INTRODUCTION
Welcome to the Proteus privacy notice. myProteus Limited (collectively referred to as “Proteus”, “we”, “us” or “our” in this privacy notice) provides a group website www.myproteus.com and the Proteus Learning Hub www.proteuslearninghub.com. Proteus does not use the group website to collect any personal data, users of the group website only are therefore directed to the cookie policy portion of this privacy notice as the only part relevant to them.
Proteus respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit the Proteus Learning Hub and other resources made available via the internet to users of the Proteus Learning Hub (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a sectioned format so you can find the specific information you want under the relevant topic areas. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
myProteus Limited is a company registered in England and Wales under company number 7304983 and with its registered office at: 9 Quy Court, Collier Lane, Stow-Cum-Quy, Cambridge, CB25 9AU.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Proteus receives (from employers who use the Proteus Learning Hub) and processes your personal data through your use of it, including any data you may provide when you access the Proteus Learning Hub (under an account created for you) or when you configure your account to receive Proteus Learning Hub email notifications.
The Proteus Learning Hub is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
CONTROLLER AND PROCESSOR
If you are accessing the Proteus Learning Hub as an employee or staff member of a company or organisation that makes the Proteus Learning Hub available to you, myProteus Ltd is the data processor of your personal data provided by your employer and your employer is the data controller of your Person Identifying Information.
If you use the Proteus Learning Hub in the course of your employment, your employer is the data controller for your personal data. You should contact your employer’s own data protection officer, if you have any questions about this privacy notice, including any requests to exercise any rights you are entitled to under the laws protecting personal data. If you have data protection questions or concerns purely regarding Proteus, we will endeavour to respond if you contact us on at the address, below.
CONTACT DETAILS
Our contact details are: myProteus Limited, 9 Quy Court, Collier Lane, Stow-Cum-Quy, Cambridge, CB25 9AU
Please ask your employer for the contact details of your employer’s Data Protection Officer.
You have the right to make a complaint at any time and we recommend, if you are a Proteus Learning Hub user, to contact your employer’s Data Protection Officer who will liaise with us to appropriately address your complaint. If you are not satisfied with the response from them, the Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues, please go to www.ico.org.uk.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 21st May 2018.
It is important that the personal data we hold about you is accurate and current. Learning Hub users must keep their user account up to date and make any changes you need to from time to time.
THIRD-PARTY LINKS
We follow your employer’s policy regarding links from the Proteus Learning Hub to other resources, to third-party websites, plug-ins and applications (which they may allow). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Proteus Learning Hub, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, when you use the Proteus Learning Hub, which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes email address.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data (Proteus refers to this as User Account information) includes your username and password, responses to self-assessments and surveys made by you, your preferences for how our systems notifies and reminds you of things that need attention.
- Usage Data includes information about how you use the Proteus Learning Hub and its contents.
The Proteus Learning Hub collects and uses Aggregated Data such as statistical, de-identified or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data for the Proteus Learning Hub under the terms of a contract we have with your employer and you fail to provide that data when requested, we may not be able to perform the contract we have (for example, to provide you with the Proteus Learning Hub services at the request of your employer). In this case, we may have to cancel a product or service you have with us, but we will notify your employer if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you on the Proteus Learning Hub including through:
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Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email, phone or otherwise. This includes personal data you or your employer provide when:
- your employer creates an account on the Proteus Learning Hub for you;
- you use a self-assessment tool or complete a survey and save a record of your answers; or
- you contact us to get help or give us some feedback.
- Automated technologies or interactions. As you interact with the Proteus Learning Hub, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy included at the end of this privacy notice for further details.
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Third parties or publicly available sources. We may receive personal data about you from your employer and various third parties as set out below:
- Technical Data from analytics providers such as Google based outside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with your employer.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Please refer to the “Lawful Basis” section of the Glossary in this privacy notice, to find out more about the types of lawful basis that we will rely on to process your personal data.
You consent to this privacy policy when you accept your user login on the first occasion you access the Proteus Learning Hub, and you also thereby consent to myProteus Ltd handling your personal data, as your employer’s data processor.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways your employer as data controller, working with Proteus as data processor, will be using the limited personal data held in the Proteus Learning Hub, and which of the legal bases is relied on to do so. We have also identified what Proteus’s legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact your employer’s Data Protection Officer, if you need details about the specific legal ground that is being relied on to process your personal data where more than one ground has been given.
Purpose/Activity: To register you as a new user.
Type of data: (a) Identity, (b) Contact.
Lawful basis for processing including basis of legitimate interest: Performance of a contract with your employer.
Purpose/Activity: To notify you about changes to our terms or privacy policy.
Type of data: (a) Identity, (b) Contact, (c) Profile.
