Privacy Policy

Who Are We?

GenPlus is a charitable body registered in Scotland (registration number SC05061), (“we”) aim to equip the next generation of young people to follow their passions and dreams, not ours. To enable 290,000 secondary school pupils to create 290,000 new projects that will change the world. To enable them to be job creators not just employees.

Our vision is for the long term, to support a new generation with the leadership skills and decision-making ability to follow their hearts and create the future. To help them deal with the complexity of a world that still faces enormous challenges in poverty, equality, diversity, the economy and social justice.

It’s a project supported by our ability as a foundation to invest for the long term and measure success in the same timescale.

The only return on our investment that we require is the success of this next generation of young people. To know that we have helped to create the best leaders in the world in the best small country in the world.

For data collected under this privacy notice, GenPlus is the Data Controller (as that term is defined in the EU General Data Protection Regulation (Regulation (EU) 2016/679)), registered with the Information Commissioner’s Office, Registration Number ZB142840.
As part of our GenPlus programme, we will need to collect and process certain information from you.

All applications provided by GenPlus comply with GDPR and the Data Protection act 2018 as well as other UK laws. The application and its data is hosted on industry standard open source systems, housed within Amazon Web Services cloud Data Centres in the UK and the EEA.

About You

This privacy notice uses “you” to mean any individual about whom we collect and hold personal data for users involved in Local Authorities and Schools, and we manage personal data relating to teachers and students past and present.

You are entitled to be informed of what data we will hold and how we intend to use that data. This Privacy Statement informs you of what data we collect, why we collect it and the lawful conditions we consider appropriate for the processing of your personal data.

This Notice including Cookies (see below section) apply to all visitors to and users of:

GenPlus Programme application (accessed via Glow account);
The GenPlus website at www.genplus.co.uk (the “Website”);
Any website that links to this Notice and/or our Cookies Policy;
GenPlus social media accounts.

This means the notice is applicable to anyone contacting us by phone, SMS, email, in letters and other correspondence, in person and via social media.

Data Controller and Contact Details

We are registered as the data processor and controller. Our charity registration information is GenPlus Registration SC050610. Our registered office is Pioneer House Renshaw Place, Holytown, Motherwell, Scotland, ML1 4UF. Our Information Commissioners Office Registration Number is as follows: ZB142840.

If you have any questions regarding the use of your personal data, please contact us at: dpo@genplus.co.uk

Data Protection Officer, Pioneer House Renshaw Place, Holytown, Motherwell, Scotland, ML1 4UF

If you wish to request access to any of your personal data held by GenPlus, please email DPO at dpo@genplus.co.uk.

Changes to this privacy notice

We regularly review the terms of this privacy notice, which we may amend from time to time. If we make any substantial changes, we will notify you by posting a prominent notice on our website.

What Data Do We Collect and Why?

We may collect, store and process the following types of personal data relating to you through our Website, online enquiry forms including social media, or by telephone or email.

Information that you provide to us if enquiring about the GenPlus programme or services from us, including name, email address, contact number, if you are connected to a school, local authority or are a parent/carer and IP address.

GenPlus application holds the personal data of individuals provided to us by Glow and using the services you select to use and provide us with consent. Your personal data is securely provided to us by Glow and their sub-processors, we hold only those details relevant to the services provided by Gen+’s and are held securely in our databases within the UK and in accordance with Data Protection Law, and is subject to appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss or destruction of, or damage. We will not hold your information more than 1 year after the GenPlus application user has closed their account on the platform. The Legal Basis for processing the Personal data we collect from you will be used for the purposes it was provided, including the following, which are:

Consent
Legitimate Interest

Should you wish to be removed from our database or advise us of an amendment to your preferences you can do so by sending an email to hello@genplus.co.uk

Facebook and other social media accounts may automatically give us access to your limited personal information; they do this to verify you are logged in with their site. Once you use our website your data is used by us in line with this privacy notice and cookie policy. We cannot be held responsible for Facebook or any other social media site and how they use your data. If you have any concerns, we recommend you review their privacy notices or policies.

Images

We may from time-to-time capture consent to use images of you in video promotions or still pictures

The legal basis for this is:

Consent

If an image can be used to identify a living individual, that image is therefore likely to constitute personal data. This includes where individuals in an image are named, and also covers situations where no names are used but other contextual information would enable individuals to be identified.

Should you wish to have us stop using your likeness if it has been used then please contact us and we can take action to stop it from being used further.

Communications

From time to time, you may have a need to communicate with us. As part of this process, you may be needed to provide personal data to us such as your name, address, contact details. We will use this to deal with your communication.

