Portal Privacy Policy

Welcome to The Global Pathogen Analysis Service Ltd (“we”, “our”, “us”)’s privacy policy.

This policy describes how we collect and use your personal data during your use of the Global Pathogen Analysis System (GPAS) portal (portal.gpas.ox.ac.uk) (the “Portal”), in accordance with data protection legislation.

IMPORTANT INFORMATION AND WHO WE ARE

  • This privacy policy aims to give you information on how we collect and process your personal data through your use of the Portal, such as when you sign up to our service or contact us. We are known as the “controller” for your personal data for these purposes and responsible for looking after it in accordance with the Data Protection Act 2018, and where applicable, UK GDPR. It is important that you read this privacy policy together with any other privacy policy 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 personal data.
  • If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by email at info@gpas.global or by post at 128 City Road London EC1V 2NX.

 

THE DATA WE COLLECT ABOUT YOU

  • Where we refer in this policy to your ‘personal data’, we mean any information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).
  • Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion or retention.
  • Type of data we collect about you:
  • Identity Data includes title, first name, last name, username or similar identifier, job title.
  • Contact Data includes email address and telephone number.
  • We also collect, use and share aggregated data such as statistical or demographic data (“Aggregated Data”). Although aggregated Data may be derived from your personal data it will not be personal data as it will not directly or indirectly reveal your identity.
  • We do not collect any special category 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.

 

HOW WE COLLECT YOUR DATA

  • Where we need to collect personal data by law, or under the terms of a contract we have with you or the organisation you work for, and you fail to provide that data when requested, we may not be able to provide you with access to the Portal and our services.
  • We collect data from and about you through direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you sign up for a user account for the Portal.

 

HOW WE USE YOUR 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 you.
  • 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 obligation.
  • In the above:
    • 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). 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.
    • 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

  • We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases under the Data Protection Act 2018, and where applicable, UK GDPR we rely on to do so. We have also identified what our 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 us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been stated.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register and provide access to your user account Identity Data

Contact Data

 Performance of a contract with you
To submit sample data to the Portal and receive results Identity Data

Contact Data

 

 Performance of a contract with you

Necessary for our legitimate interests (to develop the Portal and the services)
To allow for organisations on the Platform to share data and contact you where you are the nominated point of contact for a sample Identity Data

Contact Data

 Performance of a contract with you

Necessary for our legitimate interests (to develop the Portal and the services)
To use the Portal to view uploaded data/analysis results Identity Data

 

 Performance of a contract with you

Necessary for our legitimate interests (to develop the Portal and the services)

 

  • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

SHARING YOUR DATA WITH THIRD PARTIES

  • We may share your data as set out in the table above with third parties such as:
    • service providers such as the University of Oxford and Oracle acting on our behalf based inside and outside the UK who help us to operate and secure the GPAS portal services; and
    • other organisations on the Portal based inside and outside the UK who share data, where your organisation has opted in to do this and you are nominated as the point of contact for a sample.
  • All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies and the law. We permit them to process your data only for specified purposes and in accordance with our instructions. We do not allow them to use your data for their own purposes.
  • We may also share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our site terms of use or to protect the rights, property or safety of our site, our users, and others.
  • Where your data is shared with third parties, we will seek to share the minimum amount necessary.

 

WHERE WE STORE OR USE YOUR DATA

  • We may store data collected by the Portal manually or electronically. The data is stored by us in the UK. We may transfer your personal data outside the UK.
  • If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
    • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
  • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
  • Data traffic retrieved externally is protected using a secure connection.

 

THIRD PARTY WEBSITES

  • Our Portal may contain links to the Oracle Help Centre and for some users the Oracle Analytics Cloud. 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 Portal, we encourage you to read the privacy policy of every website you visit.

 

RETAINING YOUR DATA

  • We will only retain your data for as long as we need it to fulfil the purposes we collected it for, as well as any relating to legal, regulatory, tax, accounting, or reporting requirements.
  • 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, regulatory, tax, accounting or other requirements.
  • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you), e.g. Aggregated Data, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

YOUR RIGHTS

  • Under certain circumstances, by law you have the right to:
    • Request access to your data (commonly known as a “subject access request”). This enables you to receive a copy of your data and to check that we are lawfully processing it.
    • Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your data. This enables you to ask us to delete or remove your data under certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have 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 data where we are relying on our legitimate interests (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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
    • Request the transfer of your data 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.
  • Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. Further information on your rights is available from the Information Commissioner’s Office (ICO).
  • If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, you should email us at info@gpas.global. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the Data Protection Act 2018, and where applicable, UK GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
  • If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.

 

CHANGES TO THIS POLICY AND YOUR DUTY TO INFORM US OF CHANGES

  • We keep our privacy policy under regular review. This version was last updated on 3 November 2022.
  • Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
  • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.