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Tent Partnership for Refugees’ LGBTQ Refugee Mentorship Program – Privacy Policy

PRIVACY STATEMENT
This privacy statement (the “Privacy Statement”) sets out how the Tent Partnership for Refugees (‘we’ or ‘us’ or ‘our’ or “Tent”) will use any information that you give to Tent during the LGBTQ Refugee Mentorship Program.

Tent is a non-profit organization launched in 2016 to mobilize the global business community to support refugees. Tent manages a network of over 170 major companies committed to integrating refugees in their host communities.

Tent is a globally focused organization that is headquartered in the United States. The LGBTQ Refugee Mentorship Program will enable Tent to work with organisations and individuals from multiple regions, including North America, the United Kingdom, Europe and South America. Because of this, we have drafted this Privacy Statement to ensure that any information we process complies with all relevant data protection laws in these regions. To see Tent’s wider Privacy Policy, please see here:  https://www.tent.org/privacy-policy/

Tent is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when collaborating with us, then you can be assured that it will only be used in accordance with this Privacy Statement.

Tent may change this statement from time to time, and will let you know if we do so via email. This statement is effective from 09/14/2021.

Tent agrees to comply with any applicable legislation relating to data protection or privacy of individuals in force from time to time in the European Union (“EU”), the European Economic Area (“EEA”) or the United Kingdom (“UK”), including and without limitation: the Privacy and Electronic Communications (EC Directive) Regulations 2003, or any other legislation that implements any other current or future legal act of the EU or the UK concerning the protection and processing of personal data (including Regulation (EU) 2016/679 of the European Parliament and the Council (“GDPR”), as it forms part of the laws of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, and any national implementing laws, as well as any applicable laws or regulations on cyber security (“the EU and UK Data Protection Legislation”) whilst processing any personal data in relation to the LGBTQ Refugee Mentorship Program.

The terms “data controller,” “data processor,” “data subject,” “personal data” and “processing” in this Privacy Statement shall be interpreted in accordance with the applicable EU and UK Data Protection Legislation.

 Please contact the Tent team at info@tent.org with any questions arising out of this Privacy Statement.

Data controller and processors
Tent acts as data controller for all data processed for the LGBTQ Refugee Mentorship Program. In simple terms, this means we (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.

Tent may disclose personal data, where permitted by EU and UK Data Protection Laws, to service providers, professional advisors, persons employed and/or retained by them in order to fulfil the purposes of the LGBTQ Refugee Mentorship Program.  We use Google, Microsoft Excel, Salesforce, Survey Monkey and Box as third-party data processors for the purposes of secure storage and have appropriate contracts and procurement checks in place to ensure they both comply with our terms set as data controller as well as all relevant EU and UK Data Protection Laws.  Your information will be shared with your mentor, the company where your mentor is employed, Tent, Micro Rainbow and the NGO that referred you for this mentorship program to fulfil the purpose of the LGBTQ refugee Mentorship Program.

What we ask you to submit and what information we process
In connection with the LGBTQ Refugee Mentorship Program, we may collect, record, store, adapt, otherwise process, and use personal data of mentees.

What personal data do we collect from mentees and on what lawful basis?
As an individual in a mentee capacity, we may ask you to submit the following categories of personal data:

Category of Personal Data Law basis for processing
Name and job titles

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program, and for three years following the expiry of the program, in connection with the operation of the LGBTQ Refugee Mentorship Alumni Program.

 

Email address

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program, and for three years following the expiry of the program, in connection with the operation of the LGBTQ Refugee Mentorship Alumni Program.

 

What country/region you are based in

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program.

 

A contact telephone number

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program, and for three years following the expiry of the program, in connection with the operation of the LGBTQ Refugee Mentorship Alumni Program.

 

Name of organisation that referred you to participate in the LGBTQ Refugee Mentorship Program

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program, and for three years following the expiry of the program, in connection with the operation of the LGBTQ Refugee Mentorship Alumni Program.

