This Privacy Policy sets out how Partnership for Observation of the Global Ocean (POGO) uses and protects any information that you give to us when you use any of our websites and during the course of business with us, and is effective from 25 May 2018, when the new General Data Protection Regulation (GDPR) came into force . Any information you provide, or which we request in order to fulfil legal requirements, will only be used in accordance with this Privacy Policy. POGO may change this Privacy Policy from time to time by updating this page; any updates to this page take effect immediately. You should therefore check this page periodically for any updates.

Who we are

Partnership for Observation of the Global Ocean is a charitable incorporated organisation registered and regulated by the Charity Commission of England and Wales, No 1171692. Throughout this privacy notice, “we” and “us” means POGO and its brands. Throughout this notice, “our websites” or “our sites” refer to any websites maintained and updated by the POGO Secretariat. These include, but are not limited to: http://pogo-ocean.org , http://www.oceantrainingpartnership.org, http://nf-pogo-alumni.org/, and https://oceanscape.org.

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 on 8 Sept 2022, and Historic versions can be obtained by contacting us].

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.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Communications Officer, who has responsibility for data protection within POGO, in the following ways:

Full name of legal entity: Partnership for Observation of the Global Ocean (POGO)
Email address: pogodmin@pml.ac.uk
Postal address: Plymouth Marine Laboratory, Prospect Place, Plymouth PL1 3DH
Telephone number: +44 (0)1752 633 424

Automatic collection of information

Certain information is collected automatically. This includes but may not be limited to:

the Internet domain or IP address from which you access our websites
the type of browser and operating system used to access our sites
the date and time you access our sites
the pages you visit

This information is used to ensure that content on our site is presented in the most effective manner for you.

Lawful Reasons for Processing

When we collect your personal data. we will make it clear to you which data is necessary in connection with a particular service. The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent, e.g. when you subscribe to our newsletter, apply for training, or make an enquiry.

Contract

In certain circumstances we need your personal data to comply with our contractual obligations, e.g. if you are a project partner, grant recipient, member or supplier, we need this data to make payments to you.

Legal Compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity to law enforcement.

Legitimate Interests

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, where you have provided us with your business card, we may use your address details to send you information on our activities.

Collection of Personal Data

We may collect data in the following circumstances, when you:

Visit any of our websites
Receive a travel grant or other type of funding from us
Attend a meeting with us, or register for or attend an event we organise
Engage with us during the course of business – in person, by mail, by e-mail, by telephone, and by providing us with your business card
Engage with us on social media
Contact us by any means with queries, feedback, requests for information, complaints, etc.
Fill in forms or applications, e.g. through our websites
Complete any surveys we send you
Download data and information from our websites
Give any third party permission to share personal data they hold about you with us

We may also collect data from publicly available sources, where the information is made public as a matter of law, or when you have given your consent to share information. For example, before we enter into a contract or partnership with you we may need to carry out appropriate due diligence checks.

Examples of Personal Data we collect

We may collect both identifiable and anonymous information, depending on our relationship with you.

Identifiable Information

If you subscribe to our newsletter we will collect your name and e-mail address.
If you fill out and submit an enquiry/feedback form on our websites, we will collect your name, e-mail address and message to respond to your query.
If you interact with us via social media we will use your contact details to help us respond to your comments, questions or feedback.
If we are involved in a project, or pre-project discussions, we may collect notes from our conversations and any correspondence between us.
If we are arranging travel for you as a grant recipient, we may require details such as your full name, address, date of birth, your passport details, driving licence details, etc., which may be passed to third parties, e.g. travel agents, for processing purposes.
As a candidate for a vacancy (employment or studentship) we will ask you to provide certain personal information. The information you supply is collected solely to allow us to process and respond to your application for a vacancy.

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, or we need to pass this information on to a third party to be able to provide a specific service for 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 arrange a booking or provide some other services for you). In this case, we may have to cancel the contract you have with us or provision of the service for you, but we will notify you if this is the case at the time.

How and Why We Use Your Personal Data

We may use your personal data for the following purposes:

To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us
To respond to your enquiry to us or contact with us. We may also retain a record of your enquiry and our response to inform any future communication with you/us. We may do this on the basis of contractual obligations to you, our legal obligations, or our legitimate interests in providing you with the best service, and understanding how we can improve our service.
To protect both you and our business from fraud and other illegal activities. This may include using your personal data to maintain, update and safeguard the information we hold about you. We will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We will do all of this as part of our legitimate interest.
To comply with our contractual or legal obligations to share data with law enforcement.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy, or legally required information.

