Platform One Privacy Notice - March 2018
The University of Edinburgh (the “University”) is a charitable body registered in Scotland (registration number SC005336), incorporated under the Universities (Scotland) Acts.
Development and Alumni (“D&A” or “we”) exists to support the University’s global community of students, former students (“alumni”), current and potential supporters and other individuals and friends of the University, to develop mutually beneficial relationships; to provide services and opportunities to students, alumni, supporters and other individuals; to promote the development of alumni networks; and to fundraise, in order to support the University’s aim of delivering impact for society by discovering, developing and sharing knowledge that makes a difference locally, nationally and globally.
D&A are providing the social network and online platform, Platform One and related sites (“our services”), which will be available to members of the University of Edinburgh community including applicants, students, alumni, staff and friends of the University. Our registered and registering users (“members”) share their profile, engage with their network, exchange knowledge, personal and professional insights, post and view relevant content, learn, and find personal and career development opportunities.
This privacy notice applies to any registered or registering member of Platform One and related sites, communications and services, but excludes sites, communications, opportunities and services that state that they are offered under a separate privacy notice.
For the purpose of the General Data Protection Regulation, the data controller is the University of Edinburgh of Old College, South Bridge, Edinburgh, EH8 9YL, Information Commissioner’s Office Registration Number Z6426984.
This service is operated under contract by Aluminati Network Group Ltd. (Aluminati) acting under instruction as our Data Processor under the General Data Protection Regulation. Aluminati will process personal data strictly for the purposes of operating this service.
Aluminati is registered with the Information Commissioner under membership number Z8393842
This privacy notice uses “you” to mean any member about whom we collect and hold personal data, using the University’s Platform One and related sites, made up of applicants, students, alumni, staff and friends of the University.
How we use the information we hold
How we use your personal data will depend on your preferences. We process personal data about you in order to deliver, support, personalise and improve the opportunities and services we provide to you and others.
We use your data to authenticate you and authorise access to our services. Our services help you to connect with others, stay informed and seek personal and professional advice and support from other members. Personal data processed by us in the platform will allow you to:
- Connect, communicate, and seek informal advice and support from other members of the University of Edinburgh community. When you request advice or support, your request will include your username and photograph. We can send reminders to the user you contacted;
- Stay informed about news, events and ideas regarding the University and related professional topics you care about from within the platform; and
- Explore the profiles of other members, evaluate educational and career opportunities, seek out careers advice and support, and be found by those seeking careers advice or support. We will use your data to show you and others who work at a company, in an industry, a function or location, or have certain interests or connections. Your profile is visible to all members and administrators of our services.
We will contact you through email, notices posted on our website, messages to your Platform One inbox, and other ways through our services and push notifications. We will send you messages about the availability of our services, security, or other service-related issues, as well as messages about how to use the services, network updates, and reminders. We also enable communications between you and others through our services, including within groups and messages.
We offer settings so you can control what and how often you receive some type of messages and you can change your communication preferences at any time.
Our services allow viewing and sharing information including through posts, comments and messages:
- When you create a post or comment other members will be able to find and see your post;
- When you comment on another’s post, other members will be able see it, including the person who initiated the post;
- In a group, posts are visible to others in the group. Your membership in groups is public;
- When you join a group, you are visible to others and group administrators as a member; and
- When you send a message to another member, your message is only visible to that member.
Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.
Marketing and promotion
We use data and content about members for invitations and communications promoting membership and network growth, engagement with the University of Edinburgh and other related University services or initiatives.
Developing services through feedback and analysis
We use data, including feedback, to conduct research for the development of our services in order to provide you and others with a better experience, drive membership growth and engagement with our services, and enable connections between members.
We use your data to produce aggregate insights that do not identify you. For example, we may use your data to generate statistics about members, their profession, industry or location.
Occasionally, we may use your data as part of wider research into social, economic and employment trends. We will only publish or allow others to publish economic insights presented as aggregated data unless we have your permission.
We and Aluminati use data, which can include your communications, to check and confirm your identity, and to investigate, respond to and resolve complaints and service issues, such as bugs. We may also use your feedback (particularly if reported by significant volumes of users) and data to measure and drive improvements to our services.
Security and investigations
We and Aluminati use your data, which may include your communications, if we think it is necessary for security purposes or to investigate possible fraud or other violations of our acceptable use policy, terms and conditions, this privacy notice, and/or attempts to harm our members.
All communications sent as part of your mentoring relationships within any of our Advanced Mentoring programmes are visible to moderators of those programmes and may be read in relation to any of the above purposes.
D&A privacy notice
If you are a member of the University of Edinburgh alumni community or we otherwise hold a record for you in D&A as a potential or current supporter, or other individual or stakeholder, we will append and use certain information from Platform One and related sites so we maintain a complete and accurate record of our relationship with you, such as whether you have volunteered careers advice, or your current employment, as detailed in our privacy notice https://www.ed.ac.uk/development-alumni/about-us/data-protection.
What information we collect and hold and where this comes from
We collect personal data about you when you enquire about, register for, or use our services.
To create an account, sign up using your EASE login details. This allows us to authenticate you as a user and prepopulate some data within your account, including your name and email address. If you have been invited to join the platform as a friend of the university and do not have an EASE account, you will have the option to register directly through the platform. You provide further data, such as biography, education and professional history details and can choose to activate and complete a careers contact profile, in which you share the type of support you are willing to offer other members and/or the University.
