What is the purpose of this document?

The College is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to anyone who engages with the NIHR RSS. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
   Accurate and kept up to date.
4. Kept only as long as necessary for the purposes we have told you about.
   Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, occupation, title, addresses, telephone numbers, and email addresses.
• Details pertaining to your project / study which link to you.

The details may include:

• your previous association with NIHR activities e.g. applications, grants, awards, studies, training activities projects and programmes, PPIE activities, patient research ambassador activities.
• Some services may optionally ask for additional data such as date of birth in order to fully participate (e.g. the Google+ service in NIHR Hub). You have full choice over your participation - and control over the disclosure of this information through the application.
• For formal interactions with NIHR – such as applications for funding - we will increasingly ask researchers for an ORCiD identifier as a consistent and universal identifier of a researcher across NIHR, and beyond. This will help us (and other research bodies) to recognise you as the same individual and will provide opportunities to remove duplication of your effort in recording information more than once.

How is your personal information collected?

We collect most of the personal information about you directly when you engage with the service and as part of that engagement process. We may also collect additional information from other parts of the College, where necessary, to assist us with our role in advising / supporting you.

How we will use information about you and the legal basis for processing your data under the GDPR

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.*
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.**
• Where you have consented to the processing.***
• Where it forms part of a legal obligation(s).**

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below. We have indicated by [asterisks] the legal basis (or multiple) for which we are processing:

• To provide you with the information and services that you request from us.*/*
• To undertake surveys / evaluations relating to the NIHR RSS.**
• To monitor your use of our information and communication systems to ensure compliance with our IT policies and prevent misuse.**
• To provide you with relevant news and / or invitations to events / training sessions.**/*
• Where you attend an event or training sessions.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• Where the processing is necessary for reasons of substantial public interest, and occurs on the basis of a law that is, inter alia, proportionate to the aim pursued and protects your rights as a data subject.*
• Where the processing is necessary for archiving purposes in the public interest, for historical, scientific, research or statistical purposes, subject to appropriate safeguards.**

Our obligations

We will use your particularly sensitive personal information in the following ways:

• Equality and diversity data, including Special Category Data, is collected for equality monitoring purposes. Equality and diversity data will only be used in an anonymised form to monitor our compliance with equality and diversity objectives, and to allow us to identify, and plan initiatives to address, areas where there may be underrepresentation or inequality in our systems, processes or procedures. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. */**

Automated decision-making

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers, other institutions involved in the NIHR RSS and/or other entities in the College group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK/EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the College group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Data retention

How long will you use my information for?

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. In this instance, the personal data collected as part of your engagement with the NIHR RSS will be retained for one year after the end of successive RSS agreements / projects.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, correction, erasure, and restriction

Right to withdraw consent

 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the NIHR RSS or College’s Data Protection Officer via the details listed below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to contact us

If you wish to contact the RSS Hub delivered by the Imperial College London and Partners to ensure that your contact details are correct and up-to-date or to ask for your contact information to be removed from our records, please contact us at:

Email: nihrss@imperial.ac.uk

Should you have any complaints or concerns about the way that the RSS Hub processes your personal information you can make a complaint to:

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at:

Imperial College London
Data Protection Officer
Exhibition Road
Faculty Building Level 4
London SW7 2AZ

e-mail: dpo@imperial.ac.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.