Privacy Policy

1. About us

ARIA is the data controller in respect of your personal data. This means we are responsible for deciding how we hold and use personal data about you.

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 which we have grouped together as follows:

• Identity Data includes first name, last name, title, gender, job title, photographs and video recordings, information about the organisation that you represent / place of work, your professional location, and in some circumstances (for example where we need to arrange accommodation or to facilitate security checks at a venue), passport and/or other photo identification details.
• Contact Data includes email address, address (including of the organisation that you represent) and telephone numbers.
• Financial Data includes bank details and details about payments to you.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser language, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website. 
• Profile Data includes your subscription preferences, feedback and survey responses, as well as opinions, ideas, comments and questions, as well as any personal data within any other information provided by you and, in respect of, grant applications, personal data included in CVs or the applications in general.
• Usage Data includes information about how you use the Website.
• Marketing and Communications Data includes your preference in receiving marketing from us and your communication preferences.
• Board Member Data includes information relating to actual, potential or former non executive board members of ARIA, which may include details of your participation in ARIA’s affairs as a non executive board member such as your attendance at and contribution to meetings, voting records and any other information which is required to be recorded about you by law or which we hold in relation to your role or which we may acquire in connection with discussions relating to a potential role.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Data with your personal data so that we can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (i.e. 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) expect in very limited circumstances where you might voluntarily provide such information to us (for example, if you were to inform us of any dietary requirements in connection with religious or health reasons, or particular access requirements due to any health reasons (for example if you were to be attending an
event that we organise), or in order to contribute to our understanding of applicant diversity) in which case your provision of the information would indicate your consent to us using the information for the purposes given. Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

3. How is your data collected?

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

Direct interactions:

You may give us your Identity, Contact and Financial Data by filling in the contact or other form (whether via the Website or otherwise) or by corresponding with us by post, phone, email or otherwise (such as social media platforms). This includes personal data you provide when you:

• contact or correspond with us about the services (including our programmes) we provide such as grant funding; 
• contact or correspond with us about products or services that you or the organisation that you represent provide; 
• request marketing information to be sent to you; 
• contact us generally; or 
• in the case of Board Member Data, when you first become a non executive board member or discuss with us potentially becoming a non executive board member, and during your time as a non executive board member. 

Automated technologies or interactions: 

As you interact with the Website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

For example:

• We use Hotjar, a technology service that uses cookies and
  other technologies to collect data on our users’ behaviour and their devices, including Technical Data and Usage Data; 
• We may trial and implement other technologies that assist us to provide digital services or enhance and support the way we interact with you. If this is the case, these technology providers may also use cookies and other tracking technologies.

Technology providers that we use may also anonymise and aggregate information gained through usage of their tools for service improvement purposes.

Third parties or publicly available sources:

We will receive personal data about you from various third parties as set out below:

• Technical Data and Usage Data from analytics providers such as Google and Hotjar. 
• Identity, Contact and Special Category Data from our third party service providers (such as third party booking sites) who collect such data on our behalf.
• Identity and Contact Data from publicly available sources such as Companies House, Electoral Register and social media platforms such as X (previously known as Twitter), LinkedIn and Substack. 

4. How we will 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 the performance of a task carried out in the public interest or in the exercise of official authority vested in ARIA.
• 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.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We describe below all the ways we plan to use your personal data, the legal bases we rely on to do so, and how long we will keep such data. Where our legal basis is a performance of a task in the public interest, exercise of official authority or other legitimate interest, we provide further details of this.

Note that we may process your personal data for more than one lawful ground depending on the purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one is set out below.

5. Marketing and opting out

You will receive marketing communications (such as newsletters, updates about ARIA or information about any updating workshops or events) from us if you have requested this from us and you have not subsequently opted out of receiving that marketing.

You can ask us to stop sending you marketing communications at any time by following the opt out links on any marketing communications.  Where you have opted out from receiving marketing communications, this will not apply to the processing of personal data for any other purpose. 

6. Cookies

We use cookies on the Website. For more information about the cookies we use, please see our Cookie Policy. 

7. Disclosure of your data

We may share your data with our professional advisors (including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services) and our service providers or suppliers (for example, our hosting provider or IT support). 

We require all our service providers and suppliers to take appropriate and stringent security measures to protect your personal data in line with our policies. Except as set out below in relation to Hotjar. We do not allow our technology suppliers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions. 

We will share your data if we are required to do so by law – for example, by court order, or to prevent fraud or other crime.

The data we collect with Google Analytics cookies is transferred to and stored with Google where we analyse it with Google Analytics software (Universal Analytics). We do not allow Google to use or share this data for their own purposes.

The data we collect with Hotjar cookies is transferred to Hotjar and stored by them on our behalf in a pseudonymized user profile.

Hotjar may use your data for their own purposes, including to:

• compile and use your data, strictly in order to research, develop, modify, improve or support the services provided by Hotjar and its affiliates;
• use your data in an anonymous or aggregated form where no such information could directly identify or will reasonably be used to identify you for benchmarking or machine learning purposes; and
• collect and use data, information, or insights generated or derived from the use of the Hotjar products and services for its business purposes, including industry analysis, analytics, marketing, and developing, training and improving its products and services. 

We will not, and do not permit any of our service providers and
suppliers (including Hotjar) to:

• sell or rent your data to third parties.
• share your data with third parties for marketing purposes.

8. How long we keep your data

We will only retain your personal data for as long as it is needed for the purposes set out in this document or for as long as the law requires us to. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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. Details of retention periods for different aspects of your personal data are set out below with further detail available in our retention policy which you can request from us:

We will:

• keep your email data until you unsubscribe.
• keep your feedback data for 2 years.
• delete access log data which contain your IP address after 120 days.
• keep your business contact details during our business relationship and as required afterwards for business records purpose.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

9. 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. 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.

10. Where your data is processed and stored

We design, build and run our systems to make sure that your data is as safe as possible at all stages, both while it’s processed and when it’s stored.

The personal data we collect from or about you may be transferred to, processed and stored, at destinations outside the UK (for example, the US).  

Whenever 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 as 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. 

11. How we protect your data and keep it secure

We are committed to doing all that we can to keep your data secure. We have set up systems and processes to prevent unauthorised access or disclosure of your data – for example, we protect your data using varying levels of encryption.

We also make sure that any third parties that we deal with keep all personal data they process on our behalf secure.

12. Other websites

The Website may contain links to another website. We do not control such websites and are not responsible for their privacy statements. This policy only applies to the Website so when you follow a link to other websites you should read their own privacy policies.

13. Your rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights: 

• Request access to your personal data (commonly known as a 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 your personal data. 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. 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, or where we have processed your data in carrying out a task in the public interest.
• Object to processing of your personal data where we are relying on carrying out a task in the public interest, or a legitimate interest (or that of a third party) and you want to object to the processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may have compelling legitimate grounds to process your data which override your rights and freedoms. 
• Request restriction of processing your personal data. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful (but you do not want us to erase it), we no longer need your personal data for the purposes for which we hold it (but you need it to establish, exercise or defend legal claims) or you have objected to our use of your data but we need to verify whether we have an overriding legitimate ground to use it (where we are carrying out a task in the public interest or our legitimate interests). Notwithstanding the aforementioned, we may continue processing your data for reasons of important public interest.
• Request 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. 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 
• Right to withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us.

Most information will be provided free of charge. However, we may charge an administrative fee if your request is clearly unfounded, repetitive or excessive.

Any charges we make will be justified, transparent and kept to a minimum. 

You should:

• outline your request as clearly as possible;
• provide any dates, if relevant;
• give names and organisations, if relevant; and 
• state the format in which you would like this information (hard copy or electronic).

We may need request further information from you to help us confirm your identity and ensure your right to exercise any of your 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.

In return we will:

• respond to acknowledge your request has been received.
• act on your request within one month, as required by data protection legislation. If the request is particularly complex and will take longer to resolve, we will write to tell you this.
• write to tell you if your request is not applicable, and provide reasons why.

We may also refuse to comply with your request if it is manifestly unfounded or excessive.

14. How to contact us and complain

If you have any questions about this policy or how we handle your personal data, please contact us or email our Data Protection Officer at dpo@aria.org.uk. 

If for any reason you are not happy with the way we have handled your personal data, please contact us via our contact form. 

If you are still not happy, you have the right to make a complaint to the Information Commissioner’s Office at casework@ico.org.uk

15. Changes to this policy

We keep this policy under regular review and will post any updates on the Website. 

This policy was last updated in March 2025.