Version 3, revised January 2023
This website (‘the site’) is operated by the Bingham Centre on behalf of the British Institute of International and Comparative Law (BIICL) for the purposes of the operation of the Modern Slavery and Human Rights Policy and Evidence Centre (Modern Slavery PEC; the Centre). The Modern Slavery PEC is funded by the Arts and Humanities Research Council and is led by the Bingham Centre on behalf of BIICL, in collaboration with the Alan Turing Institute, the University of Hull, the University of Liverpool, the University of Nottingham and the University of Oxford.
This privacy policy details how BIICL and the Modern Slavery PEC use the personal information we collect, including but not limited to the information we collect through this site. We are committed to protecting your privacy and take all reasonable precautions to safeguard personal information. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data. We strive to be as transparent as possible about how and why we use your personal data. We are committed to complying with the requirements of the UK Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003, the UK General Data Protection Regulation and (where relevant) the EU General Data Protection Regulation 2016. This privacy policy does not cover the content of any external websites linked to from this site. We therefore encourage you to read the privacy policies on any external websites that you visit.
Who are we?
The Modern Slavery PEC is a part of the British Institute of International and Comparative Law (BIICL), a registered charity (no. 209425) that provides informed, independent and practical legal ideas for a global community. We are located at Charles Clore House, 17 Russell Square, London WC1B 5JP. You can contact us by post at the above address, by email at office@modernslaverypec.org or by telephone on +44 (0)207 862 5151.
We are registered as data controllers with the Information Commissioner's Office under the Data Protection Act 1998, registration number Z8167581. BIICL is the parent company of the Bingham Centre, a subsidiary with the responsibility of leading the Modern Slavery PEC.
What kind of information do we collect?
We collect information both through this website and through our other work. This policy covers both.
Sign-up details: if you sign up for events or for our newsletter, either through the site or through a third party service that we use, such as Eventbrite, we may ask you for personal information such as your name, email address, occupation and/or other contact details.
Tender/submission/funding application details: if you submit a tender to provide any services, or apply for funding or support from the Modern Slavery PEC, or submit an idea through our Research Ideas Form, we may ask for personal information that we will use to process your tender/submission/application. You will be asked to agree to specific terms and conditions regarding that information at the time of making the tender/submission/application.
Job application details: if you apply for a job at the Modern Slavery PEC, or as part of an affiliated advisory group or similar that is managed by the Modern Slavery PEC, we will ask for personal information that we will use to process your application. You will be asked to agree to specific terms and conditions regarding that information at the time of making the application.
Feedback: we may ask you for feedback about BIICL, the Bingham Centre, the Modern Slavery PEC or our partners or to complete surveys.
Online activity: we collect anonymous analytics data to better understand how visitors are using the website, using a service called Plausible. Plausible is a privacy-focused web analytics provider. We do not track, collect or store any personal data or personally identifiable information through Plausible. We do not use cookies. All the data we collect is in aggregate only.
Your communication with us: if you send us email, or communicate with us in another way, whether that is with the Modern Slavery PEC, our partners, the Bingham Centre or BIICL, we may store your personal information (such as your name, email, job title and organisation) as well as a record of our communications with you.
Equality, diversity and inclusion data: if you submit a tender to provide any services, apply for funding or support from the Modern Slavery PEC, submit an idea using the Research Ideas Form or attend any events we may ask for you to complete an anonymous equality, diversity and inclusion form, and your information will be stored internally and may be shared externally in aggregate (e.g. as part of the Modern Slavery PEC’s public reporting or for research purposes). Equality, diversity and inclusion data includes data on your personal and professional characteristics. You can choose not to submit this information.
How do we collect information?
Directly: we collect some information directly, such as when you sign up for our newsletter or complete a survey and we request certain information from you.
Third-party processors: we sometimes use third-party platforms and processors (such as Eventbrite or MailChimp) to collect and store individuals’ contact details and our communications with them, as well as to deliver newsletters, process applications, event registrations or payments, and administer surveys. In using these third parties we are pursuing our legitimate interest to use third-party technology to achieve greater efficiency within our organisation. To balance our interests against yours, we have taken steps to verify that these third parties maintain appropriate technical and organisational measures to keep your personal information secure.
What do we do with the information we collect and what is our legal basis for this?
Events: if you register to attend one of the Centre’s events, we will use your personal information to process your application to attend the event, take payment, if any, for our administration and management of the event and to send you any updates or information regarding the event. Our legal basis for doing so is to fulfil the agreement with you for your attendance.
