Updated 25 Jan 2021
At HART we are committed to providing a credible second opinion for politicians and the public to challenge the Government’s policies on tackling COVID-19. We are just as committed to protecting and respecting your privacy and data.
This document is our Privacy Policy. It explains how we collect data from you when you visit our website, what we do with it, how long we keep it and your rights in relation to the data you have provided to us. We will provide details of how you can unsubscribe from HART communications or ask for your data to be deleted.
In this document we have tried to avoid using legal language and technical jargon. We have also provided plain English summaries of some sections to make the information easier to digest.
We value your privacy and we are committed to meeting the requirements of data protection legislation. We invite you to take the time to read this policy carefully as we want you to be confident that the way HART handles your data is completely transparent, fair and reasonable.
If you have any questions or concerns do please [email protected]
Contents
1) HART – the Data Controller that looks after your data
2) Our legal basis for collecting and processing your data
3) What is ‘personal data’?
4) How HART gathers personal data
5) The data that we seek to collect from you
6) Collection of website data
7) How we store and protect your personal data
8) How we use your personal data
9) How long we hold your data
10) Who will see your data
11) Your rights and choices
12) Links to other websites
13) Keeping you up to date with changes to our privacy and cookies policy
14) What to do if you have further questions
1) HART – the Data Controller that looks after your data
Data protection law asks every organisation to make it clear who is responsible for looking after your personal data, so here are our details:
The Website www.hartgroup.org is owned and operated by HART (“We”, “HART”, “Us”). We are a voluntary unincorporated membership association. Our address is HART, 86-90 Paul Street, London, EC2A 4NE.
HART is the data controller of the data collected from you.
Who is HART?
HART is a group of highly qualified UK doctors, scientists, economists and psychologists who use a strong and broad multidisciplinary evidence base to challenge the Government’s policies on tackling COVID-19.
If you have any questions or concerns about who we are or how we process your personal data then drop us a line: [email protected]
2) Our legal basis for collecting and processing your data
At HART we collect and process your data on the basis that we clearly set out how we are going to collect and use your data in this privacy policy, and that you consent to such collection and processing when you sign up to our newsletter. See section 11.
3) What is ‘personal data’?
Personal data is any information which personally identifies you. This might include your name or email address. The information that we collect about you will be processed n accordance with this policy.
4) How HART gathers personal data
The main places that we gather personal data are:
· When you subscribe to our email newsletter on this website: www.hartgroup.org (“the Website”);
Other situations in which we gather personal data, that you may be less aware of, is:
· When you use the HART website (www.hartgroup.org) and we use tracking devices (known as cookies) to track your web visit. For more detail about how and what we do please see the HART Cookie Policy.
· When you apply for professional associate membership.
· When you report a problem with the Website or contact us regarding a complaint or enquiry.
5) Promotional Material
HART reserves the right to use any photographs or video taken during an event, by its members, or by any person connected to the organisation for use in any relevant promotional material. This media may be used on our website, social media profiles or for PR purposes.
6) Data we need to send you personal emails
At HART we send emails to you with information about our work. To do this we ask you to tell us your:
· Name
· Email address
· Consent to receiving communications from us
Data that helps us to measure the interest and response to our emails
At HART we want to understand whether you are opening our emails, and, where relevant, clicking on links within the emails that take them to our website. We do this because we want to learn which emails you find interesting and engaging. We also want to be able to identify people who have stopped opening emails for a period of time, so that we can try and tempt them to start engaging with us again or delete them from our database.
Data we need to retain to answer or resolve an enquiry or complaint
If you contact us with a complaint or enquiry we may keep a record of that correspondence to ensure that we can deal with it effectively.
7) Collection of website data
Like many other organisations with a website we use technology to collect and track data on people browsing the website. We do this because we want to know the answers to questions like the following:
• How many people are visiting our website?
• Where have they come from?
• What type of device they use (e.g. desktop computer or mobile phone) and the internet browser they are using (This technical information is useful to check that the web pages we have designed appear correctly on their device.)
• Which pages are they visiting and for how long?
• What are they clicking on?
