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National Centre for Accessible Transport Privacy Notice

Information about ncat and the Coventry University Group

The National Centre for Accessible Transport (“ncat”) is a consortium of six partner organisations

Coventry University

Connected Places Catapult

Designability

Policy Connect

Research Institute for Disabled Consumers

WSP

ncat is managed and run by The Coventry University Group (“the Group”) as part of this innovative research initiative, launched together with Motability, the Charity.

The Coventry University Group is an umbrella term for Coventry University and all of the locations owned and governed by Coventry University. As a visitor to the website or a participant of the research project your personal information will be processed by Coventry University, as well as other members of the Coventry University Group, and it may also be processed by ncat partner organisations, as part of nact’s work.

Scope

This privacy notice includes details around how personal information will be processed as part of the research project and National Centre for Accessible Transport. Schedule1 sets out information about us including our partner organisations who may be processing your personal information and when they might do this. In this privacy notice, ‘we’, ‘us’ and ‘our’ means Coventry University together with the members of the Coventry University Group or research partners. Coventry University Group are a data controller of your personal information, which means that we are responsible for looking after it. This notice does not cover any other organisations outside of ncat you provide personal information to. Those companies have their own privacy notices, so remember that the information you give them will follow their rules and not ours.

Contact Us

If you have any questions, comments, complaints or suggestions in relation to this notice, want to exercise your rights or any other concerns about the way in which we use personal information about you, please contact the Information Governance Unit at Coventry University. You can email enquiry.igu@coventry.ac.uk or write to the Information Governance Unit, Coventry University, Portal House, 163 New Union Street, Coventry, CV1 2PL and a member of Coventry University’s dedicated team will respond to you.

Alternatively, you can contact our Data Protection Officer by writing to Data Protection Officer, Coventry University, Portal House, 163 New Union Street, Coventry, CV1 2PL. You can also email dpo@coventry.ac.uk.

We will do our best to help you with your query and/or resolve any issues.  If you’re still unhappy, you can contact the Information Commissioner’s Office (ICO). Their website has details on how to contact the ICO.  Alternatively, you can call their helpline on 0303 123 1113.

Personal information we collect about you

The type of personal information we collect about you and how we collect it can vary depending on your interactions with us.

Personal information means any information which we hold about you from which you can be identified and which relates to you.  It may include things like your name, contact details etc. Sometimes it may be necessary for us to collect more sensitive information such, as ethnicity or health information (the legal term is special category data). You can learn more about our collection and use of your personal data and special category data by reading the table in Schedule 2.

How we collect your personal information

We collect your personal information directly from you, other people or organisations.

Please see below for more information.

Information you give us

Information you provide when you fill in forms on our website, including where you register on our website for newsletters or other media, or submit a query via our website.

Information you provide to us where you give information about yourself in any communications with us, either by telephone, email, post, social media or otherwise.

Information you give to us when you participate in the research project, for example by signing up to the research panels, interviews, and completing surveys or otherwise.

Information we collect about you

Details of your visits to our websites including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting, browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. For more information please see our Cookies Notice.

Data including your name and images captured on body-worn cameras or CCTV when you visit one of our campuses.

Images of you in photographs when you participate in ncat run events. If you do not wish to be included in any photographs or events, please ensure that you clearly express your wishes to a member of our staff or directly to the third parties.

Information we receive from other sources

We may receive personal data about you from other third parties, including collaborating partners of ncat, please see Schedule 1 for details.

How we use your personal information

We will use your information in a number of different ways — what we do depends on our relationship with you. We use your personal information in a variety of ways for example:

  • Where you express an interest in the ncat and their activities;
  • Where you participate in a research project;
  • Where you sign up to be part of the ncat panel;
  • Where you sign up to receive our newsletters or other material;

We have to have a valid reason to use your personal information. It’s called the “lawful basis for processing”. The table in Schedule 2 will provide you with more information about how we use your personal information and our reasons (lawful basis) for doing so.

In some cases we may rely on legitimate interest as a lawful basis for processing your personal data as outlined in Schedule 2, in such case we will undertake an assessment to ensure that processing is necessary, proportionate and does not affect your rights. Please contact us at enquiry.igu@coventry.ac.uk if you would like further information on where we rely on legitimate interest.

Your choices about the personal information you give us

We may use your personal information to send you marketing by post, by phone, through social media, by email and by text. We can only use your personal information to send you marketing material if we have your permission or where we have a legitimate interest in doing so and we have given you the option to opt-out of receiving such marketing materials. If you don’t want to receive emails or texts messages from us, we’ll provide you with the opportunity to opt-out, and you will be notified of this at the time you receive each communication.

Profiling and automated decision-making

We do not use profiling or automated decision-making to process your personal information.

Who we share your personal information with

We will share your personal information within the Coventry University Group. In addition, it is shared as permitted or required by law, on a considered and confidential basis and with a range of external organisations.

Your personal information may be shared to other organisations outside of Coventry University Group, such as ncat partner organisations as listed in Schedule 1. Please see Schedule 3 for further information about who we share your personal information with.

