INTRODUCTION

Welcome to the English Welsh & Scottish Railway Educational Trust Fund’s privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will tell you how we use and look after your personal data when you visit our website (https://ewseducationaltrust.co.uk/) or make an enquiry about or an application for funding to us (including when you access and/or share information on our application portal). It also includes information about your privacy rights and how the law protects you.

When we refer to “you” in this privacy policy we mean you as the person accessing, viewing and/or using our website or the person whose data we are processing in relation to a funding application (as an applicant or in your capacity as a relative or representative of the applicant).

The English Welsh & Scottish Railway Educational Trust Fund website is not intended for children under the age of sixteen. We may collect data relating to individuals under the age of 18 if an application is made for funding in that individual’s name, in which case applications should be made by a parent or guardian on behalf of the applicant.

[This privacy policy is provided in a layered format so you can click through to the specific areas set out below.]

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

 

1.  IMPORTANT INFORMATION AND WHO WE ARE

We may provide you with additional information about our data processing activities from time to time. It is important that you read this privacy policy together with any other notice we 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.

English Welsh & Scottish Railway Educational Trust Fund (also known as EWS Educational Trust) is a charity with registered number SC040334, with its principal address at Citygate, St. James’ Boulevard Newcastle upon Tyne, NE1 4JE and the Trustees of the EWS Educational Trust are the data controllers and responsible for your personal data. In this privacy policy we will refer to the Trustees of the English Welsh & Scottish Railway Educational Trust Fund as “we”, “us”, etc.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

If you are accessing our website and/or application portal on a device, the device manufacturer or host may also have access to the data you make available on the application portal. If you would like more information about what data these third parties collect and what they do with it, please read their privacy policies and terms and conditions.

CONTACT DETAILS 
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways.

Full name of legal entity: English Welsh & Scottish Railway Educational Trust Fund

Email address:  admin.office@ewseducationaltrust.co.uk

Postal address:  Citygate, St. James’ Boulevard Newcastle upon Tyne, NE1 4JE

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) but we would always appreciate the chance to deal with your concerns before you approach the ICO so 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. This version was last updated in [April] 2020. You can access an up-to-date version of our privacy policy on our website at any time and we recommend you check our privacy policy from time to time so you are aware of any changes.

It is important that the personal data we hold about you is accurate and current. Where relevant, please keep us informed if your personal data changes during your relationship with us by updating your account details on our application portal.

 

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 first name, maiden name, last name, date of birth, national insurance number, username or similar identifier.
  • Contact Data includes home address, e-mail address and mobile/landline telephone numbers.
  • Education Data includes information about qualifications previously obtained and/or currently held (including, university/college/school/provider attended, start date and length of course studied, level of course studied and area of study), information about the qualifications to which the application relates (including the intended university/college/school/provider, start date and length of course, level of course and area of study) and details of the applicant’s intended living situation when studying, including the cost of accommodation and any educational support needs.
  • EWS Connection Data includes job description and title of the applicant’s relative’s role within the UK rail freight industry, start and end date of the applicant’s relative’s employment and details of their employer and evidence of employment including a payslip and/or contract for the applicant’s relative.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  • Profile Data includes your username and password for accessing the application portal.
  • Usage Data includes information about how you use our website and application portal.
  • Special Category Personal Data includes information about your health where applicable to the relevant award applied for. We do not intentionally collect other special category personal data (which can include information relating to religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless relevant to the award applied for bbut where you supply this to us during the application process we will process this personal data. We do not knowingly collect any information about criminal convictions and offences.
  • We also collect, use and share Aggregated Data such as statistical or demographic data. 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 data to calculate the percentage of applicants in a certain age category. 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.

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 perform the contract we have or are trying to enter into with you (for example, to grant your application for funding). In this case, we may not be able to grant you access to all of the features on our portal but we will notify you if this is the case at the time.