How we collect website data
We use small pieces of data – known as cookies – to track web users’ behaviour and to recognize that you have visited before. We may also passively collect data through our use of pixels, beacons, log files and other technologies. Some of the emails we send to you may contain a “web beacon pixel” which allows us to identify when you have opened the email and to verify which links contained in the email you have accessed. We use this information to determine which parts of our emails are of most interest to you.
You can delete the pixel by deleting the email. If you do not wish to download the pixel to your computer or other device, you can do so by selecting to receive emails from us in plain text rather than HTML, via this form on MailChimp.
This data helps us to deliver more helpful information. For more specific information, please see the HART Cookie Policy.
HART uses ‘cookies’ or other similar tracking technologies to do the following:
• To administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve the website to ensure that content is presented in the most effective manner for you and for your computer;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep the website safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To make suggestions and recommendations to you and other users of the website about goods or services that may interest you or them.
Data that we collect as we track visits to our website
We collect details of visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources and links that you access.
Specific information that we collect from people browsing the site
With regard to each of your visits to the website we may automatically collect the following information:
i) technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
ii) information about your visit, including information that tells us the site you were previously browsing before coming to the Website, the pages you visited on the Website, and the page you went to when you left. We also track; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
8) How we store and protect your personal data
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
In the event of a suspected data security breach, we will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please note: in common with all other website owners we cannot guarantee the security of data that you transmit to us over the internet. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9) How we use your personal data
When you give us information, such as your name and email address, we use it in the following ways:
• The primary way that we use the personal information that you share with us is to send you relevant emails about our work.
• We may use your data to notify you about changes to our service or our privacy policy, or to give you notice that we will delete your data, unless you consent to continuing to receive communications.
• We may use your data to ensure that content from the Website is presented in the most effective manner for you and for your computer.
10) How long we will hold your data
We will only retain your personal data 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.
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 requirements.
HART will delete your data if your behaviour indicates that you are no longer interested e.g. if you stop interacting with our emails or website for a period of 12 months. If you stop interacting for 12 months we will delete your personal data at that point.
You can, of course, opt-out of receiving marketing from HART at any time, see section 11) ‘Your Rights and Choices’.
11) Who will see your data
HART values your privacy and will only share your data with other parties in very specific and limited circumstances. These are explained in this section:
We will share personal information with law enforcement or other authorities if required by applicable law.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of HART or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
12) Your Rights and Choices
The General Data Protection Regulation (GDPR) is a major piece of data protection law that gives you rights and choices about how your data is used. In summary, those include rights to:
· Fair processing of information and transparency over how we use your use personal information
· Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
· Require us to correct any mistakes in your information which we hold
· Require the erasure of personal information concerning you in certain situations
· Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
· Object at any time to processing of personal information concerning you for direct marketing
· Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
· Object in certain other situations to our continued processing of your personal information
· Otherwise restrict our processing of your personal information in certain circumstances
You can choose whether to receive marketing communications
HART uses personal data to send subscribers emails.
If you would like to choose to opt-out of marketing communications you can do so by visiting our unsubscribe form on MailChimp. You can change your communication preferences at any time.
You have a right to restrict the processing of your data
Every email we send to you will include a link at the top so you can unsubscribe from future communications.
You can choose to correct, update or delete your information
We want to make sure that your information is accurate and up to date. You may contact us using the below details to ask us to correct or remove information you think may be inaccurate.
If you would like us to remove the personal information we hold about you, please contact us at [email protected]
If you would like to see what information we hold about you, you can request details under the Data Protection Act 1998 and the General Data Protection Regulations – please send a description of the information you would like to see together with proof of your identity to one of the below options. No administration fee will be charged for considering or complying with such a request.
You have the right to object to your data being used for profiling purposes. All you need to do is contact us at [email protected]
You can find out more about your rights under Data Protection
For more information about your rights under the Data Protection Act and the General Data Protection Regulation (GDPR) go to the website of the Information Commissioner’s Office at ico.org.uk.
If you have a complaint about HART data processing
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at www.ico.org.uk/concerns or telephone: 0303 123 1113.
13) Links to other websites
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
14) Keeping you up to date with changes to our privacy and cookies policy
Any changes we may make to our Privacy Policy & Cookie Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes.
15) What to do if you have further questions
If you have any questions or concerns with respect to this policy or the Website you may contact us by email at: [email protected] or by post at: HART, 86-90 Paul Street, London, EC2A 4NE.
