Privacy notice - Alumni videos

Privacy Notice: Alumni Video Project

Introduction

Welcome to CAREER CHOICES DEWIS GYRFA LTD's privacy policy.

CAREER CHOICES DEWIS GYRFA LTD. (Careers Wales) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you work with us and will tell you about your privacy rights and how the law protects you.

Please use the Glossary at the end of this privacy policy to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Careers Wales collects and processes your personal data when you work with us on the alumni video project.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

CAREER CHOICES DEWIS GYRFA LTD. is the controller and responsible for your personal data (collectively referred to as "Careers Wales", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (see below for information on this), please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: CAREER CHOICES DEWIS GYRFA LTD. a company incorporated in England and Wales with company number 07442837 and registered office address Unit 4, Churchill House, 17 Churchill Way, Cardiff, CF10 2HH

Email address for our DPO: personal.data@careerswales.gov.wales

Postal address: Careers Wales, Unit 4, Churchill House, 17 Churchill Way, Cardiff, CF10 2HH

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would be grateful if you would please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes title, first name and last name
• Contact Data includes email address and phone numbers
• School Data includes details about the school that you attended
• Employer Data includes details of the organisation that employs you and about which you may be making your alumni video, together with your job title
• Video Data includes any personal data included in the video that you provide to Careers Wales as part of the alumni video project

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your School Data and aggregate the number of participants in the alumni video project and use such information to provide Welsh Government with feedback on our service.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

As part of the alumni video project we do not expect to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we expect to collect any information about criminal convictions and offences.  However, you may voluntarily decide to include some of this information in the content of the video that you provide to us for the alumni video project – this is up to you.  Careers Wales does not have control over the content of the videos that you provide to us.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to work with you on the alumni video project. We will notify you if this is the case at the time.

3. How is your personal data collected?

We expect to collect data about you directly from you.  You may give us your Identity, Contact, School, Employer and Video Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

• Express an interest in becoming involved in the alumni video project
• Sign up to take part in the alumni video project
• Work with us on the alumni video project
• Give us feedback or contact us

 4. How we use your personal data

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

• Where we have your consent to do so
• 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 we need to carry out our public task
• Where we need to comply with a legal obligation

We will only use your Special Categories of Personal Data and information about criminal convictions and offences where the law allows us to.  Most commonly, where you decide to include Special Categories of Personal Data and / or information about criminal convictions and offences in the content of the video that you provide to us, we rely on having your express consent to use such data when we store, use, process and share your video.  Less commonly, we may also process this type of information where it is needed in relation to legal claims or where you have already made the information public.

Important: You should be aware that if you do not wish to participate in the alumni video project, or if you give consent and then subsequently change your mind and withdraw it, you can still access our services (such as careers information, advice and guidance) for your own personal benefit.  Your right to seek services from us is independent of your participation in the alumni video project.

You can find out more about the types of lawful basis that we will rely on to process your personal data in the Glossary below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Withdrawing consent

Where we are relying on consent as the lawful basis of processing your personal data, you have the right to withdraw that consent.  Please see below for more information.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table at section 4 above:

• External Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy

We do not allow our third-party service providers (who are acting as our data 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.

6. International transfers

Save for your alumni video itself, we will keep your personal data in a database that is stored on Careers Wales’ own servers which are based in the United Kingdom.

Your alumni video itself will be uploaded to, stored on and shared with your old school via Vimeo.  Vimeo is a company that is based in the United States.  This means that your alumni video may be transferred to and processed in the USA.  Please note that U.S. data and privacy laws may not be as comprehensive as those in the UK.

7. Data security

We 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Our employees should only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will keep the video that you provided to us for use in the alumni video project for a period of 3 years from the date that we uploaded the video to Vimeo.

You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see the section headed your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us using the contact details set out above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). As a public body we do not rely on legitimate interests as the legal basis of processing when carrying out our public task.  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Public task means processing your personal data where it is necessary for the performance of a task carried out in the public interest or in the exercise of the official authority of Careers Wales.

Third parties

External Third Parties:

• Vimeo Inc which is based in the USA.  As stated elsewhere, we use Vimeo to host your alumni video and share it with your old school
• Service providers acting as processors based in the United Kingdom who provide IT and system administration services
• Your former school
• Professional advisers including lawyers and insurers based in the United Kingdom who provide legal, insurance and professional services to us
• Regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances

Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) or our public task and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy
  • Where our use of the data is unlawful but you do not want us to erase it
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We may also not be able to continue working with you on the alumni video project.  We will advise you if this is the case at the time you withdraw your consent

3 February 2021