PRIVACY POLICY
- Introduction
EdTech Hub is a brand name for a series of projects funded by international donors to undertake research and give evidence-based advice about how to use technology in education.
The donors involved in these projects are the UK’s Foreign, Commonwealth & Development Office, The World Bank and the Bill & Melinda Gates Foundation.
Administration of the EdTech Hub operation, including the Website is led by Results for Development Institute, Inc. (R4D).
This privacy notice will inform you about how R4D looks after your personal data when acting as a data controller of your personal data processed in connection with EdTech Hub activities. It will also explain what your privacy rights are and how the law protects you.
R4D respects your privacy and is committed to protecting your personal data. This privacy notice is for:
| The staff of EdTech Hub Funders | The staff of potential funders of EdTech Hub projects | The staff of Research Partners and other suppliers | The staff of potential Research Partners and other potential suppliers |
| Content Authors | Users of our website | Research Subjects | Individuals who receive our marketing communications |
You may find it useful to read the glossary at the end of this privacy notice before reading further.
- Important information and who we are
Please read this privacy notice
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may 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.
Controller
R4D is the controller and responsible for your personal data (collectively referred to as “R4D”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the data privacy manager using the details set out below.
Contact details
Full name of legal entity: Results for Development Institute, Inc.
Name of data privacy manager: Sophie Longley
Email address: dpo@edtechhub.org
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). We would, however, 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 notice and your duty to inform us of changes
This version was last updated on 21 February 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- 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 the following different kinds of personal data about you:
- Identity Data can includes first name, and last name, country of work or residence.
- Contact Data includes business/personal email address and telephone numbers.
- CV Data for example your employment and education history data, your academic qualifications and your interests as they may appear on a CV or other media.
- Image Data includes photographs and videos of you.
- Research Subject Data may include Identity Data, Contact Data, CV Data, Image Data, your academic performance, your age, information about the school fees that you pay, your income and your opinions plus Special Category Data (more on this below).
- IP Address Data your internet protocol address.
We may collect the following types of Special Category Data from Research Subjects: racial or ethnic origin, political opinions, religious of philosophical beliefs and health data.
We do not collect or otherwise process Special Category Data of Research Subjects under the age of 21.
- How is your personal data collected?
Direct interactions
You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
If you want to be involved on an EdTech Hub project as a researcher you may send us your CV Data by email so that we can assess your suitability for the research position.
You may send us Image Data for uploading on to our Website or other publications.
We may collect Research Subject Data directly from you when undertaking research projects.
We collect IP Address Data when you visit our Website.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
Our data processors may collect Research Subject Data from you.
Our Research Partners (who also collect Research Subject Data in the capacity of data controllers) may share with us some of the Research Subject Data that they have collected from you. For example, they may use our IT systems to store Research Subject Data or they may provide us with research papers or other articles to publish that contain Research Subject Data.
- 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 to work with you or for the purposes of undertaking or publishing research studies and articles. We will also use your personal data to send you information about EdTech Hub. If you are a Research Subject we will use your personal data to enable research papers to be written and published. We do not publish Special Category Data.
Any personal data that we publish in research papers will be kept to a minimum and would usually only involve the name and photograph of a Research Subject who had agreed to be interviewed. Most of the personal data that we collect from Research Subjects is used for the purposes of compiling statistical information used to produce research papers. Once the statistical information has been compiled and no further studies are to be undertaken on a Research Subject their personal data is anonymised. Your personal data will be collected and stored by us or our suppliers acting under our control or by our Research Partners or their suppliers acting under the control of our Research Partners.
Research papers are published under a Creative Commons (CC-BY) licence which means that anyone who accesses the research papers can re-distribute, modify and build upon them as long as attribution is given to the creator of the research papers. You can read more the Creative Commons (CC-BY) licence here: https://creativecommons.org/about/cclicenses/.
EdTech Hub Funders also have very wide rights to use the materials that are created on EdTech Hub projects so they may publish or authorise others to publish research papers containing your personal data as well.
