B5e: Privacy Notice 2018

This privacy notice tells you how we, Outreach Rescue Medic Skills (‘ORMS’) Ltd, will collect and use your personal data to provide education services which allows you as a student to create a private space online, using courses and activities, all optimised for collaborative learning.

We use Moodle software, which is free and open source, and which is hosted by ICDSoft who host the servers where the databases are located. Your data is hosted in the European Union.

ORMS has a Data Protection Officer and you can contact them if you have queries:

Contact details of the Data Protection Officer

Data Protection Officer / GDPR Owner contact details
Contact Name: Outreach GDPR Officer
Address line 1: The Outreach Organisation Ltd
Address line 2: Tan-y-Bwlch Centre
Address line 3: Llanllechid
Bangor
Address line 4: Gwynedd LL57 3HY

Wales (UK)

Email: gdpr.officer@orms247.co.uk

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Why does ORMS Ltd need to collect and store personal data?

In order for us to provide you with educational services through the Moodle/iLearn environment we need to collect personal data for correspondence purposes and/or to allow us to provide you our service. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose. ORMS Ltd. is a company which values its user’s data protection and privacy rights and we have no interest in collecting data beyond what we need to make the information work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.

Will ORMS Ltd share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to ORMS Ltd in the course of dealing with you. We do this because there are some services, such as a video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with ORMS Ltd’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact gdpr.officer@orms247.co.uk and we will be happy to provide it.

How will ORMS Ltd use the personal data it collects about me?

ORMS Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. ORMS Ltd maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. ORMS Ltd is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Can I find out the personal data that the organisation holds about me?

ORMS Ltd at your request, can confirm what information we hold about you and how it is processed. If ORMS Ltd does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of our data protection officer in the EU, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of ORMS Ltd or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

ORMS Ltd accepts the following forms of ID when information on your personal data is requested:

  • A colour copy of a Passport, driving licence or National ID Card

Data Policy

  1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

  1. Responsibilities

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

    • 2.1 Where ORMS Ltd is hosting a website on its own behalf, it is the Data Controller for all the data collected. Where ORMS Ltd is hosting someone else’s installation of the Moodle Platform (as with ORMS Ltd) it is the Data Processor for the Site Admin for that installation.
    • 2.2 When ORMS Ltd is not hosting an installation of the Software Platform, it is neither the Data Controller or the Data Processor and those duties fall on the people or organisations who have installed and are hosting those installations.

Privacy notice

3.1 Who are we?

ORMS Ltd is a training company which allows educators to create a private space online, filled with courses and activities, all optimised for collaborative learning. We use Moodle software (which we refer to as ‘iLearn’ or ‘iLearn/Moodle’) is open source

We collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with ORMS Ltd. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 at the end of this document.

Our legal basis for processing for personal data:

  • Article 6.1(a), GDPR, Consent
  • Article 6.1(b), GDPR, Contract
  • Article 6.1(f), GDPR, Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Recruitment and Induction of new Candidates
  • Emergency Contacts for people who work with us, such as employees and Contractors for Health and Safety purposes.
  • Business Development
  • Providing login systems to users via their accounts

The special categories of personal data concerned are:

  • Biometric Data in the form of facial images
  • Any special categories of special personal data which any user volunteers while using the Moodle systems or any Moodle website- for example in a forum or submission

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for ORMS Ltd to process both standard and sensitive types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw consent at any time by:

Please identify your role in relation to ORMS Ltd (if you are a Contractor, Staff member, iLearn/Moodle Partner, End-user, Site Admin etc.), and the data you wish to withdraw consent to be processed. Please include a copy of a state-issued Photo ID, to confirm that you are the person whose data is removed.

3.3 Disclosure

ORMS Ltd will pass on your personal data to certain third parties.

  • Data storage is through ICDSoft who host the servers where the databases are located. Your data is hosted in the European Union.
  • ICDSoft’s Privacy statement can be found here: https://www.icdsoft.com/en/privacy
  • Your personal details will be created into a spreadsheet which is turned into a ‘CSV’ file for uploading into Moodle. A snapshot of Moodle to include individual course archives and a copy of the master MySQL database will be taken on or around 1st May annually and retained for 6 academic years. These files are stored in a Dropbox directory.
  • Dropbox’s Privacy statement can be found here: https://www.dropbox.com/privacy
  • Portfolio services are provided through a linked portfolio platform using the Mahara application. This is accessed through a ‘Single Sign On’ (SSO) protocol used to link Moodle and Mahara together.
  • Mahara has a detailed set of privacy statements here: http://manual.mahara.org/en/18.04/faq/privacy.htm
  • Turnitin is a plagiarism prevention service that allows tutors at ORMS to check student papers and written assignments for originality against Internet sources, other student submissions, and academic databases at the same time as students are electronically submitting them. Turnitin provides tutors and students with an “Originality Report,” which is a color-coded report matching student writing with matching sources that used identical strings of words.
    • The Turnitin service involves data transfer to the United States, by accepting this policy, you consent to that transfer.
    • In meeting the requirements of Directive 95/46/EC to meet data protection requirements, organisations are free to inspect or audit Turnitin’s services any time;
    • All student work and any associated personal information is encrypted and kept secure at all times.
    • Students can keep their identity secret by using a pseudonym and by submitting papers in formats that contain little if any identifying metadata.
  • Turnitin has a detailed set of privacy statements here: https://go.turnitin.com/turnitin-and-gdpr and https://guides.turnitin.com/Privacy_and_Security
  • ORMS may disclose student’s personal data and sensitive personal data/special category data to external agencies to which it has obligations; for example for council tax, electoral registration, and visa and immigration purposes, and to other arms of central or local government, to the Robert Gordon University, to the Higher Education Funding Council for England, Higher Education Statistics Agency, Student Loans Company, Office of the Independent Adjudicator for Higher Education, Research Councils, and potentially other such organisations for defined purposes.  It may also disclose information to examining bodies, external examiners, legal representatives, Police or security agencies, suppliers or service providers, survey and research organisations engaged by ORMS, and regulatory authorities such as HCPC.
  • If students have unpaid debts to ORMS at the end of their course ORMS may, at its discretion, pass this information to debt collecting agencies in order to pursue the debt.

ORMS Ltd will not transfer, disclose, sell, distribute or lease your personal information to any other third parties unless we have your permission or are required to do so by law. This process may involve sending personal information to other countries, whose data protection laws may not be as extensive as in the EU. However, we have carried out appropriate steps to ensure the same level of protection for the processing carried out in these countries as within the EU.

3.4 Retention period

ORMS Ltd will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, considering legal and service requirements. For further details on the retention period for any particular type of data, please see our B5a Data Retention Policy [link]

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that ORMS Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

Where ORMS Ltd is your Data Controller, you may make a request directly to the Data Protection Officer using the email address gdpr.officer@orms247.co.uk

Where ORMS Ltd is a Data Processor, and act on behalf of a data controller any requests received by ORMS Ltd will be passed on to the Data Controller.

Where ORMS Ltd are not involved with your data, such as where the Moodle platform has been self-hosted, you should address your requests to the data controllers of those sites. ORMS Ltd will have no access to your data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by ORMS Ltd (or third parties as described in 3.3 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and ORMS Ltd’s Data Protection Officer, Technical Footprint Ltd.

If you wish to make a complaint about how your personal data has been processed by ORMS Ltd., you should contact your Moodle Site Admin or the Data Controller for your Moodle installation. (For example, if your university or school hosts their own Moodle site, they will be the Data Controller).

 

 

The details of Contacts for where ORMS Ltd are the Data Controller:

Supervisory authority contact details Data Protection Officer (DPO) / GDPR Owner contact details
Contact Name: Information Commissioner’s Office Outreach GDPR Officer
Address line 1: 2nd floor The Outreach Organisation Ltd
Address line 2: Churchill House, Churchill way Tan-y-Bwlch Centre
Address line 3: Cardiff Llanllechid
Bangor
Address line 4: CF10 2HH Gwynedd LL57 3HY

Wales (UK)

Email: wales@ico.org.uk gdpr.officer@orms247.co.uk
Telephone: +44 29 2067 8400 +44 1248 601546

For the details of Contacts for where ORMS Ltd are not the Data Controller, look in your installation of Moodle to identify your Data Controller.

