Privacy & Web Usage Policy ARIEL TRUST LIMITED is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). Any questions regarding this Policy and our privacy practices should be sent by email to Alternatively, you can telephone 0151 707 8211 or write to us at Ariel Trust The Florence Institute 377 Mill Street Liverpool L8 4RF WHO ARE WE? Ariel Trust Ltd is a registered charity (519688) and company limited by guarantee (2113575). HOW DO WE COLLECT INFORMATION ABOUT YOU? We collect information about you in various ways, such as through our website, social media channels such as Facebook or Twitter where you have made a connection with Ariel Trust Ltd, LinkedIn (in accordance with its license conditions), via email, job applications, job boards and in connection with our educational websites. We may collect the following personal information about you:- • Names, postal address, email address and telephone number; • Other personal information you may provide to us on your CV or during the course of our relationship. HOW WILL WE USE YOUR INFORMATION? Such information may be stored, processed and used and disclosed by us in the following ways:- • To provide our educational services to you and facilitate your access to our web-based resources • To keep you up to date about our projects • To develop and maintain our business relationship with you • To send your information to our funders as part of the monitoring & evaluation of our funding contracts • As part of the wider promotion of our work e.g. we may quote your feedback in evaluation reports or similar documents • To third parties where we have retained them to provide services that we, or you, have requested including references and criminal reference checking services ARIEL TRUST LIMITED LAWFUL BASIS FOR PROCESSING Ariel Trust will process your personal information lawfully in accordance with applicable data protection legislation. The Law on Data Protection is derived from various pieces of legislation. These include the General Data Protection Regulation (the ‘GDPR’) which became enforceable on 25 May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law, at least one of the legal grounds must apply. The two legal grounds that are most relevant to Ariel Trust Limited’s use of your personal information are: • Legitimate Interest: and • Performance of a Contract. Ariel Trust will only process your personal information if we have:- (a) a legitimate interest to do so in order to support our legitimate business purpose. Our use of your personal information will be fair and balanced and never unduly have an impact on your rights under data protection legislation, including the GDPR. (b) a contract with you that we can only fulfil by using your personal information. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy. THIRD PARTIES We may share your information with third parties, such as our funders where this is necessary for the performance of the contract. Ariel Trust will not sell your information to unrelated third parties. We may also need to share your personal information with a regulator or to otherwise comply with the law. TRANSFERRING INFORMATION OUTSIDE OF THE EU Ariel Trust will not transfer your data outside of the EU unless it is necessary to as part of the services we offers to you. By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. If we transfer your information outside of the EU in this way, we will take steps to seek to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. DATA RETENTION – HOW LONG WILL WE KEEP YOUR DATA? We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the following: 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. YOUR DUTY TO INFORM US OF CHANGES It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working or business relationship with us. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION Under certain circumstances, by law you have the right to: Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Ariel Trust will respond within the statutory timeline of 30 days and no fee shall apply. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). This is not an automatic right and will be balanced against Ariel Trust’s rights. This right does not apply where Ariel Trust is relying on performance of a contract as its lawful basis for processing. Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal information to another party. This right does not apply where Ariel Trust is relying on legitimate interest. Right to complain to a supervisory authority. Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Ariel Trust at the above address in writing. Intellectual Property All copyright and other rights (including database rights, trademarks (whether registered or unregistered) and all other intellectual property rights) in and to the Websites and their contents (which for the avoidance of doubt shall include all information contained in or available from the Websites ("the Contents")) are owned by or licensed to ARIEL TRUST or are otherwise used by ARIEL TRUST as permitted under applicable laws. Unless ARIEL TRUST explicitly states otherwise in writing on the Websites or elsewhere, you may use, view, download, copy or print textual or graphic content of the Websites provided that it is solely used by you for the purpose of enquiring about or lawfully delivering (under and subject to a licence obtained from ARIEL TRUST) the services provided by ARIEL TRUST and provided that you do not change or delete any copyright, trademark or other proprietary notices on such content. Under no circumstances may you use any Content on an unauthorised basis or in a manner that may give a false or misleading impression of ARIEL TRUST. You agree not to copy, reproduce, store in any medium (including in any other websites), distribute, transmit, modify, alter, disseminate, create derivative works from all or any part of any of the Websites or edit any part of any of the Websites other than as permitted above without obtaining ARIEL TRUST's prior written consent. Specific Prohibitions You may not use any device, software or routine to interfere or attempt to interfere with the proper working of the Websites nor may you attempt to decipher, de-compile, disassemble or reverse engineer any of the software comprising or in any way making up a part of any of the Websites. You agree to use all Websites for lawful purposes only and in a manner that does not infringe the rights of, or restrict the use of any of the Websites by, any third party. Liability The Websites and the Contents are provided for general information purposes only and whilst ARIEL TRUST has taken every care in the preparation of the Websites and the Contents, ARIEL TRUST cannot guarantee that the Contents will be completely up to date and free of mistakes. To the extent permitted by applicable law ARIEL TRUST makes no warranties, representations and/or undertakings (express or implied) in respect of the Websites and the Content (including the accuracy, reliability, suitability, quality, availability or completeness thereof). ARIEL TRUST excludes all liability (other than for death or personal injury caused by its negligence) in relation to the Websites and the Contents, whether such liability arises in contract, tort, negligence, breach of statutory duty or otherwise (including, without limitation, liability in respect of any losses, damages, costs or expenses of any nature whatsoever incurred or suffered by you of an indirect or consequential nature, such as loss of profits, data, business or goodwill). ARIEL TRUST makes no claims or representations that any or all of the Contents may be lawfully viewed or downloaded outside England and Wales and unless otherwise specifically stated, the Contents and these Websites are directed solely at consumers and/or businesses who access these Websites from England and Wales. Access to such materials may not be legal by certain persons or in certain countries. If you choose to access the Websites from outside England or Wales, you do so at your own risk and are responsible for compliance with the laws of your jurisdiction. Computer Viruses and Errors Whilst ARIEL TRUST will use reasonable endeavours to ensure that the Websites do not contain or promulgate any errors, viruses, bugs, other malicious code or harmful components and will be uninterrupted ARIEL TRUST makes no warranty or representation that this will be the case. However it is recommended that you should virus check all materials downloaded from the Websites and regularly check for the presence of errors, viruses, bugs, other malicious code, and harmful components. ARIEL TRUST excludes to the fullest extent permitted by applicable laws all liability (other than liability for death or personal injury caused by ARIEL TRUST's negligence) in connection with any damage or loss caused by errors, viruses, bugs, other malicious code or harmful components originating or contracted from the Websites and any interruptions in the running of the Websites. Termination ARIEL TRUST shall have the right to immediately terminate your use of the Websites (and if applicable the Contents) if ARIEL TRUST determines in their sole discretion that you have breached these terms and conditions or have otherwise been engaged in conduct which they determine in their sole discretion to be unacceptable. Cookies All Websites operated by ARIEL TRUST use cookies, however these cookies do not contain any Personal Data. Any time any individual uses any ARIEL TRUST website, such use will be subject to cookies unless the individual rejects them. For further information on ARIEL TRUST's use of cookies, please click here or contact ARIEL TRUST as set out above. Changes to this Privacy & Web Usage Notice Any policy changes, either due to business reasons or future changes in legislation will be posted on this page. This policy was last updated on [13 September] 2018.