Privacy notice

How we collect, store and use personal data.

1. The data controller

The data controllers are:

��ɫֱ�� group includes Universities Scotland and Universities Wales.��

The Director of Operations has responsibility for data protection, and can be contacted by:

Email��[email protected]
Post��Woburn House, 20 Tavistock Square, London, WC1H 9HQ
Phone��020 7419 4111 (office hours only)

2. The personal data we are collecting

This privacy notice applies to information we collect about:

visitors to our website
our members
individuals who sign up for mailing lists and bulletins, request information from us or use our services
delegates attending our events
clients booking our conference and meeting facilities

Personal data we routinely collect includes:

name
postal address
email address
telephone number

For our employees we will also collect:

demographic data
medical data
diversity monitoring data
bank account details
national insurance number

For our conference delegates we will also collect:��

dietary and access requirements

3. How we collect personal data
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We collect personal data through:

web forms online
telephone
paper forms

4.��How we source data

We will find contact data from several sources, for example on institution websites for individuals, other online resources, Companies House and we will also be given contact details from an individual’s colleagues to add to our mailing lists.

We generally do not buy in data lists from third parties.�� If we felt this was necessary, we would conduct a data protection impact assessment.

5. The purpose for collecting data

We use the data to keep in touch with individuals interested in the higher education sector. This could include:

people working in higher education institutions, or organisations connected to higher education
political, business, media and policy contacts
attendees at our conferences and events

For the above groups, we will email news updates relating to their work and the wider higher education sector.

For our named members and their PA’s, we will use data for administrative purposes to manage membership.

In addition, Woburn House Conference Centre will keep in touch with clients through the management of their booking and to let them know of future services available and special offers from time to time.

6. Your rights as an individual��

You can unsubscribe from email communications at any time, using the unsubscribe button, or replying to emails with the instruction to be removed from a mailing list.�� As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

If an individual makes a subject access request, ��ɫֱ�� will tell him/her:

whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
for how long his/her personal data is stored (or how that period is decided);
his/her rights to rectification or erasure of data, or to restrict or object to processing;
his/her right to complain to the Information Commissioner if he/she thinks ��ɫֱ�� has failed to comply with his/her data protection rights; and
whether or not ��ɫֱ�� carries out automated decision-making and the logic involved in any such decision-making.

��ɫֱ�� will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise. This will be provided within one month of the request being made to meet GDPR requirements.

To make a subject access request, the individual should send the request to��[email protected]. In some cases, ��ɫֱ�� may need to ask for proof of identification before the request can be processed. ��ɫֱ�� will inform the individual if it needs to verify his/her identity and the documents it requires.

If a subject access request is manifestly unfounded or excessive, ��ɫֱ�� is not obliged to comply with it. Alternatively, ��ɫֱ�� can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which ��ɫֱ�� has already responded. If an individual submits a request that is unfounded or excessive, ��ɫֱ�� will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require ��ɫֱ�� to:

rectify inaccurate data;
stop processing or erase data that is no longer necessary for the purposes of processing;
stop processing or erase data if the individual's interests override ��ɫֱ��'s legitimate grounds for processing data (where ��ɫֱ�� relies on its legitimate interests as a reason for processing data);
stop processing or erase data if processing is unlawful; and
stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override ��ɫֱ��'s legitimate grounds for processing data.

To ask ��ɫֱ�� to take any of these steps, the individual should send the request to��[email protected]

7. If you have a complaint

The supervisory authority is the��. Individuals can lodge a complaint directly with them.
Details of how to report concerns are on the��.��The helpline telephone number is 0303 123 1113.

8. The legal basis we are relying on

��ɫֱ�� will use��legitimate interest��for contacts and communications for the following groups:

higher education sector and members
policy, political, business and media contacts
income generation activities – Woburn House Conference Centre and ��ɫֱ�� conferences and events.

For these groups the data held will be:

full name
postal address (business address)
contact details including address, telephone number and email (business contact details)

��ɫֱ�� believes that:

There is a genuine business reason (the legitimate interest) for processing this data, the purpose of ��ɫֱ�� (incorporating Woburn House Conference Centre) is:

To formulate policies on any matters affecting or relevant to the university sector of higher education in the UK.
To provide information, advice and assistance to universities within the UK, or any of their representatives, on any aspect of educational affairs, including administrative and financial matters relating to or connected with education.
To represent the university sector of higher education in the UK and to conduct dealings and to liaise with the Government, any local, national or other institutions, authorities, agencies, bodies or persons, wheresoever in the world situated.
To promote and provide facilities for discussion and consultation between representatives of university institutions in the UK, on any matters affecting or relevant to the university sector of higher education in the UK.

And for our income generating activities:

To operate Woburn House Conference Centre and ��ɫֱ�� conferences and events profitably to fund the work of ��ɫֱ��, therefore using contact details for direct marketing activities.

And has considered the��necessity test:

Processing individual’s data for the purposes of communicating with members, HE sector contacts, political, media, business and policy contacts is necessary to effectively service the needs and represent our members’ interests fully.
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��ɫֱ�� considers the impact on the individual to be low (the balancing test):

We believe there is value in individuals hearing about developments and opportunities in the sector.
Providing opportunities for networking with peers.
The individuals have already expressed an interest in our work through signing up for regular newsletter, using the facilities or attending an event.
Users can opt out of communications.
We are not using any special categories of data.
We will not transfer the data to third parties.

There are��safeguards in place:

Opportunity for all contacts to unsubscribe from mailings.
Email ([email protected]��) for individuals to practice their rights (see section 6).
The amount of data held on individuals is restricted to only what is necessary, and kept no longer than necessary.
Data will not be shared with third parties, without making individuals aware and having a clear data sharing agreement.
Access to data is restricted to only staff who need it for the performance of their roles.
IT systems are secure, with regular security testing programme in place.
Data protection training is done by all staff as part of their probation.

9.��Where our data is stored

Data is stored on premise in offices in London, Edinburgh and Cardiff.�� Where cloud hosted systems are in use, the data is stored in the EEA.

10. Profiling

When you visit our website, we may store some information on your computer. This information will be in the form of a 'cookie' or similar file and can help us in many ways. For example, cookies allow us to tailor a website to better match your interests and preferences. With most internet browsers you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. You can read more about how we use cookies on our��Cookies��page.

11. Our data retention policy

��ɫֱ�� has a policy on data and document retention.�� Retention periods are based on ICSA Guide to Document Retention (3rd Edition).�� If you have questions on our retention policy, email��[email protected]

12. Leaving our website

Links to external websites are not our responsibility and that once a user clicks on a link to an external site it will be subject to that organisation’s privacy policies, not ours.

13. How recent is this Privacy Policy

This policy was last updated in August 2021.��It will be reviewed annually, or before if we introduce any changes to our data practices.

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