Data Protection, Privacy and IT Security Statement
Our NETpositive Software forms the basis of a range of Tools that are offered free at the point of use by Tool Providers 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 to the NETpositive project partners: NETpositive Futures Ltd and the Stockholm Environment Institute.
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 you provide to us and so here we explain how we collect information, what we do with it and what controls you have.
What information do we collect?
We collect two kinds of information about our users:
a. non-personal information such as IP address (the location of the computer on the internet), pages accessed and files downloaded using Google Analytics. This helps us to determine the number of individuals using the Tool, 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 you are or where you live, it simply allows us to monitor and improve our service.
b. personal and organisational information provided freely by the tool user such as the individual or business name, email address, business/user type and other demographics, and through interactions with tool content including:
- selection, ranking and status of Issues and Actions;
- user-submitted content related to personalised Issues and Actions;
The information is needed to provide you with your personalised Action Plan and also enables us to conduct research. 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.
The tool is hosted on Heroku servers (https://www.heroku.com/policy/tos) which are located in Ireland. Your IP address is also stored on their servers for 7 days.
How is the information used?
Any personal data End Users provide will be used and recorded by us in accordance with current data protection legislation and this Privacy Policy. We use information provided by End Users to:
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.
Links
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.
Security
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. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information.
Use of cookies
In simple terms a cookie is a small piece of information sent from our website to your computer to help us to identify you quickly. Any information gathered by the use of cookies is compiled on an aggregate, anonymous basis.
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.
From django:
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.
From persona:
browserid_state and can_set_cookies. Set by persona. Expiry depends on what the user selected when they logged in.
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.
We will periodically download user responses from the Tool for analysis and research purposes. These will be stored securely in accordance with the project partners Privacy Policies. Periodically data will be passed to Tool Providers to allow them to undertake research and help us improve the tool.
Information submitted by you may be communicated in anonymous aggregated form by us to our other offices and to other reputable third party organisations as referred to in this Policy, and these may be situated outside the European Economic Area.
Changes
We may make changes to this Policy from time to time. If we change our Privacy Policy we will post the changes on this page. If the change in our Privacy Policy affects the use of your personal information we will use our best endeavours to contact you by email to seek your consent to the use.
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 Policy. If you do not agree to this Policy, please do not use our Tool.
Your rights
Any personal information submitted via our websites or by text is treated in accordance with the Data Protection Act 1998. To find out more about your entitlements under this legislation, visit the Information Commissioner's website: www.dataprotection.gov.uk or read the Act online at: www.hmso.gov.uk/acts/acts1998/19980029.htm .
If you would like to review or revise information you have previously provided to us online, you may do so by emailing info@net-positive.org
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you or if you have any questions relating to this Privacy Policy or how we use the personal information we have about you, please write to:
Stockholm Environment Institute
Environment Building
Wentworth Way
University of York
York
YO10 5NG, UK
Last updated: February 2016