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1. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the Data Protection Act 2018 (UK).
2. What role does The MENTOR Initiative have?
The MENTOR Initiative (known hereafter as MENTOR) is the data controller for the purposes of data protection. This means that MENTOR decides how your personal data is processed and for what purpose. As Controller, MENTOR adheres to the principles of the data protection legislation which state that all personal data must be:
• fairly and lawfully processed;
• processed for limited purposes;
• adequate, relevant and not excessive;
• accurate and up to date;
• not kept for longer than is necessary;
• processed in line with your rights;
• secure; and
• not transferred to other countries without adequate protection.
As MENTOR is based in the UK, the UK Information Commissioner’s Office (ico.org.uk) is the leading authority for data protection purposes.
3. How does MENTOR process your personal data?
MENTOR complies with its data protection obligations by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
MENTOR uses your personal data for the following purposes: –
o To administer procedures according to core business requirements for staff and Consultants.
o To manage training and capacity building events run as part of MENTOR’s core business
o To maintain our own accounts and records as required by law
4. What is the legal basis for processing your personal data?
4.1 Contract
Processing is necessary for the performance of a contract with the data subject – for all employees, interns and Consultants to MENTOR.
Reducing Deaths and Suffering from Tropical Disease
4.2 Consent
Consent of the data subject – for participants of training programmes run by MENTOR where these participants fall within the scope of data protection legislation, either due to nationality or the location of the training.
4.3 Legal obligation
Processing is necessary for the fulfilment of a legal obligation – for all employees for which MENTOR is responsible in terms of providing data to HMRC and any other statutory, regulatory or governing body.
5. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only as required within normal business practice. MENTOR will only provide your data to third party service providers which support MENTOR in performing its core business. This limited to the administration of the HR function and includes the processing of personal data for managing leave, payroll, pension and travel/health insurance.
6. How long do we keep your personal data?
MENTOR keeps your personal data for no longer than reasonably necessary.
For all employees and Consultants, basic personal information will be retained for a period of 5 years for safeguarding/legal purposes, and as required by external funders for audit purposes.
For external participants of training programmes, limited data relating to name and email address will be retained as long as consent is given.
7. Your rights and your personal data
Under the data protection legislation, you have the following rights with respect to your personal data: –
• The right to request a copy of your personal data which MENTOR holds about you;
• The right to request that MENTOR corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for MENTOR to retain such data;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to lodge a complaint with the Information Commissioners Office (ICO).
8. Transfer of Data Abroad
All personal data is treated with confidentiality. Any personal data which needs to be transferred outside of the UK/EU for core business reasons, will be limited to the absolute necessary, and transferred in accordance with the IT policy. This includes restriction of access to data and additional security measures in the transfer process.
9. Further processing
If MENTOR wishes to use your personal data for a new purpose, not covered by this Data Protection Notice, then you will be provided with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, MENTOR will seek your prior consent to the new processing.
10. Contact Details
To exercise all relevant rights, queries or complaints, please contact MENTOR in writing (by letter or email) at:
Data Protection
The MENTOR Initiative
4th Floor (South Suite)
Burns House
Harlands Road
Haywards Heath
West Sussex
RH16 1PG
United Kingdom
Phone: +44 (0) 1444 412 171
Email: info@mentor-initiative.net
You can also contact the Information Commissioners Office on 0303 123 1113 / https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.