We use Eventbrite as the registration system for some of our events and their servers are based in the USA. Eventbrite may store and process your information outside the European Economic Area (EEA). If you wish to know more please see https://www.eventbrite.co.uk/support/articles/en_us/troubleshooting/eventbrite-privacy-policy.
If you buy a ticket for an event, we will use third-party payment processing organisations to take your payment. These organisations will be the data controller of your information for the purpose of processing those transactions, which may involve your information being processed outside of the EEA. Please read the terms and conditions before completing your payment.
Research call application details: we will use your personal information to process any applications you make to the Modern Slavery PEC, whether through this site or via a third-party processing service. We undertake this processing because it is necessary to fully assess your application, and if successful, to take steps to enter into an agreement with you (this is our legal basis for the processing). We store your contact information, if you are successful, so that we can share future relevant updates and opportunities with you. We may also ask for your permission to store your contact details if you are unsuccessful so that we can share future relevant updates and opportunities with you.
If you apply to the Modern Slavery PEC for any funding or support, you may be directed to another platform to process these applications. Some of these platforms may be managed by third parties other than the Modern Slavery PEC or BIICL, and further details will be given to you when you start the application. Please ensure you read the terms and conditions of those platforms when using them.
Job application details: we will store and use your information in order to process your job application and, if you are successful, to enter into an agreement with you (this is our legal basis for processing). We will store your information if you are unsuccessful, for a period of up to 12 months, for purposes of statistical analysis that can help improve our hiring processes. We may also ask for your permission to store your contact details for a longer period so that we can share future relevant updates and opportunities with you.
If you apply for a job, you may be directed to another platform to process your application. Some of these platforms may be managed by third parties other than the Modern Slavery PEC or BIICL, and further details will be given to you when you start the application. Please ensure you read the terms and conditions of those platforms when using them.
Feedback and surveys: if you agree to give us feedback or complete a survey, we will use the information to improve our work and activities, and may report on this publicly in aggregate. We will contact you if we would like to attribute any feedback to you directly. We usually use Submit.com or Microsoft Forms to process surveys, and they only process your information on our instructions. For more information, please see the Submit.com privacy policy, the Microsoft privacy statement and information about privacy and security in Microsoft Forms.
Research participation: If you agree to participate in any research funded by the Modern Slavery PEC, such as through completing a survey, you will be told at the time you take part how your information will be used for the particular research project or programme, and how long it will be kept for. Where research is undertaken by a third party who is funded by the Modern Slavery PEC, responsibility for any data collected as part of that research will sit with the third party.
If you agree to take part in any research that the Modern Slavery PEC conducts, we will use your information for the purpose of that research project or programme. Full details of how your personal information will be used will be given to you at the time you agree to participate.
Online activity: as noted above, we collect aggregated, anonymous data to track activity on this website using a service called Plausible. We use that data to monitor, review and improve this site. We do not share or sell any of this anonymous analytics data with third parties, except with Plausible for the purpose of using their services.
Your communication with us: we store personal information relating to your communication with us in order to keep track of our stakeholders and our engagement with them. This helps us understand who we are engaging with and what we can do to build and strengthen our networks over time, in order to improve the reach and impact of our work. We may use a third-party provider to store the personal information we collect from your communication with us. Our legal basis for doing so is our legitimate interest in increasing our organisational efficiency by storing contact details of engaged stakeholders in a format that is secure and accessible. Our normal third-party provider for this service is HubSpot, inc. (www.HubSpot.com). For more information about HubSpot’s data security measures, please see here: https://www.HubSpot.com/security. For more information about how and when HubSpot may transfer data that it holds outside of the EU, please see here: https://www.HubSpot.com/data-privacy/privacy-shield.
Equality, diversity and inclusion data: we will use this data anonymously to monitor the diversity of stakeholders the Modern Slavery PEC engages with and inform our future work and report against our EDI objectives. It may be used in aggregate within research or other activities undertaken by the Centre but this data will not be used in any application or review processes.
Marketing
If you sign up to the Modern Slavery PEC’s newsletter, we will use your details to keep you informed about developments including the latest news, blogs, programme updates, research, publications, event details, jobs and funding opportunities, and may request feedback.
We use third-party providers, MailChimp and HubSpot, to deliver our newsletters. We gather statistics around email openings and clicks using industry standard technologies to help us monitor and improve our newsletter. Please note that MailChimp and HubSpot use servers hosted in the USA, but comply with the EU-US Privacy shield. If you want to know more about how your information will be stored and processed, see https://legal.HubSpot.com/privacy-policy and https://MailChimp.com/legal/privacy/. If we use any other providers, we will update this policy accordingly.
