Website and Email Users
This Privacy Notice sets out the information that we collect about you through the website and e-newsletter for our COSMO study, why and how we use this information in relation to the study’s activities, the legal basis upon which we process that information, your rights regarding that information and how you can update it.
In this policy, references to 'we', 'us' or 'our' means the Sutton Trust of 9th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP, and UCL CEPEO of University College London, 20 Bedford Way, London WC1H 0AL. We are the joint data controllers for the personal data relating to you that we collect and hold.
We respect your right to privacy and will only process personal information you provide to us in accordance with applicable UK data protection law such as the UK’s version of the UK General Data Protection Regulation (“UK GDPR“) and the UK’s Data Protection Act 2018.
For the purposes of UK data Protection law, Sutton Trust and UCL are both Data Controllers and Registered with the regulator of information rights in the UK, The Information Commissioner’s Office. (ICO). If you have any concerns about the way, we handle your data you may complain to the ICO. For further details please go here: https://ico.org.uk/make-a-complaint/.
1. What we collect
We only collect a minimal amount of personal information. This includes information you give when signing up to our newsletter (name, e-mail address, job title) or communicating with us.
We collect this information directly from yourself when signing up to our newsletter.
2. Why we collect it and what we do with it
| Our use of your personal information | Our legal basis for processing your personal information |
|---|---|
| We use your personal information to send you our e-newsletter, which includes all our marketing communications such as our research programme, including details of recent publications or blogs; our events and activities. | We will only contact you in this way if you have given us your consent to do so. If you withdraw your consent for us to contact you with this information, we will no longer use your contact details in this way. |
| We use website usage data and user data (such as your IP address and details of your browser and device) to provide products and services; to enable certain website functions; to better understand how visitors use this website; and to present timely and relevant information to visitors. | This activity is in our legitimate interest to help ensure the website operates properly. Public task: The processing of your personal data may be necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. |
Wherever we may use our legitimate interest to process your data, you may object to such processing.
3. Where we keep it
We store your data on The Sutton Trust’s shared drive. IT providers will have access to personal information stored on these systems. IT providers will be under contract with us as a data processor, meaning that they cannot use your data for their own purposes.
We are based in the UK and store our data within the EU. Some organisations which provide services to us may transfer personal data outside of the EU, but we will only allow them to do so if your data is adequately protected. Where we store or transfer any personal information about you outside of the UK, we will take appropriate measures to ensure that we or the third-party recipient protects your personal information adequately in accordance with this privacy policy and applicable data protection laws. Such measures may include UK safeguards such as the UK Addendum in conjunction with EU Standard Contractual Clauses, or the UK International Data Transfer Agreement. Both are subject to the UK Data Transfer Risk Assessment.
We may also use the following third-party service providers named below to process and store your data:
Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their privacy policy.
Google Analytics, which we use to measure the performance of the COSMO website. We do this to find out things such as the number of visitors to the various parts of the site. Search queries and results are also logged anonymously in Google Analytics to help us improve our website and search functionality. Read their privacy policy. You can opt-out of Google Analytics cookies altogether by opting-out of the browser add-on.
Statamic, whose software (and associated add-ons) we use to manage the content of this website. Read their privacy policy.
4. Who we share it with
Data collected via Mailchimp and Google Analytics will be accessible by the COSMO team, which comprises of members of staff at the Sutton Trust and UCL CEPEO. Read the Sutton Trust privacy policy and the UCL privacy policy. We will only use your data in the ways described above.
Occasionally, where we partner with other organisations, we may share information with them (for example, if you register to attend an event being jointly organised by us and another charity). We’ll only share information when necessary and we will never share your contact information (e.g. email or telephone).
5. How long we keep it
The Trust will store information only for the purposes for which it was collected and continually review our retention periods to ensure that personal data is not stored unnecessarily.
6. Social Media
We maintain presences on social media platforms including Twitter, LinkedIn and Instagram. We use a third-party provider, Buffer to manage our social media interactions. You can find more information on Buffer’s privacy policy.
Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
7. Links to third-party websites
Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
8. Your rights
You have certain rights in relation to your personal information. You have the right to request that we:
provide access to any personal information which we hold about you
update any of your personal information which is out of date or incorrect
delete any personal information which we hold about you
restrict the way that we process your personal information (including the right to prevent us making automated decisions using your personal information, and the right to request that we stop processing your information for marketing purposes)
provide your personal information to a third party provider of services
provide you with a copy of any personal information which we hold about you
consider any valid objections which you have to our use of your personal information
inform you of the purpose for processing your data.
We will consider all such requests and will try to respond to your request within 5 working days (and in any event within any time period required by law). Please note, however, that certain personal information will be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any.
If you would like to exercise any of your rights in relation to your personal information, please email or write to us using the contact details in this policy. We do not apply a charge for providing you with your personal information or responding to your requests.
If we do hold information about you we will:
give you a description of it
tell you why we are holding it
tell you who it could be shared with
let you have a concise and clear copy of the information.
We want to make sure that your personal information is accurate and up to date and we will be happy to correct or remove information you think is inaccurate.
If you have any concerns about the processing or use of data for these purposes or would like a copy of the data you have supplied directly to us, requests should be made in writing to dataprotection@suttontrust.com.
If you decide in the future that you no longer want us to use your information, please contact the Sutton Trust by e-mailing dataprotection@suttontrust.com or phoning 020 7802 1660.
If you have any complaints about the way your data has been handled you can contact the supervisory authority in the UK, the Information Commissioner's Office, on 0303 123 1113. They are open Monday to Friday between 9am and 5pm.
9. Changes to legislation
If our practices change, or there are changes to the law, we may need to amend or update this privacy policy. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
10. Contact us
The Sutton Trust
9th Floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP.
Phone: +44 (0)20 7802 1660
Email: contact-us@suttontrust.com
Web: http://www.suttontrust.com
Centre for Education Policy and Equalising Opportunities (CEPEO)
Department of Learning and Leadership
IOE, UCL's Faculty of Education and Society
University College London
20 Bedford Way
London WC1H 0AL
Email: cepeo@ucl.ac.uk
Web: CEPEO website
We keep our privacy notices under regular review. This privacy notice was last updated on 14/09/2021.