 

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact Data, Educational Data, EWS Connection Data and Special Category Personal Data by creating an account and submitting an application via our application portal, if you submit a query on our website or if you otherwise give us feedback or contact us (including by e-mails).
  • Automated technologies or interactions. As you interact with our website and through our application portal we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

 

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 need to perform the contract we are about to enter into or have entered into with you. This includes where you apply for funding from us through our application portal and we assess your eligibility for funding and/or grant funding to you (Contract).
  • Where we have obtained your consent for processing your personal data (Consent).
  • 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 (Legitimate Interests).
  • Where we need to comply with a legal obligation (Legal Obligation).

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 (the legal bases are explained above). We have also identified what our legitimate interests are where appropriate.

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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as an applicant (or the individual making an application on behalf of an applicant) on the portal.

(a) Identity

(b) Contact

(c) Profile

Legitimate interest (in processing the application and contacting you/your contact regarding the application).

To process the grant application.

(a) Identity
(b) Contact
(d) Profile
(e) Education
(f) EWS Connection
(g) Special Category Personal Data (where relevant to the award for which you have applied)

Legitimate interest (in processing the application, contacting you/your contact regarding the application and granting the award if successful).
We will process your special category data with your express consent given to the Trust via the portal.

To notify you (as the applicant or the individual making an application on behalf of an applicant) about the outcome of your grant application.

(a)   Identity

(b)   Contact

Legitimate interest (in processing the application and contacting you/your contact regarding the application).

To grant awards if the application is successful.

(a) Identity
(b) Contact
(d) Profile
(e) Education
(f) EWS Connection
(g) Special Category Personal Data (where relevant to the award for which you have applied)

Contract
We will process your special category data with your express consent given to the Trust via the portal.

To ask you for feedback in relation to a grant.

(a) Identity

(b) Contact

(d) Profile

(e) Education

(f) EWS Connection

(g) Special Category Personal Data (where relevant to the award for which you have applied)

Legitimate Interests (in reviewing the awards we offer and the experience of our applicants and beneficiaries).


We will process your special category data with your express consent given to the Trust via the portal.

To notify you about changes to our terms or privacy policy.

(a) Identity
(b) Contact

Necessary to comply with a legal obligation.

To administer and protect the Trust, our website, our application portal and our other IT systems (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical
(d) Usage

Necessary for our legitimate interests (for running the Trust, managing our administration and IT systems and network security, to prevent fraud and in the context of a reorganisation or restructuring exercise)

To use data analytics to improve our website, application portal and associated systems, marketing, beneficiary relationships and experiences

(a) Technical
(b) Usage
(c) Aggregate

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To tell you about our grant opportunities and our work which we think will interest you (marketing)

(a) Identity

(b) Contact

Necessary for our legitimate interests in marketing our work and our funding opportunities.
You will have the option to opt-out of any marketing messages in any communication we send to you. Please remember that where you opt out of receiving these marketing messages, this will not apply to personal data provided to us and/or used by us in connection with providing funding to you.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website or app may become inaccessible or not function properly.

For more information about the cookies we use, please see www.aboutcookies.org

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 third parties set out below for the purposes set out in the table above.

  • Service providers acting as transactional processors based in the UK who provide payment, website, IT and system administration services.
  • Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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

If you are based in the EEA, we do not usually transfer your personal data outside the UK or otherwise outside the European Economic Area (EEA).

If you are based outside of the EEA, your data may transfer to us in the UK and then back to you, outside of the EEA.

 

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. They will 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 from which we collected it, 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 are passionate about the benefits the Trust can provide to applicants with connections in the rail freight sector. For this reason we collate information about the applicants and awards provided to use this for statistical purposes. We will anonymise your personal data (so that it can no longer be associated with you) if we use it 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 click on the links 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 at admin.office@ewseducationaltrust.co.uk

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.

YOUR LEGAL RIGHTS
You have the right to the following,

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 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) 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.