This is the privacy notice of Opening Universities for Refugees. In this document, “we”, “our”, or “us” refer to Opening Universities for Refugees (OUR). We are charity number 1176378 registered in the United Kingdom (UK). Our registered office is at Flat 33, Somerset House, Somerset Road, London SW19 5JA.
1. This is a notice to inform you of our policy about all the information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers both information that may identify you (“personal information”) and information that may not. “Process” means to collect, store, transfer, use or otherwise act on information”.
2. If there are one or more points below with which you do not agree, your recourse is to leave our website immediately.
3. We take the protection of your privacy and confidentiality seriously. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, as far as is reasonable, and hope that you reciprocate.
5. Our policy complies with UK law, including that required by the European Union General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.
7. Except as set out below, we do not share or disclose to a third party, any information collected through our website.
8. We will never sell your data to a third party.
The bases on which we process information about you
EU GDPR law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then, if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you agree to our terms and conditions, a contract is formed between you and OUR.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1 verify your identity for security purposes;
1.2 provide you with newsletters and updates about OUR’s work; and/or
1.3 provide you with our services.
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions (when there is otherwise no contractual relationship between us) such as when you browse our website or ask us to provide you with more information about our work, including newsletters and our products and services, you provide your consent to us to process information that may be personal information.
Wherever reasonable, we aim to obtain your explicit consent to process this information.
Sometimes you might give us your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may pass your name and contact information to selected partner organisations such as universities participating in our programmes or offering scholarships.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
3. Information we process for the purposes of legitimate interests
We may process information on the basis that there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so after having given careful consideration to factors such as, but not limited to:
- whether the same objective could be achieved through other means;
- whether processing (or not processing) might cause you harm; and/or
- whether you would expect us to process your data, and whether you would, generally consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our organisation;
- responding to unsolicited communication from you to which we believe you would expect a response;
- protecting and asserting the legal rights of any party;
- insuring against or obtaining professional advice that is required to manage organisational risk; and/or
- protecting your interests where we believe we have a duty to do so.
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation or other legal requirement.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as, but not limited to, a search warrant or court order.
This may include your personal information.
5. Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
6. Sending a message to our support team
When you contact us, whether by telephone, through our website, or by e- mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We do not keep any personally identifiable information associated with your message, such as your name or email address.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our website
Disclosure and sharing of your information
9. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information will be personally identify you.
10. Third party advertising on our website
Third parties do not advertise on our website.
11. Data may be processed outside the European Union
Our websites are hosted in the United States of America.
We may also use outsourced services in countries outside the EU rom time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the EU.
We use the following safeguards with respect to data transferred outside the EU:
11.1 we are certified under an approved certification mechanism as provided for in the GDPR.
Access to your own information
12. Access to your personal information
12.1 At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
12.3 After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
13. Removal of your information
14. Verification of your information
When we receive any request to access, edit, or delete personally identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
15. How you can complain
15.2 If a dispute is not resolved then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
15.3 If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
16. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as it is required by us:
16.1 to provide you with the services you have requested;
16.2. to comply with other law, including for the period demanded by our tax authorities; and/or
16.3 to support a claim or defence in court.
17. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary at our sole discretion. The terms that apply to you are those that posted on our website on the day that you use our website. We advise you to print a copy for your records.