How we protect your personal data

We are committed to ensuring that your personal data is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect.

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.

How long will we keep your personal data?

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected unless we need to keep it longer to comply with our legal obligations. At the end of that period your data will either be deleted completely or anonymised e.g. by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Personal data will be held for a specific period of time in such circumstances as those listed below:

application forms from unsuccessful applicants will be deleted within 1 month after the training/event has taken place.
copies of passports, invitation letters and e-mails containing passport details must be deleted as soon as possible and will be deleted no longer than 1 year after the travel has taken place.
during the process of evaluating the applications, generally spreadsheets are created that transpose some, but not all, of the information from the application forms. This information is held for a period of up to 3 years after the application deadline.

More details on the specific periods of time each type of data is held can be found in our Data Protection Policy.

With whom do we share your personal data?

We may share your personal data with any member of our group, which means our subsidiaries, as defined in section 1159 of, and Schedule 6 to, the Companies Act 2006(3) with the substitution, in relation to CIOs, of references to charity trustees for references to directors. The information you supply is collected solely to allow us to respond your enquiry, or request, or to conduct our business. We will not sell, license or trade your personal information to any third party. We would only share your personal information where required by law or to respond to a legal process, or where necessary in order to undertake our business, e.g. selected third parties who we use to provide services, such as travel agents, banks, couriers, etc. In all cases, we ensure that third party companies only receive the minimum information necessary, and ensure that:

Your data is only used for the exact purposes specified in our contract with them.
Your privacy is always maintained.
Your personal data is kept securely.
Any data held by them will either be deleted or rendered anonymous when we stop using their services.
Your data is always processed legally under the terms of the GDPR.

More information on the specific third parties we may share your data with can be found in our Data Protection Policy.

Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA). If you are based outside the UK, where necessary, we will transfer the personal data that we collect from you to the UK. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.

VISITORS TO OUR WEBSITE

Cookies are small text files that are placed on your computer when you visit a website. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

POGO and its websites use cookies. If you are concerned about security, you can modify your browser to prevent cookies being stored on your machine. For more information about the cookies we use, please see http://pogo-ocean.org/Legal.

Such data may be processed for the purposes of analyzing the use of the website. The legal basis for this is our legitimate interests in monitoring and improving our website and services.

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.

What are your rights over your personal data?

You have the right to request:

Access to the personal data we hold about you.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent based processing of your personal data after you withdraw that consent.
Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that we hold at any time and also to have that information corrected if it is inaccurate. To ask for a copy of your information or to ask for your information to be updated, please write to us, or contact us by email at pogoadmin@pml.ac.uk. If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

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 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

How can you stop us contacting you?

Click the “unsubscribe” link in any e-mail communication that we send you.
Reply to any direct email and request that you are not contacted.
Email us at pogoadmin@pml.ac.uk
Write to us at: POGO Secretariat, Plymouth Marine Laboratory, Prospect Place, The Hoe, Plymouth, PL1 3DH, UK

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. You may also still receive communication from us if we are required to contact you for contractual or legal purposes.

Complaints

If you wish to complain about how POGO has handled your personal data then in the first instance you can make a complaint to the Chief Executive Officer via pogoadmin@pml.ac.uk. If we are unable to satisfy your concerns, then under the General Data Protection Regulation you have a right to complain to the Information Commissioner’s Office at: Information Governance Department Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF UK URL: https://ico.org.uk/

Links to other sites

We may from time to time establish relationships with other companies that will enable you to access the websites of such companies directly from our site. Each individual company operates its own policy regarding the use of personal data. If you have a particular interest or concern regarding the way your data will be used then you are advised to read the Privacy Notice on the relevant site. We will try to provide you with links to high quality, reputable sites which we believe will be of interest and relevant to you, but please note that such third party sites are not under our control and we do not contribute to the content of such websites. When you click through to these sites you leave the area controlled by us. We cannot accept responsibility for any issues arising in connection with either the third party’s use of your data, the site content or the services offered to you by these sites.

Privacy policy