Holistic Think Tank (HTT) is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information.
HTT complies with the six principles of the General Data Protection Regulation (GDPR). Personal data is:
- processed fairly, lawfully and transparently
- only used for the specified, clearly explained purpose it was collected for
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- kept accurate and up-to-date
- only kept for as long as it is needed (usually until a project or activity is complete) and is then removed and securely deleted
- processed in a manner that ensures appropriate security of the personal data; it is stored in secure systems and only transferred by secure means.
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us by emailing firstname.lastname@example.org, writing to Dworkowa 2, 43-300 Bielsko –Biała, Poland.
We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.
We have appointed a Data Protection Officer who can be contacted by post, by sending correspondence to the following address: Inspektor Ochrony Danych (Data Protection Officer), Dworkowa 2, 43-300 Bielsko –Biała, Poland, or to the e-mail address: email@example.com
Any questions you have in relation to this policy or how we use your personal data should be sent to firstname.lastname@example.org
2. THE INFORMATION WE COLLECT
Data for carrying out the research function of HTT
The primary function of the Holistic Think Tank is to carry out research in relation to education to improve public policy making. Our work is usually quantitative in nature although we do undertake some small-scale qualitative studies.
If we are carrying out a primary data collection (i.e. we are asking for data directly from you) then we may provide a separate privacy notice for that study.
Data for carrying out the administrative functions of HTT
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by the Holistic Think Tank (Fundacja Fiducia).
Sensitive personal data for carrying out the administrative functions of HTT
We do not normally collect or store sensitive personal data about parters and those signed up to HTT’s newsletter. However, there are some situations where this will occur (e.g. if you have an accident on one of our events). If this does occur, we’ll take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff then we’ll keep a record of this (which may include personal data and sensitive personal data).
If you send us your CV, for example in response to an advertisement published on our website, we will also process the data indicated in the application documents that you have provided to us.
3. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter into, or perform, a contract with you (legal basic: art. 6 sec. 1 letter b of GDPR);
- comply with a legal duty (legal basis: art. 6 sec. 1 letter c of GDPR);
- protect your vital interests (legal basis: art. 6 sec. 1 letter d of GDPR);
- for our own (or a third party’s) lawful interests, provided your rights don’t override these (legal basis: art. 6 sec. 1 letter f of GDPR).
We process your sensitive personal data when it is necessary in order to fulfill obligations and exercise specific rights in the field of labour law, social security and social protection (legal basis: art. 9 sec. 2 letter c of GDPR). In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes)
HTT is permitted to process personal data for research purposes . This condition applies if processing is necessary for archiving purposes, scientific or historical research purposes or statistical purposes; is carried out in accordance with Article 89(1) of the GDPR; and is in the public interest.
We use personal data for administrative purposes (i.e. on our research, grant, and events programmes). This includes:
- receiving grant applications;
- maintaining databases of those signed up for our newsletter;
- fulfilling orders for goods or services (whether placed online, over the phone, or in-person);
- helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).
4. DISCLOSING AND SHARING DATA
Your personal data that has been collected for the purposes of HTT’s administrative functions – which include your name, organisation, and email address are held by our mailing list provider. By signing up for our newsletter you are agreeing to the terms and conditions of tool provider. This information is not shared with any other organisation. If you wish to unsubscribe from our mailing list at any time, you can do so by clicking the ‘unsubscribe’ link, found at the bottom of any email we send you – or by sending your name and email address to email@example.com stating ‘Unsubscribe’ in the email in the subject line or body of the email.
Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another NGO). We’ll only share information when necessary and we will never share your contact information (eg. email or telephone).
Data from third parties that we hold for research purposes will never be disclosed or shared without the written agreement of the data controller.
5. HOW WE PROTECT DATA
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorized access to, use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means).
All staff receives data protection training and we have a set of detailed data protection procedures required by personnel to follow when handling personal data set out in our policies.
Where we store information
HTT’s operations are based in Poland and we store our data within Poland and the European Union.
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information.
7. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);
- the right to have inaccurate data rectified;
- the right to object to your data being used for marketing or profiling; and
- where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. This is particularly the case where we receive survey or administrative data from third parties for research purposes as this will nearly always be in de-identified or anonymised formats. This means that no directly identifying information is shared with us. In these situations, the data collector will have provided you with a privacy notice that informs you how your data will be used but because we do not know who you are, we are not able to directly provide you with a privacy notice ourselves.
You can complain to HTT directly by using the details set out above.
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UODO which regulates and enforces data protection law in Poland. Details of how to do this can be found at https://www.uodo.gov.pl/
8. COOKIES AND LINKS TO OTHER SITES
The only cookies in use on our site are for Google Analytics. Google Analytics is a tool employed by organisations to help them understand how visitors engage with their website, so improvements can be made. Google Analytics collects information anonymously – and reports overall trends, without disclosing information on individual visitors. By using our site you are consenting to saving and sending us this data. You can opt-out of Google Analytics – which will not affect how you visit our site. Further information on this can be found here: https://tools.google.com/dlpage/gaoptout
Our website uses local storage strictly for system administration to provide you with the best possible experience – used in order to create reports relating to web traffic and user preferences. This includes: your IP address; details of which web browser or operating system was used; and information on how you use the site.
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact’ link at the top of the page).