Introduction
Welcome to the OpenUK’s privacy policy.
OpenUK is committed to protecting and respecting your privacy and protecting your personal data. This document will help you understand what personal data we collect about you, how we use that data, and give you clear and transparent guidance on your rights and:
1. The data we collect about you
2. How is your personal data collected?
3. How we use your personal data
4. Disclosures of your personal data
10. Changes to the privacy policy
We set out information on how OpenUK collects and processes your personal data through your use of this website and our activities, including any data you may provide through this website when you sign up to our newsletters, purchase a membership or take part in an event, work group, meeting or other activity.
This website is not intended for children and we do not knowingly collect data relating to children unless specifically stated.
It is important to you and us that you read this privacy policy together with any other privacy policy or 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 policy supplements any other notices and privacy policies and is not intended to override them.
OpenUK is the controller and responsible for your personal data referred to as “OpenUK”, “we”, “us” or “our” in this privacy policy.
Our CEO Amanda Brock is our data privacy Lead and 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 Lead using the details set out in Section 9 below.
1. 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:
- “Identity Data” includes first name, last name, username or similar identifier, marital status and title.
- “Contact Data” includes address, email address, twitter handle and telephone numbers.
- “Financial Data” includes bank account, paypal and payment card details.
- “Transaction Data” includes details about payments from you and other details of subscriptions and events you have purchased from us.
- “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.
- “Profile Data” includes your username and password, purchases or orders made by you.
- “Usage Data” includes information about how you use our website and services.
- “Marketing and Communications Data” includes your preferences in receiving newsletters and marketing from us and third parties 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. 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 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) other than in anonymised form. Nor do we collect any information about criminal convictions and offences.
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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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. 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 Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- become a supporter;
- volunteer with us by participating in an activity or work group;
- subscribe to our emails and newsletters;
- attend one of our events;
- request marketing to be sent to you;
- enter or nominate for an award; or
- give us feedback or contact us.
- 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. Please see our cookie policy for further details.
- Third parties. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- We may receive Technical and Usage Data about you from Matomo, a web analytics service provided by Matomo which is held on CIVIC servers in the UK. For further information about CIVICS’s privacy policy, please see their Privacy policy.
- We use WordPress for managing content on our website. For further information about WordPress’ Privacy Policy, please see their Privacy Policy.
- We use Google to share and receive files including meeting minutes. For further information about Google’s privacy policy, please see their Privacy Policy.
- Identity, Contact, Financial and Transaction Data from:
- Identity, Contact data, marketing and communications data from Mailchimp and Google based in the US. The information generated by the about you is transmitted to and stored by its servers in the US. For further information please see the Privacy Policies of Mailchimp and Google.
- Financial and transaction data from Stripe, our payment provider based in the US. For further information about Stripe’s privacy policy, please see their Privacy Policy.
3. 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:
- If we have entered into a Supporter arrangement 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.
- Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. 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 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.
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 register you as a new paying Supporter | (a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you |
| To process and deliver your subscription including:
(a) Manage fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To request sponsorship and administering sponsorships | (a) Identity
(b) Contact (c) Marketing and Communications |
(a) Necessary for our legitimate interests (to recover debts due to us)
(b) Performance of a contract with you |
| To send newsletters | (a)Identity
(b)Contact (c) Marketing and Communications |
(a) Necessary for our legitimate interests (to further our organisation’s objectives) |
| To send agenda and meeting minutes and related matters via email or Google Drive | (a) Identity
(b) Contact |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for apprising you of committee matters) |
| To notify to you about events, activities, news that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
(a) Necessary for our legitimate interests (to further our organisation’s objectives) |
| To enable you to attend an event | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for running events) |
| To organise and administer awards, honduras and other activities showcasing UK talent | (a) Identity
(b) Contact |
(a) Necessary for our legitimate interests (for promoting OpenUK, open source software, hardware, data etc. and rewarding winners in these fields) |
| To administer and protect our organisation and this website (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 organisation, provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content, notifications and information about our Partners, Sponsors and Friends to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests (to study how our members, visitors use our products/services and website, to develop them) |
| To use data analytics to improve our website, products/services, marketing, members and other stakeholders’ 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 further our business objectives and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
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.
4. 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 above.
- External Third Parties as set out in Section 2 above. External Third Parties also include:
- Website hosting company CIVIC UK based in 12 South Charlotte Street, Edinburgh, Scotland, EH2 4AX.
- Professional advisers, Researchers and agents acting as processors or joint controllers including without limitation lawyers, bankers, auditors, and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Caterers, event organisers etc, acting on OpenUK’s behalf.
Third parties to whom we may choose to sell, transfer or merge parts of our organisation 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 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.
5. International transfers
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. 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.
7. Data retention
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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
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.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes to:
- Request a copy of your personal data and information about our processing of it;
- Request that we correct any personal data that we hold on you;
- Request that we delete information on you, if we do not need to hold it;
- Request to object to the processing of your personal data in certain circumstances;
- Request that we copy or transfer your personal data to another IT environment; and
- Right to withdraw consent.
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 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.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy Lead in the following ways:
Email address: [email protected]
Postal address: 8 Coldbath Square, London EC1R 5HL
Telephone number: 030 3040 2030
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.
We keep our privacy policy under regular review.
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.