If you no longer want to receive marketing communications from us, you can unsubscribe from our mailing list at any time by please clicking the unsubscribe link at the bottom of our emails or by emailing office@modernslaverypec.org detailing your name and email address and specifying this is in relation to Modern Slavery PEC marketing.
For all kinds of information collected: please make sure that any personal details you provide are accurate and up to date and let us know about any changes. Please get consent first before giving us anyone else’s information.
The nature of the Modern Slavery PEC’s work means we often work in partnership with other organisations. However, we will not share your information with any other organisation unless we have your permission first, unless we have a legal basis for doing so (see section ‘Who else has access to your information?’ below).
We may also use your information to carry out analysis and research to improve the Modern Slavery PEC’s publications, events and activities, customise our website and its content to your particular preferences, notify you of any changes to our website or to our activities that may affect you, to prevent and detect fraud and abuse, and to protect other users.
However you choose to engage with or support BIICL, the Bingham Centre or the Modern Slavery PEC, we may retain your information for our own legitimate business interests for statistical analysis purposes, in order to review, develop and improve the Modern Slavery PEC’s activities. In this situation, we will only keep any personal information if it is necessary to do so, and will always put in place appropriate safeguards, including where possible anonymising or minimising the data retained.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, and you have shared contact details, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent if required or permitted by law.
How long will we keep information for?
General principle: we will only keep any personal information that you provide to us for as long as is necessary to fulfil the purpose for which you gave us the information and we will securely delete information when it is no longer needed for that purpose, as explained in more detail below. If at any point you want us to delete, amend or stop using the personal information that we hold on you, please let us know by writing to us or emailing us at the contact details below.
Consent: we keep records of consent, and any withdrawal of consent, on our files for as long as your personal information is being used in line with that consent and for a period of 6 years after the consent is withdrawn (unless otherwise requested by you).
Tender/application details: if you tender to provide any services, or apply for funding or support, and you are successful, then we will keep your information for 6 years after the associated agreement has come to an end, or if the agreement was executed as a deed for 12 years. If the project or initiative has any external funding or support, we may need to retain your information for a longer period to fulfil our obligations under those agreements, in which case we will tell you that at the time of application.
If you are unsuccessful in a tender to supply services or you are unsuccessful in an application for funding, once the process has ended we will (if you have given your permission) retain your information for 3 years for evaluation and business development purposes, and to provide you with future opportunities to apply for similar opportunities, funding and support in the future. If you do not wish us to contact you about future opportunities, please let us know by writing to us or emailing us at the at the contact details below.
Job application details: if you apply for a job at the Modern Slavery PEC, or in an affiliated advisory group or similar that is managed by the Modern Slavery PEC, we will retain your information for a period of up to 12 months for statistical analysis purposes and to monitor and improve our hiring processes. If you have given us permission to store your information for a longer period, so that we can send you relevant updates and opportunities, we will retain that data for as long as your personal information is being used in line with that consent (see ‘Consent’ above).
Research: if you agree to take part in any research that the Modern Slavery PEC carries out or funds, your personal information will be kept for as long as it is of value to the Modern Slavery PEC and/or the wider research community, and for as long as may be specified by any external research funder, patent law, or legislative or other regulatory requirements. Research data held by the Modern Slavery PEC will be reviewed at least every 5 years to consider its continued value to the Centre and the wider research community. All personal data used in research that the Modern Slavery PEC conducts will be anonymised or pseudonymised where possible, unless to do so would affect the integrity of the research data and/or its outcomes, or its future value.
To the extent that personal data arising from any research is embodied within a research report or other research outcome, it will be retained in perpetuity as part of the published materials.
We will keep personal data that supports the development of a Modern Slavery PEC project, programme, publication or other research outcome for at least 5 years after publication or after any other research outcome has been completed. If the research is funded or the subject of any other contract, your personal data may be kept for 6 years after the end of the contract or longer if the contract or funding agreement specifies, which could be up to 12 years after the contract ends.
Your communication with us: we will store any personal information we collect as part of your communication with us for as long as it remains of value to the Modern Slavery PEC. However, we will regularly review the personal information that we hold and will securely delete any personal information that is no longer of value to the Modern Slavery PEC. We will conduct such a review at least once every 6 years.
Equality, diversity and inclusion data: we will store this data in anonymised form for as long as it remains of value to the Modern Slavery PEC. However, we will regularly review the data that we hold and will securely delete any personal information that is no longer of value to the Modern Slavery PEC. We will conduct such a review at least once every 6 years.
Who else has access to your information?