You have choices about the information provided in your profile, such as your education, work experience, skills, photograph and location. Profile information helps you to get more from our services, including helping others find you. It’s your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available.
Posting and uploading
We collect personal data from you when you provide, post or upload it to our services. If you opt to sync with LinkedIn, we receive details from your LinkedIn profile (including education, professional history, biography, and address details).
We recommend that you check your settings for social media and the privacy policies of independent third party organisations to whom you provide personal data, such as LinkedIn, so you fully understand how they will process your personal data and what personal data is made publicly available. Depending on your settings or the privacy policies for these organisations, you might give permissions for us to access information from those accounts or services, as described above.
Information from others
You and others may post content that includes information about you on our services (as part of posts, updates and comments, videos).
We collect information about you when you send, receive, or engage with messages in connection with our services. For example, if you receive a mentoring request, we track whether you have acted on it and will send you reminders.
Service use log information
We log usage data when you visit or otherwise use our services, including our sites and platform technology (e.g. our off-site plugins), such as when you view or click on content (e.g. learning video) or perform a search. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
Cookies, web beacons and other similar technologies
Your device and location
When you visit or leave our services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we respect your settings.
Our services are dynamic and we will introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this privacy notice.
Who we share information with
We will never sell your personal data to third parties and will only pass your data to those third parties providing a service for the University, as set out in this privacy notice, or where under a duty to do so in order to comply with any legal obligation.
Personal data will not be shared with service providers other than those acting on the instructions of the University. Where this is the case, a written contract will be put in place between the University and the provider to set out the purposes for which the information can be used and the security measures that must be in place. This contract will ensure that the service provider agrees never to use your data for any additional purpose not set out in the agreement with the University.
Categories of recipients of personal data
- Provider of our Platform One and related sites used to provide our services.
- From time to time we may use an external service provider to help conduct research into social, economic and employment trends.
How we store and protect your information
Your personal data is held securely on Platform One and related sites within the EEA and in accordance with the General Data Protection Regulation, and is subject to appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss or destruction of, or damage.
In certain limited circumstances, your data may be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes employees engaged in, among other things, the provision of support services. We will take steps reasonably necessary to ensure that your data is treated in accordance with this privacy notice.
We take appropriate steps to ensure that we only record and store personal data which is relevant, that we keep it securely, that it is accurate and up-to-date and kept for an appropriate length of time. All University employees with access to your personal data, volunteers and contractors have a responsibility to maintain confidentiality to ensure that it is only used for the benefit of the University and its members, and we ensure relevant training or agreements are in place where appropriate.
Our website may, from time to time, contain links to and from websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the internet, and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to try to prevent unauthorised access.
Further information about the University’s Data Protection and Information Security policies can be found by clicking on the links below.
Data Protection: http://www.ed.ac.uk/records-management/data-protection
Information Security: http://www.ed.ac.uk/infosec
How long we hold your information
We retain the personal data you provide while your account is in existence or as needed to provide you services. We will retain your information and keep your profile open until you decide to close your account.
If you choose to close your Platform One account, your personal data will generally stop being visible to others on our services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our acceptable use policy and terms and conditions, or fulfil your request to opt out from further messages from us from Platform One.
Account information that is in our backups is removed at the expiry of those backups which are held securely and, where necessary, encrypted. Backups generally expire after 1-12 months depending on the class of information and any legal requirements regarding the duration they need to be retained.
Information regarding your interactions with others (e.g. through mail or group posts) will remain visible after you close your account or delete the information from your own profile or mailbox. We do not control data that other members may have copied out of our services. Groups content associated with closed accounts will show an unknown member as the source.
The legal basis for collecting and holding your information
Your choices and keeping us up to date
We provide you with choices that allow you to opt out or control how we use and share your data, including deleting or correcting data you include in your profile. We will only communicate with you in Platform One about information that we believe is relevant to you and you can change your communication preferences, stop using services, or choose to close your account at any time. This may mean you do not receive the communications, services and opportunities that may be of interest to you, such as information about networking, events, volunteering, career and other opportunities. To do this please visit your profile page within the platform.
If you are a member of the University’s alumni community, you may also change your alumni contact details or alumni preferences at any time via the alumni portal channels in MyEd or by contacting us at email@example.com
Alternatively, you can write to us at Development and Alumni, The University of Edinburgh, Charles Stewart House, 9-16 Chambers Street, Edinburgh, EH1 1HT, or call us on +44 (0) 131 650 2240.
Accessing your personal information
If you wish to request access to any of your personal data held by D&A, please use the University’s subject access procedure detailed at http://www.ed.ac.uk/records-management/access-to-information/data-protection-request
Changes to this privacy notice
We regularly review the terms of this privacy notice, which we may amend from time to time. If we make any substantial changes we will notify you through our services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. Your continued use of our services after we publish or send notice about our changes to this privacy notice means that you consent to the updated privacy notice. We will retain previous versions of our privacy notice.
Queries, concerns or complaints
If you have any queries, concerns or complaints about this privacy notice, or about how we hold and process your personal data in relation to Platform One and related sites, please write to:
Data Protection Officer
The University of Edinburgh
Edinburgh, EH8 9YL
You have the right to raise any concerns you may have with the Information Commissioner’s Office at firstname.lastname@example.org but we ask that in the first instance you raise these with our Data Protection Officer to allow us the opportunity to provide you with a response.