THE KARTA INITIATIVE: PRIVACY POLICY

This privacy policy explains how we use and manage your information in accordance with the General Data Protection Regulation (EU) 2016 / 679 and the Data Protection Act 2018 (together, the “Data Protection Laws”).

1. Introduction

The Karta Initiative is a social mobility charity which aims to connect bright low-income students with world class higher education.

To help us achieve this aim, we may collect and process your personal data. This helps us to, among other things, assess prospective candidates to our Programmes, support scholars during their journey through higher education, as well as being necessary for the administration of our supporter’s donations and to assess the impact of Karta’s work on social mobility.

We aim to be clear and transparent with you about how, what, when and why we collect your personal data. We ask that you read this privacy policy carefully to understand the terms on which your personal data is shared with us.

If you have any questions about this privacy policy, including any request to exercise your legal rights (see Your legal rights), please contact the data privacy manager using the details provided in the Contact us section of this page.

Throughout this policy we use language which can be defined as follows:

Programme: any programme which you may have applied to, for example, the Karta Access Programme or the Karta Catalyst Programme; and

The Karta Initiative: is what is known as the “data controller” and is responsible for your personal data and this policy (collectively referred to as “Karta”, “we”, “us” or “our”).

2. What personal information do 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 of the individual has been removed or anonymised.

We may collect the following different kinds of personal data about you:

Identity Data includes first name, middle name, last name, title, date of birth, country of birth and nationality, and gender.

Contact Data includes correspondence address, email address(es), physical address(es) (including postal code) and phone number(s). We may also ask for the Contact Data of a person to contact in the case of an emergency (an Emergency Contact).

Financial Data includes bank accounts and payment card details.

Education Data includes school attended, academic performance and academic and extra-curricular interests.

Parental Data includes, in respect of parents, their occupation(s), education, household income and/or wealth, and eligibility for financial aid provided by the state.

Destination Data includes University or college enrolment, and details of any financial aid.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website (including the specific pages of our website that you visit, the time and date of your visit, the time spent on those pages).

Communications Data includes your preferences in receiving newsletters and correspondence form us. We may use your personal data to contact you with newsletters, updates on the progress of Karta catalysts, details of and invitations to events, requests for Karta alumni to consider supporting us in terms of time, philanthropy, and donations and / or supporting the employability of current Karta members, and other information that may be of interest to you.

Users of our digital learning platform, Karta Connect, will also be requested to provide a contact phone number of a parent for the purposes of account security and recovery (an Account Contact). No other personal data is collected when you sign-up to or use Karta Connect.

We also collect Aggregated Data such as statistical or demographic data for the purposes of evaluating social mobility and the impact of Karta’s work. For example, we may aggregate data to:

• produce annual reviews or reports that are to be shared with donors or third-parties; and

• assess where our digital learning platform, Karta Connect, is being used globally (through the use of anonymised zip codes or area designations).

Aggregated Data could be derived from your personal data, but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we ever 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 policy.

On occasion we may have cause to collect personal information related to your health (including disabilities, allergy information and serious medical conditions) which the Data Protection Laws consider to be Special Category Data (or “Sensitive Data”). For example, if you are a prospective applicant to one of our Programmes, we may ask you to provide any historic or current health conditions for the purposes of assessing you against our eligibility criteria. We may also ask you for this information to ensure we can provide appropriate support to you during your tenure on our Programmes.

On most occasions where we collect Special Category Data for these purposes, we will obtain your consent and, at the time of collection, we will make clear to you the purpose for which it is collected. You may withdraw your consent at any time (see Your legal rights below). We would only ever record Special Category Data without your consent in very rare circumstances where the relevant information has been clearly and deliberately shared publicly by you.

We do not collect any other Special Category Data about you which relates 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.

3. How do we collect your personal data?

We use different methods to collect data from and about you including through:

Direct interactions. You may give use your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, video conferencing means or otherwise.

Third parties or publicly available sources. We will receive personal data about you from various third parties as follows:

• In the case of prospective applicants, Identity, Education, Parental Data supplied by you oryour school;

• Technical Data from analytics provides such as Google based outside the European Union;

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

• Company and charity filings;

• Articles found in publicly available media; and

• Social networking websites such as Linkedin.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies (see Cookies below).

4. Why is your personal data being collected?

We will only use your personal data when the law provides us with a legal basis on which to do so. Most commonly, the bases on which we will use your personal data are:

• 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 perform the contract we are about to enter or have entered into with you;

• where we need to comply with a legal obligation imposed on Karta; and

• to protect your vital interests.

Generally we do not rely on consent as a legal basis for processing your personal data, other than for Special Category Data or where we seek to pass on your personal information to donors.

We have set out below, in a table format, a description of all the reasons why we may use your

5. Disclosure of personal information

We may share your personal data with the parties set out below for the purposes set out in the table above:

• Donors of Karta for the purposes of keeping them informed on the progress and impact of our work. We will only ever pass on this information either with your consent or where we can convert it into Aggregated Data;

• University partners so that they may provide support and reasonable adjustments to Karta Catalysts; and

• Tata Trusts (and its internal and external auditors) in respect of Financial Data only and for the purposes of completing audits required by law.