We may share your information with the Arts and Humanities Research Council and our partners who we are working together with in relation to the Modern Slavery PEC. For more information, see:
https://ahrc.ukri.org/
https://www.turing.ac.uk/
https://www.hull.ac.uk/
https://www.liverpool.ac.uk/
https://www.nottingham.ac.uk/
https://www.ox.ac.uk/
We may share your information with our partners and with companies who help us to operate this site, and if you register to attend an event or apply to one of our grants or indicate interest in any other activity carried out by the Modern Slavery PEC, we may share your details with the companies/organisations who help us to fund and organise the events, grant programmes and other activities. Our legal basis for doing this is to pursue our legitimate interest of being able to operate and administer the event, grant or activity. Some of these organisations may process your information in countries outside the European Economic Area (EEA), such as the United States, where data protection laws are not the same as in the EEA.
We may share your information within BIICL and the Bingham Centre for the purposes of managing the event, grant or activity. BIICL currently provides a wide range of support and services for its subsidiaries. Our legal basis for sharing your information with BIICL and the Bingham Centre is to pursue the legitimate interests of shared resources and management reporting between the Modern Slavery PEC and these organisations.
If you author a blogpost that we publish on the site it will be displayed publicly. Please be careful when disclosing personal information which may identify you or anyone else. We are not responsible for the protection or security of information which you disclose through a blogpost. We may disclose your personal information to law enforcement agencies if required by law (in which case our legal basis for doing this is for compliance with a legal obligation), or to protect or defend ourselves or others against illegal or harmful activities (in which case, our legal basis for doing this is the pursuit of these legitimate interests).
Security
We take steps to protect your personal information and follow procedures designed to minimise unauthorised access or disclosure of your information. If you have a password for an account on this site or third-party platforms we use, please keep this safe and don’t share it with anyone else. You are responsible for all activity on your account and must contact us immediately if you are aware of any unauthorised use of your password or other security breach.
Contacting us, exercising your rights and complaints
Funder:
- Arts and Humanities Research Council: Polaris House, North Star Avenue, Swindon, SN2 1FL
Partners:
- The Alan Turing Institute, a registered charity in England and Wales (charity number 1162533) and a company limited by guarantee, incorporated in England (number 9512457) whose administrative offices are at the Alan Turing Institute, British Library, 96 Euston road, London NW1 2DB
- The University of Hull, an independent corporation established by royal charter and an exempt charity, whose administrative offices are at Cottingham Road, Hull, HU6 7RX
- The University of Liverpool, an independent corporation established by royal charter (company number rc000660) and an exempt charity (x7758) whose administrative offices are at Foundation Building, 765 Brownlow Hill, Liverpool, L69 7ZX
- The University of Nottingham, an independent corporation established by royal charter (company number rc000664) and an exempt charity, whose administrative offices are at University Park, Nottingham, NG7 2RD
- The University of Oxford, a civil corporation established under common law, and an exempt charity, whose administrative offices are at Wellington Square, Oxford, OX1 2JD
You are legally entitled to know what personal information we hold about you and how that information is processed, which includes the right to:
- Know what information we hold about you
- Ask us to correct any mistakes in your information which we hold
- Ask us to delete your personal information
- Ask us to stop using your personal information or restrict how we can use it, for example if you feel it is inaccurate or no longer needs to be used by BIICL, the Bingham Centre or the Modern Slavery PEC
- To object to us using your personal information
- To object to any automated decision making that we may do using your personal information
If you wish to know what information we hold about you, or wish to exercise any of your other rights as detailed above, or have any complaint about how we are using your personal information, then please email or write to us at office@modernslaverypec.org or Charles Clore House, 17 Russell Square, Bloomsbury, London WC1B 5JP and provide enough information to identify yourself (e.g. name and address or any registration details).
If our information is incorrect or out of date, please provide us with information to update it. If you want us to delete, restrict or stop using any information we hold about you, please explain the reasons why you are asking this. If you are unhappy with how we are using your information, again please explain the reasons and we will investigate the matter.
You can also write to the same address if you have a complaint about this policy.
If you are unhappy with how any data rights request or complaint has dealt with you have the right to complain to the Information Commissioner at Wycliff House, Water Lane, Wilmslow, Cheshire SK9 5AF or at the following link: https://ico.org.uk/concerns. Their helpline number is: 0303 123 1113.
Changes to the privacy policy
We may change this privacy policy from time to time. We will notify you of any changes that relate to information we already hold about you, where practicable. You should check this policy occasionally to ensure you are aware of the most recent version.
British Institute of International and Comparative Law, a company limited by guarantee registered in England and Wales with company number 615025 and charity number 209425.
Registered office: Charles Clore House, 17 Russell Square, Bloomsbury, London WC1B 5JP
Email: office@modernslaverypec.org.