We may engage third parties to provide processing activities where it is necessary and we have a reason (a lawful basis) to do so. We require that all third parties who process personal data on our behalf to treat it in accordance with applicable data protection laws. We do not allow our third-party service providers to use your personal data for their own purposes, but only to process it for specified purposes, and in accordance with our instructions. Such processing is to be conducted under a formal agreement, which includes provisions around the processing of personal data, and which provides appropriate safeguards.

Sharing your personal information outside of the UK

We will not share your personal data with parties outside of the UK, however if we are required to share the data outside of UK, we shall ensure that:

  • We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the UK Government. Currently the UK Government recognises EU and EEA member states as having adequate levels of protection for personal information, as well as those other countries currently recognised by the European Commission as having such adequate protections; and
  • Where we use certain service providers or partners who are based in countries which are not deemed by the UK Government to have adequate levels of protection for personal information, we may use specific contracts approved by the UK Government which gives personal information the same protection it has within the UK, EU and EEA.

Please contact us at enquiry.igu@coventry.ac.uk if you would like further information about the specific mechanism used by us when sharing your personal information outside of the UK. We keep our mechanisms for transferring personal data outside of the UK and/or the EEA under regular review to ensure that these are in line with UK data protection laws.

How long we keep your personal information?

We only hold your personal information for as long as we do the activities we told you about or have a valid reason to keep it. We consider a number of factors in deciding how long to keep your information:

  • The nature and sensitivity of the information.
  • The potential risk of harm from unauthorised use or disclosure of the information.
  • The purposes for processing the information and how long it will take to achieve those purposes.
  • How long it is reasonable to keep records to show we have met the obligations we have to you and by law.
  • Any time limits for making a legal claim.
  • Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations.
  • Any relevant legal proceedings that apply.
  • 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 data indefinitely without further notice to you.

If you would like more information about how long we keep you information for, please contact the Information Governance Unit via enquiry.igu@coventry.ac.uk.

Keeping your personal information secure

We employ appropriate security measures to prevent information from being accidentally lost, used, or accessed unlawfully, and we are Cyber Essentials, and Cyber Essentials Plus certificated.

We publish an Information Technology Policy that describes the way IT is governed, and we underpin the Policy with additional protective controls and Standards, and work with our supplier and partners to embed security by design.

How we may contact you

Please note that we may contact you by post, email, telephone, text, social media, or any other suitable electronic method in connection with the purposes set out above. We’ll never contact you to ask for your bank details or passwords.

Your rights in relation to your personal information

It is your personal information, so we need to make you aware of your rights and how to exercise them.

Access

The right to be provided with a copy of your personal information (subject access request).

To make a request for your data please complete and return our subject access request form by email to dsar@coventry.ac.uk. Alternatively, you can write to the address below.

Rectification

The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.

Erasure

The right to require us to delete your personal information, in certain situations. Please note 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.

Restriction of processing

The right to require us to restrict processing of your personal information in certain specific circumstances, e.g. if you contest the accuracy of your personal information.

To object

The right to object:
— at any time to your personal information being processed for direct marketing (including profiling);
— in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests. In some cases, we may demonstrate that we have a compelling reason to continue to process your personal information, despite any objection, as is necessary for our public interest tasks, the exercise of an official authority vested in us, or for our legitimate interests or those of a third party which override your rights and freedoms.

Data portability

In certain situations, the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to another organisation.

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not currently use tools which involve automated decision making.

Withdraw consent

Where we rely on consent to process your personal information, you may withdraw that consent at any time. You will be provided with information on how to withdraw consent at the time it is collected from you.

Right to complain

If you are concerned about the way we have processed your personal information, you can complain to the Information Commissioner’s Office (ICO). Please visit the ICO’s website www.ico.org.uk for further details, or you can use their online tool for reporting concerns: https://ico.org.uk/concerns/.

If you wish to exercise any of your rights or would like any further information, please send a written request to the Information Governance Unit, Coventry University, Portal House, 163 New Union Street, Coventry, CV1 2PL or email dsar@coventry.ac.uk.

 

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website.

Schedule 1

This privacy notice applies to the processing of your personal information by:

Coventry University
Priory Street, Coventry, United Kingdom, CV1 5FB

ICO Registration Number: Z6939585

When your personal information might be processed:
Coventry University is responsible for managing the National Centre for Accessible Transport (“ncat”) which is part of the innovative research launched together with Motability, the Charity. The personal data will be processed by the University, where you participate in activities, events or research run by the University, ncat and its partners.

Coventry University Enterprises Limited
Priory Street, Coventry, United Kingdom, CV1 5FB

ICO Registration Number: Z5451039

When your personal information might be processed:
In relation to internal support services provided to Coventry University and ncat.

Motability
Warwick House, Roydon Road, Harlow, Essex CM19 5PX

ICO Registration Number: Z8393245

When your personal information might be processed:
Where you provided your information directly to Motability as part of participating in their processing activites. Including, where you agree to Motability sharing your data with other parties for specified purposes such as research activities , including participating in ncat activities.