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract affecting you, (b) Necessary to comply with a legal obligation.
Purpose/Activity: To administer and protect the technical systems on which the Proteus Learning Hub operates (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data: (a) Identity, (b) Contact, (c) Technical.
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests, (b) Necessary to comply with a legal obligation.
Purpose/Activity: To deliver relevant content to you and compile comparative non-identifying summary and performance information and measure or understand the effectiveness of the services we provide you.
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to keep the Proteus Learning Hub updated and relevant and to develop our business).
Purpose/Activity: To use data analytics to improve the Proteus Learning Hub experience.
Type of data: (a) Technical, (b) Usage.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to keep the Proteus Learning Hub updated and relevant and to develop our business).
Purpose/Activity: To make suggestions/recommendations to you about items or services that may be of interest to you.
Type of data: (a) Identity, (b) Contact, (c) Usage, (d) Profile.
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to help operate our services for your and your employer’s benefit).
COOKIES – “Cookie policy”
We may use cookies. Cookies are information files that the Learning Hub or the Proteus Website may send to your computer to allow us to administer the sites, provide extended security functionality, optimise the user experience or track usage patterns. The cookies we use are described below:
a) Log in cookie
Purpose: This cookie is essential for the Learning Hub to work efficiently. It is an encrypted authentication cookie used to identify and remember you, and your preferences, to allow you to move easily about the Proteus Learning Hub without needing to reintroduce yourself. This cookie expires when you log out of the Learning Hub.
Name: AspNet.ApplicationCookie
b) Session cookie
Purpose: This cookie is essential for the Learning Hub to work efficiently. It is an encrypted cookie that is used to identify you throughout the ‘session’ that you are logged into the Learning Hub to provide/retain appropriate data which is required to operate the Learning Hub. This cookie expires after 60 minutes of non-activity on the Learning Hub or when you have logged out.
Name: ASP.NET_SessionId
c) Security cookie
Purpose: This cookie is essential for the security of the Learning Hub. It is used, in line with best practice standards, to provide additional security to you as a user in relation to preventing cross-site scripting (XSS) attacks and preventing others attempting to log in as you. This cookie persists until you chose to clear your cookies from your browser internet settings.
Name: __RequestVerificationToken
d) Analytics cookies
Purpose: These cookies are used to collect information about how you use our Proteus Website. The cookies collect data in an anonymous form and help us to better understand the number of visits we’d have to our website, where visitors have come from and the pages they’ve visited. These cookies by default expire after 2 years of inactivity, or until you chose to clear your cookies from your browser internet settings.
Name: _ga – Google GA cookie, _gat – Google GA cookie, _gid – Google GA cookie
How do I change my Cookie Settings?
You may choose to disable cookies, receive a warning before a cookie is placed on your computer, and erase cookies from your local storage through use of options or preferences menus in your browser. It is possible, however, that some parts of the Proteus Learning Hub will not operate correctly if you disable the cookie feature.
For the Learning Hub: Consult with your organisation’s primary contacts and your IT department if you have any questions or concerns about the cookies that are included in the Learning Hub.
For the Proteus Website: You may prevent your data from being used by us via Google Analytics. You can do this by installing the Google Analytics Opt-out Browser Add-on for your web browser. This can be downloaded from http://tools.google.com/dlpage/gaoptout.
To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
OPTING OUT
As the Proteus Learning Hub is a service provided at the request of your employer, there is no “opt out” provided. There is no facility on the Proteus group website to sign up for information to be sent to you and therefore no “opt out” applies there.
CHANGE OF PURPOSE
If for any reason Proteus changes the purpose of processing your personal data your employer will be informed of this and your employer will keep you updated. Some authorities may be lawfully entitled to require Proteus to process your personal data under a legal requirement, without your knowledge or consent. Proteus will do so only in compliance with the applicable rules, as required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:
- External Third Parties, as set out in the Glossary of this privacy notice.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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 your employer or our instructions (as applicable) 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, which in the case of the Proteus Learning Hub is to fulfill our contract with your employer, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Your personal data in the Proteus Learning Hub ceases to be held by Proteus when your employer’s contract with us comes to an end. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you and ceases to be personal data) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the “Your Legal Rights” section in the Glossary. Please note: where your employer is the controller of the personal data supplied to us, Proteus is only processing your personal data in the course of providing a service to your employer, therefore you should first approach your employer, if you wish to exercise any of these rights.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we (or your employer) may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we reserve the right to refuse to comply with your request in these circumstances.
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 may take us longer than a month 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.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
Service providers acting as processors for Proteus, who provide IT, IT security and system support and administration services.
YOUR LEGAL RIGHTS
You have the right (through your employer's Data Protection Officer) to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive 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. 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 enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 (see below), 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, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