The legal basis for this is:

Consent
Legitimate interest

The reasons for communication with us may include:

To respond to a survey
To make a complaint
To enquire about working with us

Website Services

We offer a ‘Contact us’ form to provide a mechanism for you to get in touch and learn more about the Gen+ programme. The form collects your Name, Email address, if you are connected to a school, local authority, or a parent or carer and message – this data is sent to the Gen+ systems to process.

Also, to improve our Website and services, we may use details of your activity on our Website and interactions with us such as system version, device type browser details, details and your interactions with us.

Legal Basis:

Legitimate Interests
Consent

These are used so we can:

Manage the Website and related services such as problem-solving, data analysis, testing, research, produce surveys and developing the Website and our products and services.
We use the information to assist us in developing relevant content on the Website.
Provide customers who have opted-in to receive communications, with relevant information by email
Use website analytics tools as described further in our Cookie Policy.

Legal Basis

Under data protection laws, we are required to have a legal basis to process your personal information. We have set out below the legal bases we rely on:

Consent: The data subject has given permission for GenPlus to process their personal data for one or more processing activities. Consent must be freely given, clear and easy to withdraw.
Legitimate interest: This is a processing activity that a data subject would normally expect from GenPlus where personal data is given for activities like marketing interests in our programme and services.

Gaining consent

We may be required to gain consent when it comes to processing certain types of your personal data. This consent as detailed above must be clearly given. Consent can relate to using the website or marketing communications.

If you have given consent for us to process your personal data you also have the choice to withdraw that consent. This can be done by emailing: dpo@genplus.co.uk

Sharing Personal Data

We will not share your information with 3rd party organisations. Your data is processed by approved 3rd party data processors. They will never contact you with marketing or promotional offers.

Your personal information may be processed outside the European Economic Area (EEA) where privacy laws may not provide protection to the same level as in the UK.

Before any transfer takes place, we will take steps to make sure your personal information will be adequately protected, as required by the UK Data Protection Act. This may include contractual safeguards.

There may be circumstances when we are legally obliged to share your personal data e.g.

To the extent that we are legally obliged to do so by law.
In connection with any ongoing or prospective legal proceedings.

In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information, wherein our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Security and storage of personal data

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. The GenPlus website uses a security system that protects your information from unauthorised use.

Your Rights

As a result of GenPlus processing your personal data you have a number of individual rights:

You may instruct us to provide you with any personal information we hold about you, via a Subject Access Request – Upon receipt of such a request, we will, after confirming identity provide all relevant data we may hold about you, in the most practical format and as soon as possible. We may withhold personal information that you request to the extent permitted by law.
You may instruct us to correct any inaccuracies in that personal data which we will do as quickly as possible.
You may instruct us to no longer process your personal data for marketing or any other purposes, which we will do as quickly as possible.
You may instruct us to destroy some/all of your personal data which we will do as quickly as possible. (The Right to be Forgotten)
You may in certain circumstances request that your data is transferred to another service provider. (The right to Data Portability)

Retention

The time we keep personal information depends on why we have it and how we use it:

We keep records of your dealings with us for up to six years after the last contact, to respond to any complaints or disputes if they arise
We’ll keep other personal information about you if it’s necessary to comply with the law

Cookies

The GenPlus website uses “cookies” to help improve your online experience.

A cookie is a text file that is placed on your hard disk by our web page server. Cookies cannot be used to run programs or deliver viruses to your computer and are safe

Cookies are uniquely assigned to you and can only be read by a web server in the GenPlus domain that issued the cookie to you.

None of the cookies on our web site collect or store personal data. We only store standard internet log data for our internal reporting purposes. We do this to find out things such as the number of visitors to the various parts of the GenPlus Website. We collect this information in a way which does not identify anyone, keeping your privacy as well as allowing us to improve the website wherever possible.

The GenPlus website collects some personal/identifiable information as part of the ‘requesting information’ process but this is always done by asking you the user to enter details. We will never capture personal information without making you aware first and with your consent.

You still have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the GenPlus services or Website.

Google

We use Google Analytics to carry out statistical analysis of page use, page interactions and paths through the Website to evaluate and develop our Website. This is known as ‘digital analytics’. We may also record certain information that customers provide during a Website purchase or other process.

This information allows us to understand individual behaviours and needs more accurately. For more information on how Google uses the data collected via this service, see here: http://www.google.com/policies/privacy/partners/.

To opt out of being tracked via Google Analytics, you can also use Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.

Complaints

If you are dissatisfied with any aspect of our handling of your personal data, then you can make a complaint to dpo@genplus.co.uk. If you are still dissatisfied after your response you can complain to the Information Commissioner’s Office, their contact details are listed on www.ico.org.uk.