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The Code

Privacy Notice
Diversity and Inclusion Programme: The Code

  1. This privacy notice sets out how we, dentsu Ltd of 20 Triton Street, London, NW1 3BF together with our group companies ("we", "us", "our") process your personal data ("you", "your").
  2. This notice applies to:
    • students who participate in our programmes;
    • parents or guardians of participating students;
    • speakers and attendees of our workshops and events;
    • staff at schools or colleges which participate in our programmes;
    • our website visitors and
    • individuals who visit our offices, contact us or who we interact with in connection with our diversity and inclusion programmes.
  3. Please send us an email to dpo@dentsuaegis.com if you have any questions or if you would like more clarity on any matters set out in this notice.

What personal data do we process about you?

  1. "Personal data" means any information relating to an identified or identifiable natural person; such person is known as a 'data subject'. In practice, almost all information relating to you will be your personal data. We may process the following personal data about you:
    • Information which you provide to us
      • Students who participate in our programmes may share their name, interests, school or college details, year group details, home address, family details and feedback on our programmes and activities. We may ask for gender and ethnicity details, but this is always on an anonymous basis.
      • Parents of participating students may share their name, contact details, family details and feedback when they enquire about our programme, their child’s participation or when parental or guardian consent is required.
      • Speakers and attendees of our events may share their name, professional details, contact details and feedback on our programmes as required for their engagement in connection with our programmes.
      • Staff at participating schools and colleges may share their name, professional details, contact details and their feedback on our programmes when interacting with us.
      • Images of students, speakers, attendees, parents, and school staff may be obtained for internal and promotional purposes.
      • If you visit our website you may contact us through online tools. You may provide us with your contact details, information about your query or complaint, your interest in our programmes or organisation, your marketing preferences, feedback about our content or other contributions.
      • If you interact with us, you might provide your contact details and the details of your query or communication.
      • All such information will be necessary to assist with your query, organise and deliver our programmes to you.
    • Information about you from third parties
      • Our partner organisations may provide information about schools and students who might want to participate in our programmes.
      • Students or schools may provide next-of-kin or guardian information which may be required to obtain the guardian’s consent.
      • Schools may provide information about their students as is relevant for the child’s participation in our programmes.
      • Third parties may provide to us information about you, particularly if you work for a school or a supplier and they may offer your details as a point of contact.
      • Such information is necessary to organise and deliver our programmes to those who wish to participate.
    • Information about your device
      • When you visit our website, we may collect technical information about your device such as IP address, device ID, cookie ID, operating system, browser, time zone setting, clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences, and methods used to browse away from our website.
      • When we send you emails, we may collect technical information about your interaction with the email, such as open rates and if you clicked on any content.
      • This information is not mandatory, but it will often be collected automatically as part of technical processes. Our cookies notice explains which information is collected through cookies and similar technologies.

Why do we use your information?

  1. Generally, we will use your personal data to (i) deliver our programmes to you through interaction, content and events; (ii) produce and organise our programmes; (iii) respond to your enquiries; (iv) produce information about the success of our programmes and research materials; and (v) operate, develop and promote our organisation, programmes and relevant materials. We would need you to provide your personal data, for us to deliver and provide these services. We may not be able to provide these programmes or services to you if you do not provide us with your personal data.
  2. We must inform you about the legal basis for us to use your personal data, often called "legal grounds". This will normally be that we have your consent to our use of your data or it is in our legitimate interest to use your personal data to ensure that our programmes are operated properly, efficiently and securely, as is further explained below.
    PurposePersonal dataLegal ground for processing
    Keeping you informed about matters relevant to your participation in our programmes, such as events, appointments, requirements, changes in terms, etc., and your use of our services or content.

    Responding to queries, communications and resolving complaints.
    • name
    • contact details
    • participation, activity & usage data
    • professional details
    • details of your queries or complaints
    We will send you information based on our legitimate interest to satisfy your requests, organise, and deliver our programmes and to resolve any complaints.
    Working with information as is required for administration, including:
    • to enable you to participate in our programmes, competitions, prize draws or events;
    • for administration of our organisation, programmes, and content, including engaging and sharing data with third party suppliers who fulfil functions in relation to our programmes, services or content;
    • for processing next of kin, parent or guardian information for legal reasons;
    • to keep appropriate business records.
    • name
    • contact details
    • family data
    • professional details
    • next of kin and guardian details
    • participation, activity & usage data
    • device data
    Necessary for our legitimate interest to properly and efficiently deliver our programmes and manage our organisation and related activities.
    Sending you promotional information about our programmes, services and organisation and profiling your information for direct marketing purposes.

    Profiling may involve using automated means to process your personal data to analyse or predict your personal preferences, interest, or behaviours.
    • name
    • email address
    • professional details
    • school/college details
    • previous interaction & interests
    • participation, activity & usage data
    • device data
    Where you have requested information from us, we may send you newsletters, publications, event invitations, etc. based on our legitimate interest to satisfy your requests, to understand your interests based on the information available to us and to provide you with relevant content.

    If not requested or if consent is required by law, we may send you such communications if you provided consent.

