Data Protection, Privacy and IT Security Notice
Date: 25th May 2018
Our NETpositive Software forms the basis of a range of Tools that are offered free at the point of use by Tool Providers (in this case YPO) for their stakeholders (End Users). We take privacy concerns very seriously and are committed to protecting the data End Users share with us as they interact with our Tools.
This statement explains the Data Protection, Privacy and IT Security practices which apply to the NETpositive Software we operate; references to "we" or "us" are NETpositive Futures Ltd.
For the purposes of academic research, and software development, data will also be securely transferred to our project partners, the Stockholm Environment Institute (http://www.sei.org) who will treat this data in strict accordance with the terms of this privacy notice, UK Data Protection Legislation and the General Data Protection Regulation.
Our aim is to safeguard End Users' privacy whilst providing a personalised and valuable service to the Tool Providers (e.g. Universities, Purchasing Consortia, Industry Groups, and Industry Clients) who have offered them for free to their stakeholders.
We want to be transparent about what happens to information provided to us and so here we explain how we collect information, what we do with it and what controls users have.
Your acceptance of this Policy
By using our Tool, you consent to the collection and use of information by us in accordance with our Privacy Notice. If you do not agree to this Notice, please do not use our Tool. After the 25th May 2018, we will be asking users to tick a box on registration (or for existing users, first login after this date) to explicitly consent to this Notice.
If, at any time, you wish to know what information we hold about you, or your company, or wish to remove or modify the data we hold about you, please contact our data controller, Sandra Pickering at: firstname.lastname@example.org.
If you believe at any time that we are in breach of any data protection laws or good practice, please contact us, which in no way affects your right to also raise your concerns with a supervisory authority.
What information do we collect?
We collect the information on the basis of informed consent, that you provided either at the time of registration, or for existing users – from 25th May 2018 – at your first log-in after this date. We collect two kinds of information about our users that is necessary to achieve the ambition of the NETpositive Software – that of promoting sustainable development in business supply chains:
a. Personal Information which includes:
i. the IP address of the computer used to access the Tool (the location of the computer on the internet), pages accessed, and files downloaded, analysed using Google Analytics. This helps us to determine the number of individuals using the Software, how many people visit on a regular basis, which pages are most popular, and which pages are least popular. This information doesn't tell us anything about who users are or where they live, it simply allows us to monitor and improve our service.
ii. your freely-provided email address, as supplied by you at registration, which acts to identify the account you hold on our system and will be used to provide you with updates about the NETpositive Tool and its content, in order for us to stimulate the regular use of the Tool. Your email may be shared with the Tool provider.
b. Organisational information provided freely by the Tool user and through interactions with Tool content such as the business name, business email address, business/user type and other demographics, including:
- selection, ranking and status of Issues and Actions;
- user-submitted content related to customised Issues and Actions;
The information is needed to provide users with their customised Action Plan and also enables us to conduct research on to the social value provided by businesses and suppliers. This both supports the provision of the Tool (by providing stakeholder information to the Tool provider) and also enables us to improve our Tool content in future. We do not conduct profiling or automated decision making on the basis of supplied data.
The Tool is hosted on Heroku servers which are located in Ireland, and any personal information collected by the Tool (as identified above) is stored on these servers. Additional services offered by Heroku in conjunction with the hosting of data (such as backups) may be transferred to other locations, such as the US. The end user’s IP address is also stored on Heroku servers for 7 days. Heroku is owned by SalesForce, and you can read about their data processing compliance status with respect to the GDPR here: https://www.salesforce.com/gdpr/overview/
We take back-ups of the data hosted on these servers, which is also forwarded to our research and software development partner, the Stockholm Environment Institute. All back-ups are securely stored on password protected and encrypted machines.
How is the information used?
We may disclose aggregate statistics about our site visitors, in order to describe our services to prospective partners, and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
We may disclose personal information if we receive a complaint about any content you have posted or transmitted to the Tool if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the project partners, and the Tool.
We reserve the right to use aggregate, anonymised, data from the Tool, which may be used by us in project reports, promotional/marketing material, and other forms of dissemination.
Aside from provision of data to Tool Providers, as described above, no information containing personally identifying information will be sold or otherwise disclosed to external parties.
Retention Period for Data
Any data you provide will be retained by us for a period of 8 years following the date of your last log-in. This allows us to fulfil our role of providing longitudinal analysis of the activities of businesses in delivering sustainable development and social value. After this period, your data will be removed from our databases.
Our sites contain links to other sites. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our websites and recommend that you check the policy of each site you visit.
In addition, if you linked to our Tool from a third-party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third-party site and contact its owner or operator if you have any concerns or questions.
We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal data under our control. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information.
Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Most web browsers automatically accept cookies, but if you prefer, you should be able to change your browser to prevent that. You should read the information that came with your browser software to see how you can set up your browser to notify you when you receive a cookie, this should then give you the opportunity to decide whether to accept it. However, you may not be able to take full advantage of the Tool if you do so. Cookies are specific to the server that created them and cannot be accessed by other servers, which means they cannot be used to track your movements around the web.
Further information about cookies can be found at the Interactive Advertising Bureau's website www.allaboutcookies.org.
The following cookies are used to ensure the functioning of the Tool:
From Google analytics:
__utma – (2-year expiry) This cookie keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred.
__utmb – (refreshed on each page load) and __utmc – (expires end of session). Working together to calculate how long a visit takes.
__utmz – (6 months expiry) Keeps track of where the visitor came from.
see http://www.morevisibility.com/analyticsblog/from-__utma-to-__utmz-google-analytics-cookies.html for more info.
csrftoken – (1 year expiry) Refreshed for each form. Used to combat Cross Site Request Forgery - i.e. submitting bogus form data.
sessionid – (2 weeks expiry) This maintains the user's login.
Where is the information stored?
Information which you submit via our Tool is sent to servers hosted by Heroku https://www.heroku.com/policy/tos located in Ireland. This is necessary in order to process the information and to provide you with access to additional resources provided through the Tool.
Information submitted by you may be communicated in anonymous aggregated form by us to the offices of our partner, the Stockholm Environment Institute and to other reputable third-party organisations as referred to in this Policy, and these may be situated outside the European Economic Area.
Any personal information submitted via our websites or by text is treated in accordance with the Data Protection Act 1998 and the GDPR. To find out more about your entitlements under this legislation, visit: https://www.gov.uk/data-protection and https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
If you would like to review or revise information you have previously provided to us online, you may do so by emailing email@example.com
NETpositive Futures Ltd
31 Ings Lane
Last updated: 25th May 2018