We operate this Privacy and Cookies Policy because we are committed to safeguarding the privacy of those using our website (isdhaldev.wpengine.com) and the confidentiality of any information that we collect about you. We are Institute for Strategic Dialogue. We are a limited company in England (number 06581421) whose registered office is PO BOX, 75769, London, England, SW1P 9ER. We are the data controller in respect of all personal data collected via our website. We are registered as a data controller with the Information Commissioner’s Office (“ICO”) and our registration number is ZA306601. This Privacy and Cookies Policy sets out how we will use any personal data that we may obtain from you. Our website is not intended for children and we do not knowingly collect data relating to children. If we change any of the terms of our Privacy and Cookies Policy we will post the revised policy on our website behind the “Privacy and Cookies Policy” link at the bottom of each page. Whenever you submit your information to us, whether it be by using our website, by email, over the telephone, in person or by any other means, we will collect and use of such information in accordance with the terms of this Privacy and Cookies Policy. We are committed to ensuring that all personal data we hold is treated properly and in accordance with applicable data protection legislation. In accordance with data protection legislation, we are required to explain to you how we will treat any personal data which we collect from or about you. You have the right to lodge a complaint with the ICO if you have any concerns with regard to the way in which we process your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. What information do we collect and how do we use it?
You may give us information about you by corresponding with us by phone, e-mail, social media or otherwise, by submitting an enquiry via our website, by submitting information for the purposes of being considered for a vacancy, by opting in to receive our newsletter and/or other marketing information, or by signing up to any initiatives, resources or programmes provided by us. We may also collect information about you through social media channels and other publicly accessible sources where such information is collected pursuant to our research and academic objectives. In such circumstances we have adopted procedures to ensure that such information is, where appropriate, anonymised or pseudonymised before it is processed any further.
The information we may collect, use, store and transfer about you includes the following:
- name, username or similar identifier (such as social media handle), title and job title (“Identity Data”);
- work contact details, address, email address and telephone number(s) (“Contact Data”);
- bank account and payment card details (“Financial Data”);
- passport information and other information necessary to book transport and accommodation on your behalf (“Travel Data”);
- your preferences in receiving marketing from us and your communication preferences (“Marketing Data”).
As a visitor to our website, we may also automatically collect data about you such as internet protocol (IP) address, 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 our website (“Technical Data”) as you interact with our website. We collect Technical data by using cookies and other similar technologies. Please refer to section 8 for further information regarding the cookies used on our website.
We have set out below a description of what personal data you may give us, the ways we use your personal data, and which of the legal bases we rely on to do so.
|Purpose/Activity||Type of Data||Lawful basis for processing|
|To respond to an enquiry made by you (whether by phone/email/social media/ through the website or by other means)||(a) Identity Data (b) Contact Data (c) Information submitted pursuant to your enquiry||Necessary for our legitimate interests (to respond to your enquiry and provide you with the information requested regarding our organisation and the services we provide)|
|To provide you with our newsletter and/or other marketing information||(a) Identity Data (b) Contact Data (c) Marketing Data||Consent. If you subscribe to receive our newsletter and/or other marketing information but subsequently decide that you no longer wish to receive our newsletter and/or other marketing information, please see section 4 below|
|To provide you with information regarding, or access to, our initiatives, resources or programmes and to obtain feedback in respect of such initiatives, resources or programmes||(a) Identity Data (b) Contact Data (c) Financial Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how our initiatives, resources and programmes are used and to improve such initiatives, resources and programmes)|
|To sign you up to attend and/or participate at our events||(a) Identity Data (b) Contact Data (c) Financial Data (d) Travel Data||Performance of a contract with you|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data (b) Contact Data (c) Technical Data||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To use data analytics to improve our website, customer relationships and experiences||(a) Technical Data||Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To consider you for a vacancy||(a) Identity Data (b) Contact Data (c) Information contained within your CV and application||Necessary for our legitimate interests (for running and improving our business)|
|To undertake research in accordance with our charitable objectives.||(a) Identity Data (b) Profile data such as opinions and affiliations linked to your social media accounts||In order to ensure this data is processed lawfully and transparently, the following procedures are followed by ISD:Data collected from social media platforms is primarily accessed through the official application programming interface (API) of that platform, and stored and used in compliance with that API’s terms of service. Data is only collected from platforms which users have knowingly accessed and have consented to provide that platform with published data.Any collected data is securely stored on a monitored server, accessible only to approved ISD staff. Data collected from social media sites is not stored for longer than is necessary.ISD applies techniques in artificial intelligence to social media data in order to conduct research. We ensure that the reasons for applying these techniques, the methodology used to analyse data, and the conclusions drawn from our analysis are presented clearly and fully in each report.ISD does not publish research based on personal data that is irrelevant to our research, nor is personal data shared with third parties without appropriate data protection safeguards. Most data published or shared with a third party is aggregated, anonymised or altered to prevent identification of a natural person.Where possible, data published in the course of ISD’s research is aggregated, anonymised or altered to prevent identification of a natural person. An exception to this policy is when the user is publicly known to the extent that they would not reasonably expect their public social media posts to be private.In the event that a data breach is discovered, ISD will act in accordance with the GDPR to ensure that any damage from a breach is minimised, including informing relevant supervisory authorities and acting to identify and resolve any security issues allowing the breach.In order to respect the rights of data controllers to maintain control of their personal data, ISD will remove any personal data pertaining to an individual who requests such deletion. This includes taking reasonable measures to ensure that content deleted from social media platforms is also removed from datasets used by ISD.|
If we require your information for the purposes of performing a contract with you and you fail to provide this information, or if the information you provide is not accurate, we may not be able to perform the contract we have or are trying to enter into with you. You warrant that any information you supply to us is accurate and up to date, that you will inform us if any such information requires updating, and that if you submit a third party’s details to us you have that third party’s permission to do so. We will not sell any of your personal data to any third party.