The Research Institute for Disabled Consumers (RIDC)
Impact Hub King’s Cross
34b York Way
London N1 9AB
(currently registered under Research Institute for Consumer Affairs
10 Blenheim Court, 62 Brewery Road, London, N7 9NY)

ICO Registration Number: Z9930819

When your personal information might be processed:
Where you provided personal data directly to RIDC as part of participation in RIDC run events and agreed to its processing activites. Including, where you agree for your information to be shared with third parties for specified purposes such as research activities or where your information was collected by RIDC on behalf of the University and ncat, including joining research panels, events, surveys or providing any other information.

Designability
Designability Charity Ltd, Wolfson Centre, Department D1, Royal United Hospital, BATH, BA1 3NG

ICO Registration Number: Z6810677

When your personal information might be processed:
Where you provided your personal data to Designability as part of its roles for supporting ncat and its activities, events and research.

Policy Connect
32-36 Loman Street, London, SE1 0EH

ICO Registration Number: ZA247748

When your personal information might be processed:
Where you provided your personal data to Policy Connect as part of its roles for supporting NCAT and its activities, events and research.

Connected Places Catapult Services Limited
170 Midsummer Boulevard, Milton Keynes, MK9 1BP

ICO Registration Number: ZA773399

When your personal information might be processed:
Where you provided your personal data to Connected Places Catapult Services Limited as part of its roles for supporting ncat and its activities, events and research.

WSP UK Ltd
70 Chancery Lane, London, WC2A 1AF

ICO Registration Number: Z9060340

When your personal information might be processed:
Where you provided your personal data to WSP UK Ltd as part of its roles for supporting ncat and its activities, events and research.

Schedule 2

The table below provides further details about the information we collect about you.

Identification Data

Description (type of data this includes)

  • Full Name
  • Home Address (Mailing address)
  • Email Address (personal)
  • Name of the organisation
  • IP Address

Why we process this information

  • To provide you with the information about NCAT activities, projects and otherwise.
  • To communicate with you and respond to your queries
  • Where you agreed to participate in the research project, please refer to the Participant information Sheet for the details.
  • To promote Coventry University, NCAT or Motability by using photographic images on our website and in other promotional materials.
  • Attending a specific event organized and managed by the University or NCAT.
  • If you’re a partner institution, agent, research collaborator, volunteer or any other third party working with us
  • Where you are a Guest, or you have been invited to speak at a NCAT events, that will be delivered and/or recorded via the Microsoft Teams or Zoom video conferencing platform.

Lawful basis (legal justification)

  • Consent or Legitimate interests
  • Consent or Legitimate interests
  • Public Task
  • Legitimate interests or consent
  • Legitimate interest
  • Contract or public task or legitimate interests
  • Contract or public task or legitimate interests

Special Category of Data Equality and Diversity Data

Description (type of data this includes)

  • Racial or Ethnic Origin Data
  • Health Data Including, but not limited to disabilities data.

Why we process this information

  • For the purpose of the research project to understand and develop solution for poor public transport for disabled individuals, please refer to the relevant Participant information sheet.

Lawful basis (legal justification)

  • Public Task

Image Data and Monitoring Data

Description (type of data this includes)

  • Photographs and videos, together with sound recordings.
  • Images and videos from CCTV and body cameras.
  • Images, videos, podcasts and others.
  • CCTV and bodycam data

Why we process this information

  • To support the marketing and the promotion of Coventry University, Motability, NCAT or one of our partners by using photographic images on our website and in other promotional material
  • For prevention and detection crime and where you attend the campus, to ensure health and safety of our staff, students and visitors to any of our campuses, for example, by processing CCTV images or body camera footage. Signs are in place to indicate where cameras are in use.

Lawful basis (legal justification)

  • Legitimate interests or Consent
  • Legal Obligation and Legitimate interests

Mobility Data

Description (type of data this includes)

  • Personal information such as registration for events organized by University or NCAT.

Why we process this information

  • To organize events and other engagement activities as may be necessary for the research project and as part of NCAT activities.

Lawful basis (legal justification)

  • Legitimate interest

Testimonial and Survey Data

Description (type of data this includes)

  • Information given where you choose to participate in a survey or give a testimonial.

Why we process this information

  • To promote and market NCAT, Motablity Coventry University or one of our partners.

Lawful basis (legal justification)

  • Legitimate interests or consent

Reporting Data

Description (type of data this includes)

  • Internal and external audits

Why we process this information

  • Providing disclosures of personal information to support internal and external audits for the purpose of Research funding audits.

Lawful basis (legal justification)

  • Contract and Legal obligation

Schedule 3

Who we share your information with

Where you sign up to receive information in relation to ncat activities, the personal data will only be used to provide you with the requested information about ncat.

We may share your information with our partners that form part of or join ncat and where we have an agreement in place for the information to be shared.

Where you take part in The Research Institute for Disabled Consumers (RiDC) activities and agree for your information to be processed for similar activities, your information will be shared with RiDC.