Aluminate Privacy Notice
Royal Holloway and Bedford New College, also known as Royal Holloway, University of London, will act in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA2018) when controlling and processing your personal data.
This notice explains how we collect, use and share your personal data and your rights in relation to the processing of your data through the use of our Royal Holloway Connect platform (Royal Holloway Connect is hosted on the Aluminati Network Groups Aluminate platform).
In this notice:
- ‘personal data’ means any data which can identify you directly or indirectly (whether by itself or when combined with other data), regardless of the format or media on which the data are stored. This includes data that can identify you when combined with other data that is held separately (pseudonymous data) but does not include data that has been manipulated so that you can no longer be identified from it (anonymous data).
- ‘processing’ means any activity relating to your personal data including collection, use, alteration, storage, disclosure and destruction.
What personal data will be collected in Royal Holloway Connect
The data the College collects includes:
- Personal contact details
- Personal address details
- Education, professional qualifications details
- Current and previous employment details
- Usage data which may include how you use Royal Holloway Connect, who you connect and communicate with in the platform and how you engage with services and systems
- Communications data which may include your preferences in receiving marketing communications from Royal Holloway
- Visual images
Where you choose to provide this, special category data processed may include:
- Sexual orientation
- Gender reassignment
- Ethnic origin
- Trade union membership
- Religious or other similar beliefs
- Physical or mental health details
- Spent and unspent criminal convictions
Personal data provided by you about others
You may provide us with personal data about other individuals, for example, next of kin/emergency contact details and information about your family circumstances and dependents. You should notify the relevant person that you are providing their contact details to the College and in what capacity (i.e. as your listed next of kin/emergency contact).
How and when do we collect your personal data?
We will collect your personal data:
- When you register for a Royal Holloway Connect account
- When you update or amend your Royal Holloway Connect profile
- When you join a Royal Holloway Connect mentoring scheme or any other engagement scheme within the platform
- When you connect with alumni, recent graduates or students within the Royal Holloway Connect platform
- When you use Royal Holloway Connect to communicate with alumni, recent graduates or students within the platform
- When you contact us by any means with queries etc.
Personal data from third parties
Why do we collect this data, how do we use it and what is our legal basis for doing so?
We collect this data in order to verify alumni using the Royal Holloway Connect platform and in order to provide you a service through the alumni engagement functions within the platform. These include:
- mentoring programmes
- an alumni directory
- alumni personal profiles
- mentor profiles
The data provided by you to Aluminate is processed on the basis of your consent. You can withdraw that consent at any time and delete your account with the platform.
Any data which is passed from Aluminate to Royal Holloway during the course of your use of the platform is processed on the basis of our legitimate interests.
In relation to special categories of personal data and personal data relating to criminal convictions and offences, we may request your explicit consent unless a condition applies which allows us to process such personal data without doing so.
How long the College will retain your personal data
Sharing your personal data with third parties
We never sell any of your personal information.
International Data Transfers
How the College keeps your personal data secure
The College has put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in any unauthorised way or altered or disclosed. In addition, the College limits access to your personal data to the persons and organisations, including those described above, who have a lawful and/or legitimate need to access it.
The College has also put in place procedures to deal with any suspected personal data security breach and will notify you and any applicable regulator of a suspected breach where legally required to do so.
Aluminati Network Group who provide the services to host and maintain the Royal Holloway Connect platform 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.
You and your data
You have a number of rights in relation to the processing of your personal data by the College:
- Access: You have the right to request access to and be provided with a copy of the personal data held about you together with certain information about the processing of such personal data to check that the College is processing it lawfully and fairly.
- Correction: You have the right to request correction of any inaccurate or incomplete personal data held about you.
- Deletion: You have the right to request erasure of any personal data held about you where there is no good reason for the College to continue processing it or where you have exercised your right to object to the processing of your personal data.
- Restriction: You have the right to request restriction of how the College processes your personal data; for example, to confirm its accuracy or the College’s reasons for holding it or as an alternative to its erasure.
- Objection: You have the right to object to the College’s processing of any personal data which is based on the legitimate interests of the College or those of a third party based on your particular circumstances. You also have the right to object to the College processing your personal data for direct marketing purposes.
- Portability: You have the right to receive or request that the College transfers a copy of your personal data in an electronic format where the basis of the College processing such personal data is your consent or the performance of a contract, and the information is processed by automated means.
- Complaints: You have the right to complain to the Information Commissioner’s Office (ICO) in relation to how the College processes your personal data. Our registration number with the Information Commissioner’s Office is Z7056965.
The College may be entitled to refuse any request in certain circumstances and where this is the case, you will be notified accordingly.
Where the lawful ground relied upon by the College to process any of your personal data is your consent, you have the right to withdraw such consent at any time without having to give any reason. However, if you do so, the College may not be able to provide some or all of its services to you or the provision of those services may be affected.
You will not have to pay any fee to exercise any of the above rights, though the College may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, you will be notified accordingly.
To protect the confidentiality of your personal data the College may ask you to verify your identity before fulfilling any request in relation to your personal data.
Changes to this notice
The College may update this notice at any time and may provide you with further notices on specific occasions where we collect and process personal data about you. You should check this notice regularly to take notice of any changes. Where any change affects your rights and interests, we will make sure we bring this to your attention and clearly explain what this means for you.
Questions or comments
If you have any questions or comments regarding this notice or you wish to exercise any of your rights you should contact our Data Protection Officer by email at firstname.lastname@example.org.
You also have the right to complain to the Information Commissioner’s Office and you can find more information on their website – www.ico.org.uk