 

Lived experience information that may contain or infer special category data (i.e, racial or ethnic origin, political opinion, religious or philosophical beliefs)

 

 

Explicit consent from the mentee.
Information about personal and professional background

 

Explicit consent from the mentee, and for three years following the expiry of the program, in connection with the operation of the LGBTQ Refugee Mentorship Alumni Program.

 

Sexual orientation and gender identity

 

Explicit consent from the mentee.

 

Access to telecommunications services and technology

 

Based on Tent’s legitimate interests in connection with the operation of the LGBTQ Refugee Mentorship Program.

 


What we do with the information you submit
Tent may process the personal data you submit for the following purposes related to the LGBTQ Refugee Mentorship Program:

  • Analyze the information to make sure that participants are a good fit for LGBTQ Refugee Mentorship Program.
  • Share the information with the companies participating in this LGBTQ Refugee Mentorship Program so that they can match mentors and mentees based on similar professional and personal interests. Note that each mentee’s data will only be shared with one company that they have been assigned to for mentorship.
  • Invite participants to attend webinars and events (e.g. workshops, hiring fairs) focused on the economic integration of LGBTQ refugees. Note that we may co-host these events with other NGOs (e.g. Stonewall, Micro Rainbow), companies and government agencies that are interested in supporting the economic integration of LGBTQ refugees.
  • In cases where mentees are dealing with a difficult professional or personal situation or are being unresponsive to their mentor’s outreach, Tent or the company who is mentoring this mentee will reach out to the NGO that referred the mentee for this mentorship program for additional guidance or support. Tent and the company may also reach out to Micro Rainbow for further assistance for the mentee. 
  • Any other purpose for which notice has been provided, or has been agreed to, in writing.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. 

Data Transfers
Tent is an international organization and, provided you consent to such transfer, Tent employees based in the United States will have access to the personal data you have provided in the Google Docs survey in order to support the administration of LGBTQ Refugee Mentorship. We may also transfer your personal data to the third party service providers located outside the European Economic Area on the basis of the European Commission approved standard contractual clauses.

For information on the safeguards applied to such transfers of personal data outside of the UK and Europe, please contact the Tent team at info@tent.org.

Data retention and access
We employ appropriate technical and organisational measures, including physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

 For information on the safeguards applied to the retention of personal data, please contact the Tent team at info@tent.org.

 We will retain your personal data for so long as is necessary for you to participate in the LGBTQ Refugee Mentorship Program. Thereafter, we will retain your name, contact details, info about your professional background and details of the relevant mentor and mentee match for 3 years in order to contact you in regards to the LGBTQ Refugee Mentorship Alumni Program, and where otherwise required or permitted by law.

Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Statement. You should exercise caution and look at the Privacy Statement applicable to the website in question.

Data subject rights
Subject to applicable EU and UK Data Protection Legislation, you have the following rights under EU and UK Data Protection Legislation in respect to your personal data:

  • Access: You may request access to the personal data we have collected on you. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
  • Correction: You may notify us to correct the personal data we hold about you, for instance, if you have changed your address or phone number.
  • Deletion: You may also elect to have the personal data we have collected on you deleted from our customer database.
  • Restricting Our Use: You may request that we stop processing your personal data (other than storing it), if: (i) you are verifying the accuracy of it; (ii) you believe the processing is against the law; (iii) you believe we no longer need your information for the purposes identified to you; or (iv) you are verifying whether our legitimate grounds to process your personal data, override your own rights.
  • Transfer: If you wish to transfer your personal data to another organization as a data controller (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Right to Withdraw Consent: If you previously gave us your consent to process your personal data in for a particular purpose, you can contact us at please contact the Tent team at info@tent.org to let us know that you withdraw that consent at any time.

We do not carry out any automated processing, which may lead to an automated decision based on your personal data.

Our Contact Information
If you have any questions about this Privacy Statement or treatment of your personal data, you can contact the Tent team at info@tent.org. 

If your query or complaint is not resolved by Tent to your satisfaction and you wish to make a formal complaint to the relevant national supervisory authority, with the competent data protection supervisory authority in the relevant jurisdiction. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.

Publication Date: September 2021

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