Introduction

This Privacy Policy applies in relation to the collection and use of personal data, in the course of operational activities, by:

• The Legal Education Foundation, a charity registered with registration number 271297, with registered office at 15 Alfred Place, London, WC1E, 7EB; and
• Justice Collaborations, a charity registered with registration number 1187441, with registered office at 15 Alfred Place, London, WC1E, 7EB,

and references in this Privacy Policy to (“TLEF“, “we“, “us” or “our“) should be interpreted accordingly.

Each of The Legal Education Foundation and Justice Collaborations process personal data independently of each other and do not jointly determine the purpose and means of that processing.

This Privacy Policy applies to personal data provided directly to us by the individuals concerned and to personal data provided to us by companies and other organisations. The term “personal data” refers to information that relates to an identified or identifiable individual, such as name, birth date, telephone number, e-mail address or mailing address.

We have policies, procedures and training in place in respect of data protection, confidentiality and information security. We regularly review such measures with the objective of ensuring their continuing effectiveness. We may therefore update this Privacy Policy from time to time. This version was updated on 30th June 2020 and sets out your rights under the new General Data Protection Regulation (“GDPR“) which came into force on 25th May 2018.

International transfers of personal data

We, and our service providers who process your information on our behalf, may not transfer your information outside of the EEA unless the European Commission has decided that a country (or territory or one or more specified sectors within that third country as the case may be) ensures an adequate level of protection; or we, or our service providers, have provided appropriate safeguards as required under GDPR for such processing or transfers.

Provision of personal data to third parties

We will only share personal data with third parties where we are legally permitted to do so. Where we transfer personal data to third parties, we will put in place appropriate contractual arrangements to protect personal data. We will disclose your information in the circumstances set out below.

• To third party service providers: We will disclose your information to third parties who provide us with services; for example, third parties who supply us with information technology services to help run our business or professional advisers, such as lawyers or accountants. Where we disclose information to our service providers we impose strict controls to ensure that it continues to be properly protected. Please refer to the above paragraph (International transfers of personal data) for information where service providers are based outside of the European Economic Area.
• In accordance with the law: We will disclose your information where we are under a legal obligation to do so; for example, because a law obliges us to disclose that information or we have to disclose it as part of a legal claim. We will also disclose your information where there is substantial public interest, and the disclosure is necessary and proportionate. For example, we will share your information with tax authorities.
• With your consent and in other situations: We will also disclose your information in other situations, such as where you have asked us to or where there is a legitimate reason to do so. For example, we might disclose your information in the context of the restructuring of our operations, though we will seek to anonymise your information where reasonably practicable.

Your Rights (data subject requests)

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to ask for a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you depending on the purposes of processing. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This is not absolute and only applies in certain circumstances. This enables you to ask us to delete or remove personal data where the personal data is no longer necessary for the purposes which we originally collected or processed it for. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, without undue delay (and otherwise within one month of receipt of the request).

Object to processing of your personal data in certain specific situations (including where we are relying on a legitimate interest (or those of a third party)). You must give specific reasons why you are objecting to the processing of your personal data, and these reasons should be based upon your particular situation. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms. In addition, you also have an absolute right to object to direct marketing at any time where we are processing your personal data for direct marketing purposes.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to verify the data’s accuracy;
• where our use of the data is unlawful but you oppose erasure and request restriction instead;
• where we no longer need the personal data, but you need us to hold the data to establish, exercise or defend legal claims; or
• where you have exercised your right to object to use of your data but we need to verify whether we have legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of England & Wales. You agree to submit any dispute arising out of your use of this to the exclusive jurisdiction of the courts of England & Wales.

Complaints

Should you wish to complain about our use of your personal data, please contact us using the Contact Form. We will investigate all complaints received and will endeavour to respond to complaints promptly.

You may also complain about our use of personal data to the Information Commissioner’s Office. For further information on your rights and the complaints process, please visit the Information Commissioner’s Office website: https://ico.org.uk/make-a-complaint/.

Data Retention

We will only keep personal data for as long as necessary for the purposes for which it was collected, or as required by applicable law or regulation.

Unless there are any legal, regulatory or contractual requirements, we will retain records (which may include personal data) in accordance with our Data & Record Retention Policy.

What personal data we collect, why and how we use it

We will only use your personal data when the law allows us to. Most commonly we will use one of the following lawful bases:

• Execution of a contract with you
• Necessary for our legitimate interests
• After obtaining consent from you
• Necessary to comply with a legal obligation

To find out more about how and why we process personal data for different purposes, please refer to the relevant section below:

1. Website Visitors:

What data do we collect?

We automatically collect data about visitors to our website (for example on browsing patterns) by using cookies. (See Cookie Policy).

How do we use your data?

This data is used only in an anonymous form; no individual is identified.

2. Website Enquiries:

What personal data do we collect?

• Your name,
• Your organisation name (if applicable) and
• Your email address.
• You may optionally provide your phone number.

How do we use your personal data?

We use your personal data only for the purpose of responding to your query using your email address (or your phone number if you have provided it).

To whom might we disclose your personal data?

