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Privacy Notice for Brightside’s Online Mentoring Platform
Brightside (which refers to the group of organisations 'the Brightside Trust' and 'Brightside Social Enterprise Ltd') is committed to protecting and respecting your privacy. This Privacy Notice relates to your personal information, which is any information or combination of information that could be used to identify you as an individual. This Privacy Notice explains how we collect, store and use the information you provide to us or that we otherwise collect about you – this may include some information that we have already collected when you first have the opportunity to read this Privacy Notice.
This Privacy Notice applies to your access and use of this website and Brightside’s online mentoring platform (the "Brightside Services") and forms part of our Terms and Conditions. As a mentor or mentee using Brightside’s online mentoring platform, when you register your online mentoring account, you will be asked to acknowledge that you have read and understood this Privacy Notice. In this Privacy Notice we refer to users of the Brightside Services (including this website generally, as well as the online mentoring platform), as "service users".
We may update or change this Privacy Notice so please check this page from time to time and review this statement for changes. We will notify you of changes to this Privacy Notice by posting a notice on our home page for a reasonable period of time and changing the “last updated” date – in the case of significant changes, we may also contact you directly to draw your attention to the changes.
This Privacy Notice was last updated on 17th May 2018.
If you have any questions or concerns relating to this Privacy Notice, please contact us. You can find details on specific areas of our Privacy Notice by clicking on the links below:
- What kind of information we collect and why
- How we use your personal information
- How we may share and disclose your information
- How we keep your information safe
- How long we keep your information
- Third party sites
- Children's online privacy
- Your data protection rights
- Contact us
1. What kind of information we collect and why
When you use the Brightside Services, to make your visit productive and enjoyable, and to enable Brightside to provide you with the best possible services, Brightside may collect and process certain information (including personal information) that either:
- you provide to us, for example when registering for our online mentoring platform or to receive our newsletter or completing an online survey
is transferred to us from third parties including, if you use our online mentoring platform:
- other institutions that have contracted with Brightside to carry out an online mentoring project with them ("Contracted Partners"); and/or
- your online coordinator (being an individual holding a Disclosure and Barring Service enhanced clearance, who is authorised by Brightside and/or its Contracted Partners to implement and maintain an online mentoring programme)
- you or your mentor (if you are a mentee) or mentee (if you are a mentor) upload or post to the Brightside online mentoring platform during your (or his or her) use of the Brightside Services (including any online survey in which you may participate); or
- you or your mentor or mentee provide to us in any other way, for example by emailing us, disclosing to us by telephone or during any meeting you may have with us, your online mentor coordinator or our Contracted Partners.
This information may include the following:
- personal contact details, including your name, postcode, mobile telephone number and e-mail address;
- biographical details, including information about your employment or education and DBS/CRB checks where applicable;
- demographic information, including information in relation to your age, gender, interests and hobbies; and
- statistical information, relating to your use of the Brightside Services, including course progression, messages sent or received, and number of visits to the Brightside Services,
but if you are a mentee or mentor it will also include a wide range of information posted or uploaded to our mentoring platform during your and your mentor's or mentee's use of the Brightside Services. If you are a mentee, this may on occasion include some limited personal information in the categories identified as particularly sensitive by data protection law, if included in the communications that you and your mentor upload or post to the platform – for example, information as to physical or mental health, religious or similar beliefs, political opinions, racial or ethnic origin or criminal convictions. Uploading or posting information in these categories is entirely voluntary. We do not use this information except in the provision of the Brightside Services to you.
If you do not provide (non-sensitive) information that we request from you, we may not be able to allow you to continue to participate in our mentoring programmes.
We may also collect certain types of information automatically, including:
- your Internet Protocol (IP) address or device identifier;
- your device’s operating system and browser type; and
- details of the websites visited before or after you visit our website, pages viewed and activities undertaken whilst using the Brightside Services.
2. How we use your information
Brightside may use your information for the purposes described in this Privacy Notice or as otherwise disclosed to you in the Brightside Services agreement or within the services themselves. For example, we may use your information:
- to set up a service user account so you can use the Brightside Services;
- so we can carry out the Brightside Services for you and our Contracted Partners, including:
- for our day to day operations;
- to meet our objectives; and
- to comply with legal obligations;
- to communicate with you about your use of the Brightside Services, including by way of survey where applicable;
- so we can better tailor are services to you and our Contracted Partners - Brightside will always anonymise any information used for these purposes to protect your identity;
- monitoring, evaluation, research and reporting purposes in respect of the Brightside services – except as discussed below (How we may share and disclose your information), Brightside will always anonymise any information used for these purposes to protect your identity; and
- to contact you about the services in which you have expressed an interest and, also, other goods, services and features Brightside and/or the Contracted Partners believe that you will find interesting. Each time you are contacted, you will be told whom you need to inform if you do not want to be contacted again by that person.
We abide by applicable data protection law in our collection, use and other processing of your personal information. Generally, we can lawfully process your personal information as described in this Privacy Notice because we need to do so in order to pursue our legitimate interests, and those of our Contracted Partners, in pursuing the purposes disclosed to you in this Privacy Notice, the Brightside Services agreement or within the services themselves. However note the following points:
- we will only contact you about services in which you have expressed an interest, or other goods, services or features Brightside and/or the Contracted Partners believe that you will find interesting, with your consent;
- our collection, use and other processing of information relating to health, and other personal information in the particularly sensitive categories discussed above (What kind of information we collect and why) is permitted on the special legal basis that it is necessary for the provision of the Brightside Services, which are confidential counselling, advice or support services; and
- as mentioned above, we may occasionally be required by law to disclose or otherwise process personal information.
3. How we may share and disclose your information
Your privacy is very important to us. We will not share your personal information with anyone outside of Brightside, other than with any Contracted Partner relevant to your mentoring programme, any online coordinator relevant to your use of the Brightside Services and our service providers (so we can provide the Brightside Services to you), except in the very limited circumstances discussed below. The platform does also allow you to share personal information with your mentor / mentee.
Three of our service providers currently host personal information outside the European Economic Area, in the U.S.A. However, they are all participants in the U.S. "privacy shield" scheme, which is approved by the European Commission as ensuring adequate protection for European personal data. These service providers and a link to their privacy notices are listed below:
- Survey Monkey, which we use for the conduct of surveys: https://www.surveymonkey.co.uk/mp/policy/privacy-policy/
- Salesforce, which we use for customer relationship management: https://www.salesforce.com/eu/company/privacy/full_privacy/
- Mailchimp, which we occasionally use for service updates and sending out the Brightside Newsletter: https://mailchimp.com/legal/privacy/
We keep track of the academic progress of mentees after they have completed mentoring programmes, so that we can assess the effectiveness of our services and improve them for the future. In order to keep track of your academic progress, if you are a mentee, we may provide basic information about you (sufficient to allow you to be identified) to evaluation, research and other educational partners (for example, UCAS) so that they can disclose information about your progress to us or otherwise assist us with monitoring and assessing your progress. We do not use these results in any way that might affect you individually, but only as part of our assessment of our mentoring programmes. If you do not wish us to use and share your information in this way please let us know (see Contact us).
In exceptional circumstances where a mentee or mentor is deemed to be at risk of significant harm or to have suffered significant harm, or to be a danger to another person, confidentiality may need to be broken. The mentee or mentor will be informed of our intended action, or in exceptional circumstances the action may already have been taken before the mentee or mentor can be informed. In addition, Brightside reserves the right to use or disclose any personal information as needed to satisfy any law, regulation or legal request, to protect the integrity of the Brightside Services, to fulfil your requests, or to cooperate in any law enforcement investigation.
4. How we keep your information safe
Your personal information will be kept on secure servers and kept confidential by Brightside and, except in the limited circumstances discussed above, will only be seen by Brightside staff and, if you are a mentor or mentee, our Contracted Partners relevant to your mentoring and your online mentoring coordinator. These parties are all contractually obliged to keep your personal information secure and confidential.
All messages will be kept private from any individuals except those stated above. From time to time, if you are a mentor or mentee, Brightside staff and your online mentoring coordinator may review messages and other materials posted or uploaded to the platform to protect your safety by ensuring that there is no misuse of this website or of your mentoring relationship.
5. How long we keep your personal information?
For platform users, we keep your personal information for no longer than 10 years and upon request will delete your personal information from our systems within three months.
Cookies are small text files that are placed on your computer by the websites that you visit. There are two kinds of cookies: session cookies, which we use to store information relating to your current session on the site but which are deleted when you leave the site; and permanent cookies, which remain on your computer so that our site recognises you when you return. The information in a cookie may include an encrypted version of your username and a unique identifier for that session. You need to enable cookies on your web browser in order to use this site. We also use Google Analytics to provide us with statistical data on how people use this site. Google Analytics cookies are third party cookies set by Google, which include both session and persistent cookies.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
7. Third party sites
This Privacy Notice only relates to the Brightside Services and does not extend to your use of the internet outside this website; in particular, it does not relate to any websites to which you may link using the hypertext connections within the Library section (or any other section) of our website or the Brightside Services and Brightside is not responsible for the privacy practices of other websites.
You are encouraged to read the privacy statements of the other websites you visit from your use of the Brightside Services so you are aware of their data privacy practices.
8. Children's online privacy
Brightside recognises the importance of protecting the privacy of children. We will not knowingly collect any personal information from children under the age of eleven years. When a service user discloses personal information to us, the service user is representing to us that he or she is at least eleven years old.
9. Your data protection rights
You have the right to request a copy of the personal information that we hold about you or ask us to correct any inaccurate personal information. You can also object to our processing of your personal information, or ask us to delete the information we hold about you or to restrict its processing so that we keep it but only make very limited use of it. All of these rights are subject to various exceptions and conditions. If you would like a copy of all or some of your personal information, or to exercise one of your other rights, please Contact us.
You can also complain to the office of the UK Information Commissioner: https://www.ico.org.uk.
10. Contact Us
If you have any questions or comments about this Privacy Notice or Brightside's personal data processing or data protection practices, or wish to:
- opt out of receiving communications about services in which you have expressed an interest, or other goods, services or features Brightside and/or the Contracted Partners believe that you will find interesting;
- ask us not to disclose information about you to evaluation, research and other educational partners so that we can track your academic progress (see How we may share and disclose your information); or
- exercise the data protection rights discussed above,
please contact us at firstname.lastname@example.org. You should also use this email address to let us know if any of your personal data changes. Alternatively, you can write to us at the address set out below, or call us on +44 207 922 7800.
Brightside CAN Mezzanine 32-36 Loman Street London SE1 0EH