3. Third parties
We may share personal data about you:
- with third parties who are directly involved in dealing with any request or enquiry made by you;
- where such disclosure is required by law;
- with third parties who are providing us with professional advice;
- Where the disclosure is in connection with any criminal investigation, legal proceedings or prospective legal proceedings where permitted by law;
- where the disclosure is in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- where we have stated or informed you otherwise (e.g. in this policy or on our website).
We may share our research, which may contain personal data, with ISD Germany, ISD US, and with other third parties we have engaged on a project where it is necessary for our legitimate interests (or those of a third party) and the data subjects’ interests and fundamental rights do not override those interests. 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 processors 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. We will not pass on your personal data to any third party for the purpose of marketing unless we have obtained your consent to do so. We may also disclose your personal data to third parties in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers and subscribers will be one of the transferred assets.
4. How do you stop marketing information being sent to you?
We will only send you our newsletter and/or other marketing information to you if you have opted in to receive them. If you have opted in to receive our newsletter and/or any other marketing information from us, you can ask that our newsletter and/or other marketing information is no longer sent to you by emailing us at [email protected] or clicking on the appropriate link in the footer of any of our marketing emails. It may take up to 15 days to remove you from our marketing lists.
5. Security and International Transfers
We will take all reasonable steps to protect your personal data. However, the Internet is global and no data transmitted via the Internet can be guaranteed by us to be completely secure during transmission. We cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default. It is possible that the information you provide to us will be temporarily transferred via a route outside the European Economic Area (EEA) as it passes between you and us. Third parties based outside the EEA may be involved in initiatives, resources or programmes you have signed up to and, where that is the case, 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 will, subject to our comments below, ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The transfer is to a third party located in a country that has been deemed to provide an adequate level of protection for personal data by the European Commission.
- The transfer is subject to use of a contract approved by the European Commission which gives personal data the same protection it has in Europe.
In the absence of an adequacy decision in respect of the relevant country, or appropriate safeguards as detailed above, we will not transfer your personal data outside of the EEA unless we have a lawful basis for doing so (for example, because you have explicitly consented to the proposed transfer).
6. Your rights
If you have given your consent to receive our newsletter and/or any other marketing information, you may withdraw your consent at any time. Please see section 4 above for further information on how to do this. You have a legal right to see a copy of the personal data that we keep about you, subject to certain exemptions. Requests for such information should be made by email to [email protected]. In some circumstances you may also have a right to:
- rectify or erase any personal data we hold about you;
- restrict our processing of your personal data;
- object to us processing your personal data;
- data portability in respect of your personal data.
In accordance with applicable data protection legislation, we follow security procedures when we process your personal data. We may therefore request proof of your identity before disclosing certain information to you or acting on any requests pursuant to this section 6. Please contact us at the above address if you have any reason to believe that information we hold about you is inaccurate.
7. How long do we retain your personal data?
We only retain your personal data for as long as we need it for the purpose for which is was collected. Whilst taking in to consideration our legal obligations, we will on an ongoing basis: review the length of time we retain your personal data; consider the purpose or purposes for which we hold your personal data for in deciding whether (and for how long) to retain it; securely delete your personal data if it is no longer needed for such purpose or purposes; and update, archive or securely delete your personal data if it goes out of date. Information on how long we retain certain data is set out below. Alternatively, please contact us at [email protected] for further information. If we are booking travel and/or accommodation on your behalf, your Travel Data will be retained until the conclusion of the relevant event you are attending and/or participating at. If you have opted-in to receive our newsletter and/or marketing information, you can opt out at any time. If you have signed up to one of our initiatives, resources or programmes, the length of time that we retain your personal data will depend on the relevant initiative, resource or programme.