We will not disclose personal data received through a website enquiry to any third parties unless you have given us consent to do so.

3. Grant Applicants and Justice First Fellowship (JFF) Host Applicants

What personal data do we collect?

We collect personal data about Grant and JFF Host Applicants to manage our relationship with them. This would normally include contact names, email addresses and phone numbers that have been provided by Grant and JFF Host Applicants.

How do we use your personal data?

We use personal information from Grant Applications to contact Applicants regarding their Application including requesting additional information and, if successful in drafting a Grant Agreement.

Once a Grant Agreement is in place we will use your personal information to manage the Agreement and our relationship with the Grantee or JFF Host Organisation, including requesting reports, providing access to our contact management system, managing payments and keeping records for accounting and audit purposes.

We will occasionally send information about our, news/events or other items of interest to your email address. We will only do so if you have consented to receive these, and we will provide the opportunity to change your preferences at any time.

To whom might we disclose your personal data?

We may disclose personal data to our auditors and advisors as required by law or as reasonably required in the management of our charity. We may disclose personal data to third parties, such as Regulators, where required by applicable law and regulation.

Updating your records

If a contact at a Grantee or JFF Host changes role or ceases to work for that organisation we ask that we are informed of the change so that we can update our records. This can be done via our Contact Form.

 

4. JFF Applicants

What personal data do we collect?

If you apply to be a Justice First Fellow we will ask you to provide additional personal information when completing the online application form.

This may include some or all of:

• • Name
  • Address
  • Phone number(s)
  • Email address
  • Educational background
  • Diversity information including gender, date of birth, ethnicity, disabilities

Certain personal data is referred to as Special Categories’ of personal data under the GDPR. These include information about ethnicity, nationality and disabilities. Where we collect such information, we collect it for equality and diversity monitoring purposes or, in the case of information relating to disabilities, to facilitate adaptations in the host’s workplace in order to ensure special needs are catered for at interview and in monitoring equality of opportunity. This information is not mandatory.

Successful candidates may be asked to provide bank details for the payment of expenses.

How do we use your personal data?

Access to the application form will be provided to the third-party organisation to which you have applied to (referred to as “JFF Host Organisations”).

Successful candidates will become members of the Justice First Fellowship Scheme and their contact details will be used to keep them informed of events relating to the Fellowship Scheme during the period of their training contract. Data will also be retained to keep you informed of events relating to the JFF after you have qualified unless you ask us to remove your contact details from our records.

To whom might we disclose your personal data?

Applicants’ personal data and application will be passed to the JFF Host Organisation(s) you have selected and, subject to your consent, to other Hosts.

Fellows’ contact details will not be passed to other Fellows or Hosts without their specific consent.

5. Suppliers, Consultants and Professional Advisors

What personal data do we collect?

We aim to collect personal data about our suppliers, consultants and professional advisors only to the extent necessary for us to receive goods and services, manage our relationship with them.

How do we use your personal data?

We use the personal data in managing and administering our operations, and to comply with contractual, legal and regulatory obligations. This will include managing payments and keeping records for accounting and audit purposes.

To whom might we disclose your personal data?

We may disclose personal data to our auditors and advisors as required by law or as reasonably required in the management of our charity. We may disclose personal data to third parties, such as Regulators, where required by applicable law and regulation.

6. Job Applicants

What personal data do we collect?

When we recruit for a new member of staff we will request a copy of a Curriculum Vitae and any additional personal information we require for the application process.

This may include some or all of:

• • Name
  • Address
  • Phone number(s)
  • Email address
  • Diversity information including gender, date of birth, ethnicity, disabilities
  • Educational background
  • Previous work experience
  • Previous employers

Certain personal data is referred to as Special Categories’ of personal data under the GDPR. These include information about ethnicity, nationality and disabilities. Where we collect such information, we collect it for equality and diversity monitoring purposes. Data relating to disabilities is also collected so that any reasonable adjustments can be made to accommodate applicants at interview and, if successful, in the workplace.

We may use a recruitment agency and or selection consultants to assist in this process and will ask and expect them to follow the GDPR guidelines in dealing with applications.

How do we use your personal data?

Your personal data is only used for the purpose of the recruitment process for the role for which you applied.

To whom might we disclose your personal data?

Your data may be disclosed to a recruitment agency or selection consultant if we contract with one or more to assist in the recruitment process.

7. Other Contacts

What personal data do we collect?

We also collect contact details from publicly available sources, such as organisation websites, to enable us to contact people who we believe may have an interest in the information we provide and events we may hold.

How do we use your personal data?

We may contact you in relation to an event or activity of ours which we believe will be of interest to you. You will be provided with a mechanism to opt in to any such contact and the ability to state your preferences in relation to such communications.

To whom might we disclose your personal data?

We will not disclose your data to any third parties unless we first obtain your consent.

Provision of general information regarding our work

We may send information relating to our work, documents we publish and events we run or participate in to Contacts (including but not limited to suppliers, Grantees, JFF Hosts and Fellows).

Before sending such information, we will ask for your consent and you will be provided with a mechanism to opt in to any such contact and the ability to state your preferences in relation to such communications.