See section 11 below to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in 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. 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 provide our services to your organisation | (a) Identity (b) Contact(c) Image Data | Necessary for our legitimate interests (to supply our services to organisations who fund EdTech Hub projects) |
| To enquire whether your organisation would be interested in funding EdTech Hub projects | (a) Identity (b) Contact | Necessary for our legitimate interests (to find organisations who may wish to fund EdTech Hub projects) |
| To receive goods or services from your organisation | (a) Identity (b) Contact (c) Image Data(d) CV Data | Necessary for our legitimate interests (to receive goods or services from our Research Partners or suppliers) |
| To consider your organisation’s offer to supply goods or services to us | (a) Identity (b) Contact (c) CV Data | Necessary for our legitimate interests (to identify potential suppliers or potential Research Partners to receive goods or services from) |
| To administer and protect our operations (e.g. troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity(b) Contact | Necessary for our legitimate interests (for running our organisation, provision of administration and IT services and network security) |
| To let you know about EdTech Hub projects | (a) Identity (b) Contact | Necessary for our legitimate interests (to promote our aims) |
| To publish content on our Website that you provide us with | (a) Identity (b) Contact (c) CV Data(d) Image Data | Necessary for our legitimate interests (to publish your content on our Website) |
| To receive communications from you through our Website | (a) Identity (b) Contact | Necessary for our legitimate interests (to enable Website users to contact us or leave comments on our Website) |
| To find out from what location you have accessed our Website and your use of our Website | (a) IP Address Data | Necessary for our legitimate interests (to enable us to understand how effective our Website is, to administer and improve our Website and to understand our audience reach) |
| To enable us or our joint controller Research Partners to carry out EdTech Hub research projects and publish the results (see “how we use your personal data” above). | Research Subject Data (not containing any Special Category Data) | Necessary for our legitimate interests (to enable us to fulfil our obligations under our contracts with EdTech Hub Funders which involve the administration of EdTech Hub projects and undertaking research projects for the purposes of publishing research studies that will give people and organisations the evidence they need to make decisions about technology in education) |
| To enable us or our joint controller Research Partners to carry out EdTech Hub research projects and publish the results (see “how we use your personal data” above). | Research Subject Data (containing any Special Category Data) | The Research Subject’s consent. |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around promoting EdTech Hub. We have established the following personal data control mechanisms:
Service offers from us
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you or how we can better promote EdTech Hub (we call this marketing).
You will receive marketing communications from us if you have requested information from us and you may receive marketing communications from us if we are legally permitted to make unsolicited contact with you. We will not contact you if you have opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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 would like 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.
- Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in section 5 above.
- External Third Parties as set out in section 11 below.
- Third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy notice.
All third parties are required to respect the security of your personal data and to treat it in accordance with the law.
- International transfers
We do not transfer your personal data outside the United Kingdom (UK) other than as set out below.
Like most businesses we use software to support our operations. For example, we use Microsoft as our email and platform providers. Your personal data may therefore be transferred out of the UK because Microsoft and other major players in the software industry store some of their data in the U.S.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
- 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 an operational 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 and a data breach reporting policy 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.
- Data retention
How long will you use my personal data for?
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.
Details of retention periods for different aspects of your personal data are available in our data retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see “request erasure” in section 10 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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 that 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you wish to exercise any of the rights set out above, please contact us.
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 may 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 may 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.
- Glossary
Content Authors individuals who write blogs or articles displayed on our Website or who post comments on our Website on those blogs or articles.
EdTech Hub Funders the UK’s Foreign, Commonwealth & Development Office, The World Bank and the Bill & Melinda Gates Foundation.
Research Partners any organisation that carries out research on any EdTech Hub research projects.
Research Subjects individuals whose personal data is collected by R4D or its processors for an EdTech Hub research project or whose personal data is included in an article or research paper that appears on the Website or other website or publications chosen by R4D to further the aims of disseminating EdTech Hub research papers.
Website the EdTech Hub website at https://edtechhub.org
LAWFUL BASIS
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means the data subject has given clear consent for us to process their personal data for a specific purpose.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
THIRD PARTIES
External Third Parties
- Service providers who provide IT and system delivery/administration services.
- Professional advisers who provide, for example, accountancy and legal services.
- Regulators and other authorities who may require reporting of processing activities in certain circumstances.
- Organisations who EdTech Hub Funders may direct us to transfer your personal data to when our contracts with the EdTech Hub Funders end.