Annex 1

Purpose of processing Categories of personal data The source of the personal data
sending e newsletters to ilearn.orms247.co.uk users email address, name Data subject
Presentation admission process run by admissions / marketing department for ORMS events email address, name, workplace, summary of applicable presentations Data subject
Communicating marketing campaigns on Facebook name, email address, location, job title, interests, any other Facebook categories used Data subject
Communicating marketing campaigns on Twitter name, email address, location, interests Data subject
Recruitment Name, Address, phone number, email, social media profile links, Photograph, educational and work history, interests Candidate
Recruitment Contact details Candidate
On-boarding Contact details, emergency contact details, drivers licence, passport, id documents, banking details, tax details, superannuation details, gender, qualifications, biometric data, date of birth Employees
Health and Safety Name, phone number, email, relationship with Employee Employees
HR Records Health Records Employees
On-boarding Contact details, emergency contact details, drivers licence, passport, ID documents, banking details, gender, qualifications, biometric data Employees
On-boarding Telephone number Team Members
Performance Performance information contact details Managers/HR
Engagement Contact details, job information, engagement information Employees/HR
Letter of Offer Name, address, phone number, email and remuneration details Employees/HR
Confirmation of Information Contact details, remuneration details, length of service, job information Employees, HR
Exit interviews Contact details, feelings about working at ORMS Employees
On-boarding Photograph Employees
Interview Answers to questions around previous job and skills Moodle HR
Central code repository contact details (name, surname, email, photo), activity and contribution Data subject
Community education and feedback ORMS Ltd. contact details (name, surname, email, photo), activity and contribution Data subject
Mirror of central code repository contact details (name, surname, email, photo), activity and contribution Data subject
Conduct user studies, interviews, and surveys Contact details, activity, contribution Employee
Community engagement & recruitment for user studies Contact details, activity, contribution Data Subject, Employees
Paying wages to employees Contact details (name, surname and email), Bank details, Tax details, sick leave, Annual Leave, salary, pension Employee
Collecting fees payable by direct clients Contact details (name, surname and email) Client
Collecting fees payable by partners Contact details (name of partner, email, name and surname of partner representative) Partner
Receiving event registration fee Contact details (name, surname, email of the participant, phone number, business name and address) Attendee
Paying supplier invoices Supplier details (name, surname, email, bank details) Attendee, supplier
Individual’s Profile on iLearn site Contact details Data subject and data subject employer
Individual’s data on iLearn website User and activity data Data subject, Controller
Lead / Customer Information Contact Details Data Subject
Writing and storage of agreements/contracts/documentation with partners, and potential partners Contact details ORMS Partner / Applicant
General Business Documentation of meetings including attendees Partner Organisation details, Partner details, Partner Employees Controller
General Business Documentation Partner Organisation details, Partner details Controller
General Business Documentation Partner Organisation details, Partner details Controller
Log storing and searching for analysing and troubleshooting iLearn sites and signup/provisioning Location, IP address ORMS Ltd site admins and ORMS Ltd site users
Storing of historical logs – Moodle, web server, statistics website name, location, IP address ORMS Ltd site admins and ORMS Ltd site users
Facilitating the signup and control of the ORMS Ltd account Name, email, location, telephone number ORMS Ltd site admins
Primary provider for text messaging. Logs for text message sending Phone numbers ORMS Ltd site admins
Email processing (Moodle and signup) email ORMS Ltd site admins and ORMS Ltd site users
Backup text messaging service. Phone numbers ORMS Ltd site admins
News, Updates, Product tip emails subscriber lists (opt in) Name, email ORMS Ltd site admins
Email sent to site admins regarding their ORMS Ltd service Name, email, financial data ORMS Ltd site admins
Operational reporting on cloud servers and Moodle sites Location, IP address, Moodle activity data ORMS Ltd site admin
Recurring subscriptions and Payment name, email, country ORMS Ltd site admins
Billing engine and subscription management contact details, country, website name ORMS Ltd site users
Assignment submission document converter (when students submit assignments in various file formats, this process converts them into PDF file, so the teacher can grade and annotate the document) could be any data submitted in the file ORMS Ltd site users
Web conferencing feature for all ORMS Ltd sites contact details, voice, audio, video, biometrics, IP address, location data ORMS Ltd site users
Authentication, Design, development and tracking of Moodle code, profile published on Tracker site, notifications Contact details, biometric (avatar) Data subject
Authentication, profile published, notifications Contact details, biometric (avatar), any details provided by user Data subject
Authentication, notifications Contact details, biometric (avatar) Data subject
Statistics and error recording IP Address, error logged messages potentially including usernames, and usage records Website records
