vicechancellorsoffice/compliance/dataprotection/) or https://www.bangor.ac.uk/planning/dataprotection/DPExtra.php.en for further information in relation to your rights.
Any requests or objections should be made in writing to the University Data Protection Officer:
Swansea University
Mrs Beverley Buckley, University Compliance Officer (FOI/DP) Vice-Chancellor’s Office Swansea University Singleton Park Swansea SA2 8PP
Email: dataprotection@swansea.ac.uk
Phone: 01792 606281
Bangor University
Gwenan Hine Head of Compliance Planning & Governance Office
Bangor University,
Bangor,
Gwynedd,
LL57 2DG
Email: gwenan.hine@bangor.ac.uk Phone: 01248 382413
Security of your information
Only members of staff and contracted specialists who need access to relevant parts or all of your information will be authorised to do so. Information about you in electronic form will be subject to password and other security restrictions, while paper files will be stored in secure areas with controlled access.
Our website and online application system is hosted by Amity Web Solutions. The Amity servers are physically located in a secure location next to London Bridge, under 24/7/365 guard (and used by many financial institutions). The website is regularly updated with security patches and Amity subscribes to a service of ethical hackers who will try to find their way around website security and report any issues to the web developer.
Payments are made online using a debit or credit card through Sage Pay. There is no retention of card numbers and the University cannot see any card numbers.
Any personal information we may receive about you from third parties such as results of tests on behaviours, competencies and interests will be treated in the same manner as data collected by us or provided by you directly to us.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How to make a complaint
If you are unhappy with the way in which your personal data has been processed you may in the first instance contact the University Data Protection Officer using the contact details above.
If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: -
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Marketing Consent
By signing up as delegates on the ION leadership programme, you are consenting for ION Leadership to contact you about ION leadership course information and administration. This will also include sending you information on ION course, event and support information.
If you attend an ION Leadership event then we may use photography from the events on social media and our website. If you attend one of our events, and would prefer not to be included in any photographs, please let a member of the team know at the event.
Your information is held by ION Leadership, in line with our Privacy Policy, which can be viewed through the link below:
https://ionleadership.co.uk/privacy-policy
Your information is held to enable us to correspond with you, answer your enquiries and to provide opportunities and advice.
In line with legislation, we will always give you the opportunity to opt out of future relevant electronic marketing from ION leadership, but as a delegate, we will need to still contact you about course activities and administration.
To opt out of electronic marketing for ION Leadership Swansea please click ion-unsubscribe@swansea.ac.uk
To opt out of electronic marketing for ION Leadership Bangor please click unsubscribe-ion@bangor.ac.uk
Individuals who are Non Corporate subscribers (including Sole traders and non LLP Partnerships)
If you are an Individual, sole trader or Non LLP Partnership we need to ask for your consent to opt in to receive relevant electronic marketing.
I agree for ION Leadership to send me specific information about relevant ION Leadership products and services, which would be of interest to you.
Your details will never be shared with another organisation to enable them to market to you.
How can we contact you?
Please tick the box.
ALL
Telephone
Mail/Letter
SMS/Text
ION Leadership will contact you again to renew your consent in 5 years to reaffirm your consent. The 5-year period covers the original 3 year term of the programme plus the 2-year extension.
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