    You can opt-out at any time, and we will stop all activities concerning your personal data carried out for direct marketing.
    Using your image for promotional purposes.
    • name
    • image
    • other information, as you may agree
    We will use your image only if you provided consent, which will be obtained separately.
    Collecting your guardian’s consent for you to participate in our programmes
    • name
    Necessary for our legitimate interest to comply with best practice and laws
    and attend our offices, where legally required.
    • family data
    • information
    • next of kin and guardian details
    Analyse statistical data as is required to improve and develop our programmes and related activities. For these purposes we will:
    • use information collected on the website and through cookies and similar technologies;
    • run and evaluate satisfaction surveys;
    • receive and evaluate your feedback;
    • conduct statistical analysis.
    • name
    • email address
    • family data
    • professional details
    • school/college details
    • previous interaction & interests
    • background information
    • next of kin and guardian details
    • participation, activity & usage data
    • device data
    Necessary for our legitimate interest to:
    • provide our programmes properly, efficiently and effectively and with relevant content;
    • understand our participants and users, their needs and interest in our programmes, services and content;
    • inform our marketing strategy to grow our programmes and organisation.
    We will use information obtained through cookies and similar technologies if you provided consent
    Recording images and CCTV footage of you for security and authentication purposes when you visit our offices.

    We will monitor our networks, websites and systems for suspicious activities and deploy other security measures.
    • name
    • background information
    • images of you
    • usage data
    • device data
    • security logs
    Necessary for our legitimate interest to ensure the security of our organisation and people, preventing and detecting fraud or illegal conduct.
    We will collect information about your gender and ethnicity for diversity monitoring.
    • anonymous information, unless you provided your name in which case we will anonymise it without delay
    • gender information
    • ethnic background
    Necessary to carry out equal opportunity or treatment monitoring to comply with best practice and anti-discrimination laws in the substantial public interest.
    To share information within our offices, departments, business units and our group companies.
    • any necessary information on a proportionate and lawful basis
    Necessary for our legitimate business interest to use our group's resources to organise, develop and deliver our programmes, run our organisation and decide on future strategies.
    To share information with other third parties, such as regulator, law enforcement agencies or where this is mandatory under a court order.
    • Any information subject to mandatory disclosure, where this is proportionate and lawful
    We share your data as necessary for compliance with any legal obligation to which we are subject or, where appropriate and proportionate, in order to satisfy our legitimate business interest to comply with best practice or applicable laws, and where this is necessary for the establishment, exercise or defence of legal claims or wherever courts are acting in their judicial capacity.
  3. We will update you about any new purposes of processing of your personal data from time to time.
  4. We have implemented appropriate policies and procedures to ensure that your information is processed in accordance with the data protection principles.

Disclosure of your personal data

  1. If you support or get involved in our programmes, we will generally not share your information except with our group companies and suppliers as is required to use our group’s resources to organise, develop and deliver our programmes, run our organisation and decide on future strategies.
  2. Generally, we may wish to disclose or are compelled to disclose your personal data to third parties in the following scenarios:
    • to our offices, departments, business units and our group companies as explained above;
    • to schools or colleges as is appropriate and necessary in connection with their participation in our programmes;
    • to our suppliers to facilitate the provision of our programmes, content and services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, engagement tools, plugin providers, communications providers, accounting or security tools and others;
    • to successor or partner legal entities for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, or similar event relating to our business;
    • to courts, authorities or other third parties where we are required by law to do so; and
    • other third parties where you have provided your consent.

International transfer of your personal data

  1. We will generally keep your personal data in the country of your residence. However, some of our servers may be located in or outside of Europe.
  2. We may also use cloud storage or another supplier who stores your personal data abroad on our behalf.
  3. Where this is the case, we will ensure that your data protection rights are adequately protected by appropriate technical, organisational, legal, and contractual safeguards. You may contact us if you wish to be informed of the appropriate safeguards in place for international transfers of personal data.

Retention of personal data

  1. We retain personal data for as long as is necessary for the purposes listed above or longer, as may be required by the law. Please contact us for further details of applicable retention periods.
  2. Generally, records about your participation in our programmes will be retained for 6 years. After this time, your personal data will either be securely deleted or anonymised and used for analytical purposes.
  3. Where data is collected on the lawful basis of consent, we assume your consent stands due to your continued interaction with us unless you confirm that you no longer want us to continue processing your personal data. You can withdraw your consent at any time. For more information, please see "Data subject rights" below.

Security of personal data

  1. We will use appropriate technical and organisational information security measures designed to prevent unauthorised access to your personal data. We also seek to ensure our suppliers do the same.
  2. We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation, as appropriate.
  3. Our staff will access your personal data on a need to know basis.

Your right to opt-out

  1. If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please let us know.
  2. You can stop our communications at any time by clicking on the unsubscribe link at the bottom of the message.

Data subject rights

  1. Subject to certain exemptions and limitations, as a data subject, you will generally have numerous rights in relation to your personal data, including the following:
    • Right to information about matters set out in this notice.
    • Right to make an access request to receive copies of personal data.
    • Right to rectification of any inaccurate or incomplete personal data.
    • Right to withdraw consent previously provided.
    • Right to object to processing including automated processing and profiling.
    • Right to erasure of personal data, within limited circumstances.
    • Restriction on the processing of personal data.
    • Right to data portability from one service provider to another, where applicable.
    • Right to lodge a complaint with the Information Commissioner’s Office.
  2. If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.

Changes to this notice

  1. We may modify this notice from time to time and will publish the most current version on our website.

Version number: 1
Last updated: 01 May 2020