We require all third parties to respect the security of your personal data and to treat in ac cordance with the Data Protection Laws. 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.

In certain circumstances, Karta may be required to process or disclose your personal data without your knowledge or consent if required to do so by law or in response to valid requests by public authorities (a court, regulator, state agency or otherwise).

6. Change of purpose

We will only ever use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for an ancillary or alternative purpose, that purpose is compatible with the original purpose, and if we have a legal basis on which to do so.

If we ever need to use your personal data for a purpose that is unrelated to the purpose for which it is given, we will notify you and will explain the legal basis which allows us to do so.

7. How do we store your personal information?

Your data will be retained, stored confidentially and processed in accordance with the Data Protection Laws.

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 our instructions 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.

We will only retain your personal data for as long as reasonably necessary to fulfil the purpose for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitively of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In certain circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in order to assess the impact of Karta’s work. In this case, we may use this information indefinitely without further notice to you.

8. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve the site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use analytical or performance cookies which allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can instruct your browser to refuse some or all cookies or to alert you when websites set or access cookies. Please note that if you refuse cookies, some parts of this website may become inaccessible or not function properly.

9. Third-party analytics

We may use Google Analytics as a third-party service provider to monitor and analyse the use of our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

10. Social Media

Karta has a presence on the social media platform, Linkedin. You can interact with us through your existing Linkedin account. For more information on the privacy policy of Linkedin, please see their privacy policy which can be viewed here: https://www.linkedin.com/legal/privacy-policy.

11. Data portability

Save as is set out below, if you are not resident in the United Kingdom and opt to provide us with any information, please note that we transfer the data, including any personal data, to the United Kingdom and process it there. The Data Protection Laws to which persons in the United Kingdom are subject may differ from those of your jurisdiction.

In the case of Karta Connect only, any information that is shared whilst using the platform, including any personal data, may be transferred to, and maintained on, computers or servers located anywhere within the European Economic Area. Any such personal data that is so transferred and stored is subject to laws on data protection that are equivalent to those in the United Kingdom.

Your consent to this privacy policy followed by the provision of any such information represents and constitutes your consent to the transfer of your personal data.

Karta will take all reasonable steps necessary to ensure that your personal data is treated in accordance with the standards described above (see How do we store your information?) and that no transfer of person data will take place to an organisation (third-party or otherwise) or a country unless there are adequate controls in place that meet standards that are equivalent to those required by the Data Protection Laws.

12. Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates made from time to time on this web page.

You are advised to read this privacy policy each time you visit the website to ensure you are familiar with the latest changes. Changes to this privacy policy are effective only when they are posted on this webpage.

13. Ensuring the accuracy of your information

We aim to ensure that all information we hold about you is accurate and, where necessary, kept up-to-date. Please keep us informed if your personal data changes and we will ensure that it is updated and amended without delay.

14. Your legal rights

You can request confirmation of whether we hold your personal information, and, where we do, instruct us to provide you with any personal information we hold about 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 below). 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.

In certain circumstances, you may also have the right to:

• request to have your information rectified if that information is inaccurate or incomplete;

• request that we erase any personal data held about you;

• request us to return the personal information which you gave to us in a structured and electronic (machine-readable) form to allow you to pass it on to someone else;

• restrict our processing of your personal data if you believe it is inaccurate or unlawful to do so, or where use of your personal data is no longer required;

• to transfer your personal data to a third party;

• object to us using your personal data in certain ways, which include direct marketing and processing based on legitimate interests, on grounds which are specific to your particular situation; and

• where we rely on your consent to process your personal information, to withdraw such consent.

If you wish to exercise any of the rights set out above, a request should be made in writing to David Blake. Please note that we may, where permitted by law, reject any such request or limit the scope of our response (for example, if, in the circumstances, any such right does not apply to you).

You will not have to pay a fee to exercise any of the rights set out above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We endeavour to respond to all legitimate requests within one month. Occasionally, it could take us over a month if your request is particularly complex or you have made a number of requests. If this is the case, we will notify you and keep you updated as to the status of your request(s).

15. Contact us

The Karta Initiative is incorporated in England and Wales as a charitable incorporated organisation (charity number 1173020), as well as in India (the Karta Initiative India Foundation). Find out more about Karta.

If you have any questions about our privacy policy or information we hold about you, you can:

Email: info@karta-initiative.org

Telephone: 01865 435 182

Write to: David Blake, 177 Woodstock Road, Oxford, OX2 7NB

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues. Details of how to do so can be found on its website.

16. Glossary of legal terms

Performance of a 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.

Legitimate interest means the interest of our charity in conducting and managing our charity to enable us to provide you with the best service and the best and most secure experience in your dealings with use. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

To protect your vital interests means to protect an interest which is essential for your life for example emergency medical care.