Business Development statistics generation Data compiled from other listed data sources Website records
Making and receiving phone calls Call metadata including phone numbers and time & call duration telephone records
Making and receiving phone calls Call metadata telephone records
Authentication, documents, usage, emails Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records Data Subjects, ORMS Ltd
Communication in and outside of company Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records Data Subjects, ORMS Ltd
Communication in and outside of company Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records Data Subjects, ORMS Ltd
Internal HR functions leave and communications HQ personal staff information leave information, communications details Data Subjects, ORMS Ltd
Partner billing, record keeping and communications HQ authentication information contact details, ORMS partner contact details, client statistics & invoicing Data Subjects, ORMS Ltd
Purchasing various services (domains, etc) Profile data and credit card for ORMS Ltd Staff or Contractor Data Subjects, ORMS Ltd
Licenses for software Personal contact information, cloud stored work may have personal data in it Data Subjects, ORMS Ltd
Notifications of critical ICT events ORMS Ltd person information, possible data in alert if relevant to alerting Data Subjects, ORMS Ltd
Authentication, subscribed marketing & security notifications, bounce records, read and open records, link click records Personal contact information (Name & Email) Data Subjects, ORMS Ltd
Billing & Purchasing Billing information including name, addresses, order information Data Subjects, ORMS Ltd
Authentication, document management & office license Contact Details, IP addresses Data Subjects, ORMS Ltd
Hosting corporate infrastructure HQ Person information, all data covered by other register entries. Data Subjects, ORMS Ltd
Legacy ticketing system Contact details, biometric (avatar), any details provided by user Data Subjects, ORMS Ltd
Ticketing System / Public Comms Hub Contact details, biometric (avatar), any details provided by user Data Subjects, ORMS Ltd
CRM for Services team Contact details, contract details with partners, any other information related to partnership with ORMS Ltd Data Subjects, ORMS Ltd
Monitoring No personal data, just system level metrics Data Subjects, ORMS Ltd
Authentication, Database/API query derived statistics Contact details Data Subjects, ORMS Ltd
Credential and secure information store Username and passwords for cloud services, may contain other notes Data Subjects, ORMS Ltd
Public site spam prevention User contributed content (forum posts) Data Subjects, ORMS Ltd
DNS and Denial of Service Protection (gradually being phased out) Website usage and all passed traffic data Data Subjects, ORMS Ltd
Voice and Video Meetings ORMS Ltd Employee contact information and recorded video Data Subjects, ORMS Ltd
Monitoring sites Email address & Name for Authentication Data Subjects, ORMS Ltd
Virus & Malware scanning for Windows Users Email address, Name, Scan data from local computer Data Subjects, ORMS Ltd
Moodle Staging Sites for internal use only Any non-anonymised data from production instances for testing Data Subjects, ORMS Ltd
Test specific features as part of development Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available Data Subjects, ORMS Ltd
Demo most recent version of software to the public Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available Data Subjects, ORMS Ltd
Statistics and Marketing Tracking IP addresses and logs, site behaviour analytics Data Subjects, ORMS Ltd
Ongoing testing of software Logins for staff, possible other data as test cases Data Subjects, ORMS Ltd
Distribution of software Source code with names in it and Moodle profiles for HQ Staff and Contractors Data Subjects, ORMS Ltd
Language translations for Moodle Profile data Data Subjects, ORMS Ltd
Moodle documentation repository Profile data Data Subjects, ORMS Ltd
Private Moodle Code Repository Profile Data Data Subjects, ORMS Ltd
Learning Moodle course Profile data, course results Data Subjects, ORMS Ltd
Public Moodle Code Repository Profile data Data Subjects, ORMS Ltd
Storage of documents and other communications Free form storage of documents, so any personal data is possible Data Subjects, ORMS Ltd
Service status notifications User logins for HQ Staff Data Subjects, ORMS Ltd
User login and other information Login and other personal profile information Data Subjects, ORMS Ltd
Course hosting service Login and other personal profile information Data Subjects, ORMS Ltd
Testing accessibility features in Moodle Login and other personal profile information Data Subjects, ORMS Ltd
Collaborative document/code editing Open system with varied data as well as user IP addresses Data Subjects, ORMS Ltd
Register of research related to Moodle Published research documents, login details and profile Data Subjects, ORMS Ltd
Hosting applications for Moodle Login information Data Subjects, ORMS Ltd
Legacy Moodle sites Login information Data Subjects, ORMS Ltd
Indexing for search purposes Any data supplied over our sites network Data Subjects, ORMS Ltd
Collection and processing of anonymized data from third parties Anonymized data from other institutions as well as login/profile for ORMS Ltd employees and contractors Data Subjects, ORMS Ltd
News and information for the Development community Login and other personal profile information. Details of specific development project participants Data Subjects, ORMS Ltd
Communication to Moodle community Login and other personal profile information Data Subjects, ORMS Ltd
Accounts for access to software and licensing Login and other personal profile information Data Subjects, ORMS Ltd