London School of Hygiene & Tropical Medicine Privacy Notice for the Rapid Assessment of Avoidable Blindness (RAAB) project
London School of Hygiene & Tropical Medicine (a higher education institution established by Royal Charter and an exempt charity with registration number RC000330) of Keppel Street, London, WC1E 7HT, is a data controller for the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). Within this document London School of Hygiene & Tropical Medicine (LSHTM) may be referred to as "the School"," we" or "us". The School undertakes to treat your personal data in accordance with these data privacy laws. This privacy notice together with our Data Protection Policy, guidance, and any additional documents referred to within them, explains how we process your personal data. Please read this notice carefully. If you have any questions in relation to the School’s processing of your personal data, please contact the Data Protection Officer on firstname.lastname@example.org.
This privacy notice applies to a) RAAB website (www.raab.world) users who create a user account to access RAAB survey data and/ or reports and b) RAAB enquirers (which may include RAAB Partners or RAAB Survey PIs)/ trainers/ prospective trainers who make an enquiry via email@example.com or firstname.lastname@example.org or via a RAAB Trainer application form and whom wish to stay in touch with project developments and/or RAAB Trainers Programme via occasional email updates from the RAAB team (the RAAB team includes researchers at the International Centre for Eye Health (ICEH) at LSHTM and Peek Vision). The School has to process and retain certain personal data relating to you, to be able to provide this information.
How we obtain data about you
We receive personal data relating to you when you choose to provide it to us via the website’s user registration interface or ‘subscribe’ option, or by contacting us via email to email@example.com or firstname.lastname@example.org or completing the RAAB Trainer application form.
What Personal Data we process about you
Information you give us: We may process the following categories of personal data about you:
- Email address;
- Research objective/ reason for accessing RAAB data.
- (For Trainers/prospective Trainers only)
- Language capabilities
- Academic history/Experience history in relation to an application to be a RAAB Trainer
Technical usage information: When you visit the website, we collect the information sent to us by your computer mobile phone or other access. This includes:
- IP address;
- device information including, but not limited to, identifier, name, and type of operating system;
- mobile network information;
- standard application usage data; and
- standard web information, such as your browser type and the pages you access on our website.
Purposes of Processing
We process these personal data about you so that we can provide you with information that you have indicated you would like to receive. We may occasionally provide you with information that we believe is directly related to the information you have indicated you would like to receive from us. We may also offer you options to receive further types of information from us and to provide feedback on RAAB and, where applicable, how RAAB data and/ or reports have been used, analysed and/or disseminated.
Legal Basis for Processing Your Personal Data
Under the UK GDPR we have to say how we are lawfully going to use your data. (If you are interested, you can find out more about the law by visiting the Information Commissioner’s Office website at www.ico.org.uk.)
The School’s Royal Charter empowers it to perform certain functions to operate as a higher education institution. These functions include “promoting … research… and education in public health and tropical medicine and such other academic subjects as [the School] may consider appropriate”. We will rely on this basis for the majority of the processing we do of your personal data and we use appropriate safeguards.
We ask you to not share your login information. Dataset(s) may not be used for purposes other than those expressed in the online user registration form and may not be redistributed or passed on to others in any form.
Under the UK GDPR we have a number of lawful reasons that we can use (or 'process') people’s personal data. One of the lawful reasons is called “legitimate interests”.
Broadly speaking “legitimate interests” means that we can process your personal information if:
- we have a genuine and legitimate reason; and
- we are not harming any of your rights and interests
This means that when you provide your personal data to us we use your information for our legitimate interests to carry out our work maintaining and improving the RAAB survey methodology. Before doing this, we will also carefully consider and balance any potential impact on you and your rights.
We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate service and provide the best and most secure experience. These are what we consider to be our “legitimate Interests”.
Occasionally, we may need to process your data on the basis of your consent. If this happens, we will seek your consent to process your data for that purpose. We will explain to you how you can withdraw your consent at the time of you giving it. If you do withdraw consent, this will not affect the lawfulness of processing based on your consent before your withdrawal.
The following are some examples of when and why we would use this approach in our work:
- Direct Marketing: We may send email communications which inform you of RAAB project news or developments.
- Research: To determine the effectiveness of the RAAB repository, and to develop our services, systems and relationships with you.
- Feedback: We may wish to request feedback from users who downloaded RAAB data and/ or reports on how they have been used, analysed and/or disseminated.
We will also hold information about you so that we can respect your preferences for being contacted by us.
When we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Please see our Data Protection Policy for more information.
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using our contact information at the end of this notice.
Transfers of personal data outside the European Economic Area
Google Analytics is used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. We collect information including the number of visitors to the website, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
If you are a RAAB enquirer (which may include RAAB Partner or RAAB Survey PI)/ trainer/ prospective trainer, RAAB stores your data on a cloud-based project management system, Monday.com. Monday uses servers outside of the UK. Where we do this, and the recipient is in a country which the European Commission has decided does not have adequate data protection laws, we will make sure that appropriate safeguards are in place to protect your information and your rights under privacy law.
In addition, data stored on Monday.com is accessed by pre-authorised staff members of LSHTM and Peek Vision Ltd via password encryption, some of whom may be based outside of the UK.
Where we store your personal data
User registration details are stored on our website’s database. These are only made available to the RAAB team at ICEH and Peek Vision.
Enquirer and Trainer/prospective Trainer details are stored on our Project Management system. These are only made available to the RAAB team at ICEH and Peek Vision.
Retention of your personal data
We will hold your personal data for the time specified in our data retention schedules, or if there is no such time specified, for a reasonable time. This may mean that we retain your personal data indefinitely, until you tell us you no longer wish to receive the information, or until the RAAB project at the School comes to an end. We will aim to keep your contact information up-to-date and if we become aware that it is out of date and cannot be updated we may at that time delete your data.
Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website; any transmission is at your own risk.
Third party links
Contact details for queries
If you want further information about how your personal information is used or want to correct, restrict or erase, have access to personal data or exercise your right to data portability, please contact email@example.com.
How to complain
Individuals have the right to complain about the processing of their personal data. If you are dissatisfied, please contact the School’s Data Protection Officer in the first instance at firstname.lastname@example.org. If we are unable to adequately address any concerns you may have about the way in which we use your personal data, you have the right to lodge a formal complaint with the Information Commissioner's Office. Full details may be accessed on the complaints section of the Information Commissioner's Office website.
The Commissioner can be contacted at the following address: