Privacy notice information for the Greater Manchester Electrochemical Hydrogen Cluster

This privacy notice describes how we collect and use personal information related to the Greater Manchester Electrochemical Hydrogen Cluster (GMEHC) project beneficiaries during and after your relationship with us.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your information.

Who we are

The GMEHC is a partnership between Manchester Metropolitan University, The University of Manchester and National Physical Laboratory (NPL). It is funded by the Innovate UK Accelerator programme.

The GMEHC partners are all “data controllers”. This means that we are responsible for deciding how we hold and use personal information about you as a beneficiary. 

What information does the GMEHC collect?

Personal data means any information about an individual from which that person can be identified. 

The types of information we hold about you includes:

• personal contact details such as your name, title, address, telephone numbers, email address, information from due diligence checks e.g., directorships and other relevant business interests.
• age bracket and gender (where applicable).
• records of your attendance and participation at our online/virtual meetings and sessions.
• information about the requested business support needs, and potential provision and assistance agreed with you.
• correspondence with or about you.
• financial information about your company for due diligence purposes (e.g. turnover, pre-tax profit) and evaluation purposes (e.g. for Innovate UK as funders, to monitor the impact of public funding on businesses).
• photographs for use in marketing.

We may also hold the following categories of more sensitive personal information: equality monitoring information such as information about your marital status, ethnic origin, sexual orientation, religion or belief.

Most of the information we hold about you will have been provided by you, but some may come from other external sources and intermediaries, such as referrals from the Growth Hub; Chambers of Commerce, GMCA, Innovate UK, etc. Data will be stored on a project-specific Sharepoint, accessible by the project partner staff involved in GMEHC, and in other IT systems, such as the GMEHC partners’ email, internal storage system and project-based CRM system, e.g Salesforce.

Why does the GMEHC process personal data? 

This section includes an explanation of our lawful basis for processing. 

Our core purpose is to conduct research and innovation into the use and advancement of hydrogen systems for the benefit of society and the environment. As a public authority acting in the public interest, we rely upon the public task lawful basis to pursue this aim. 

Where applicable for research and development projects to enter into a contract with you and to deliver our agreed contractual services. For example, providing you with the agreed business support services. i.e. to get innovation ready and provide technical support. 

Processing your personal data allows the project to:

• determine the type of support you require to develop a new product/service, or prior to this, support for your business to become innovation ready.
• make claims to funders supporting the projects.
• maintain accurate and up-to-date project beneficiary records and contact details.
• operate and keep a record of support provided through and funded by its project.
• provide referrals where applicable and appropriate to other business support agencies we believe could help you and your business.
• to comply with legal obligations, for example, subsidy control legislation.
• maintain and promote equality in the workplace.
• undertake business management and planning, including accounting and auditing.
• maintain contact with you to ascertain the impact and results of the support provided.
• obtain feedback and conduct evaluations to enable the development and improvement of our projects (current and new).
• ensure network and information security and compliance with information and communication policies.
• comply with requirements from Innovate UK as the funding body to carry out checks and audits on the grant beneficiaries.

Where we process special categories of personal information, such as those relating to your ethnicity, religious beliefs, sexual orientation, disability, or gender identity, this is done for the purposes of equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds, which justify our use of your personal information.

We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you if this position changes.

Who has access to data?

Your information may be shared with project delivery partners, including: Manchester Metropolitan University, The University of Manchester, National Physical Laboratory (NPL) as well as Innovate UK.  

We will only disclose information about you to other third parties if we are legally obliged to do so or where we need to comply with our contractual obligations, for instance we may need to pass on certain information about you to the relevant funding bodies supporting the Unit and its Projects. 

The GMEHC also shares data with third parties that process data on its behalf, for example consultants and auditors. 

How does the GMEHC protect data?

The GMEHC takes the security of your data very seriously and has internal policies and controls in place to try and ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

Where the GMEHC consortium asks third parties to process data on its behalf, for example consultants or evaluators, they do so on the basis of written instructions, are under a duty of confidentiality and must ensure that they have appropriate technical and organisational measures in place to keep the data secure.

How long does the GMEHC and the University keep data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, contractual or reporting requirements.

Your personal data will be stored throughout your involvement with the GMEHC project, and for a period afterwards: due to funding requirements all data will need to be retained until at least 31st December 2035 or until notified by Government that records can be destroyed. 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once project records are no longer required contractually and/or for statutory purposes, we will securely destroy your personal information in accordance with our data retention policy.

What if you choose not to provide personal data?

Certain information, such as contact details, your eligibility to work in the UK etc. are required to allow the GMEHC to enter a contractual relationship with you as project funding streams have eligibility criteria that must be complied with.

You have certain obligations under your beneficiary contract to provide the GMEHC with data. For example, to ascertain eligibility to access funding support; ascertain previous subsidy awards, etc.
Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Data subject rights

As a data subject, under data protection legislation, you have various rights in relation to your personal data. You can:

• request access to your own data by making an access request – this enables you to receive a copy of the personal information we hold about you and check that we are lawfully processing it;
• request that we correct any inaccuracies in the data that we hold about you;
• request that we erase your personal data where we are not entitled by law to process it or it is no longer needed for the purpose it was collected;
• request that processing of your data is restricted – this enables you to ask us to suspend the processing of personal information about you, for example if you want to establish its accuracy or the reason for processing it;
• object to processing of your personal information where we are relying on our legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground;
• request the transfer of your personal information to another party.

In most situations we will not rely on your consent as a lawful basis for processing your data. If we do request your consent to process your data for a specific purpose, you are under no obligation to provide it and you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing before your consent was withdrawn.

If you wish to make an access request or assert any of the rights detailed above, please contact the Data Protection Officer using the contact details below.

Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) as the supervisory authority in respect of the processing of your personal data. We would encourage you to expend our internal complaints procedure through our initial contact and the University Data Protection Officer, prior to contacting the ICO.

If you wish to contact the ICO the following contact information can be used:  

• Emaill: [email protected]
• Telephone: 0303 123 1113

For any further contact information please go to the ICO website.

Contacting us

For questions or concerns about this Privacy Notice or how we store and use your personal information, please contact the GMEHC consortium by emailing [email protected] in the first instance. 

Alternatively, please contact the Data Protection Officer based in the relevant GMEHC partner organisation. The University’s Data Protection Officer can be contacted by emailing [email protected] or by writing to: Data Protection Officer, Legal Services, Ormond Building, Manchester Metropolitan University, Manchester, M15 6BH. 

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.