Privacy policy old
IMCM Website Privacy Policy
The IMCM website adheres to the University of Oxford Website Privacy Policy, with the exception of the list of cookies it uses. You can find a list of these and their purpose in our Cookie Statement.
IMCM Research Data Privacy Notice
A. Privacy policy – Research Data
The Oxford-GlaxoSmithKline Institute of Molecular and Computational Medicine (IMCM) is an academic-industry collaboration which aims to improve tools in, and knowledge from, genetics, genomics, molecular and single cell biology, spatial imaging, machine learning and novel methods of data handling to study the pattern of diseases in new ways. Ultimately its goal is to uncover new indicators and predictors of disease and use them to accelerate the most promising areas for drug discovery.
In order to undertake this research collaboration IMCM will acquire and analyse research datasets from third party providers, hereafter ‘research data’, some of which will contain personal data.
This policy (together with IMCM Information Security Policy, together with any other documents referred to in it) describes how we collect and use research data which contains personal data, in accordance with the UK General Data Protection Regulation (UK GDPR) and associated data protection legislation.
B. Who is using this personal data?
The University of Oxford is the “data controller" for the research data. This means that we decide how to use it and are responsible for looking after it in accordance with the UK GDPR.
Access to this personal data within the University will be provided to those staff who need to view it as part of their work in connection with the research aims of the institute. It will also be shared with the third parties described in Section G.
This privacy notice has been drafted to explain our views and practices regarding this personal data and how we will treat it. We may update this policy at any time.
C. Glossary
Where we refer in this policy to your ‘personal data’, we mean any recorded 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 or retention.
D. Types of data we collect
We will collect, store, and use the following categories of research data:
• Personal qualities, e.g.:
- Age
- Sex
- Ethnicity
• Health visit information (some datasets include information about tests, treatments sample acquisitions during health visits), e.g.:
- Visit date information
- Procedure information
- Test/treatment/sample type
- Administering clinician
- Health status information, e.g.:
• Disease type
- Onset date
- Disease progress test results
• Test/treatment/sample derived information, e.g.:
- Epigenomic.
- Harmonised endophenotypes.
- Genetic.
- Genotype.
- Genome wise association study.
- Imaging.
- MEG-MRI.
- Metabolomics.
- MRI.
- Proteomic.
- Smartphone motorscore.
- Transcriptomic.
- Whole Exome Sequence (WES).
- Whole Genome Sequence (WGS).
E. When we collect this data
We will collect this data as we expand our research activities, identifying datasets of potential research interest, engaging in due diligence activities to acquire the datasets in compliance with relevant legal, regulatory, contractual and ethical rules.
F. How we use your data
We process your data in order to pursue the IMCM research agenda. Data will be processed to mitigate identified information governance and security risks, including data subject identification risks, before being ingested into a data analysis platform. Researchers, bioinformaticians, data managers and related experts will process the data to produce high-quality research results which may be published in research journals, presented at academic conferences, used to drive further research and/or protected and exploited as intellectual property for the benefit of the collaborating institutions.
We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
G. Sharing the data with third parties
As an academic-industry collaboration, IMCM will, where permitted under its relevant data sharing agreements and where it serves its research agenda, share research data with GlaxoSmithKline (GSK) researchers to further that research agenda.
We may share the research data with third parties who provide services on our behalf, such as for securely storing, backing up and providing analysis tools for the data. All our third party service providers are required to take appropriate security measures to protect the data in line with our policies. We do not allow them to use the data for their own purposes. We permit them to process the data only for specified purposes and in accordance with our instructions.
We may also share the research data with third parties if we are under a duty to disclose or share it 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 research data is shared with third parties, we will seek to share the minimum amount necessary.
H. Where we store or use research data
We may store research data manually or electronically. The data is stored on secure cloud-based servers hosted by the Microsoft Corporation and located in the United Kingdom, or EEA.
As the Microsoft Corporation are based in the United States of America, storing this information counts as a transfer outside the United Kingdom. This transfer will only take place if one of the following applies:
• the organisation receiving the data is covered by an arrangement recognised by the UK as providing an adequate standard of data protection;
• the transfer is governed by approved contractual clauses;
There may be further occasions when we transfer your data outside the United Kingdom, for example, were we to choose another data hosting provider. Such transfers will only take place under the same conditions as noted above.
I. Retaining your data
We will retain your data for as long as we need it to fulfil our purposes, including any relating to legal, accounting, or reporting requirements, and in line with the expectations of research personal data retention.
J. Your rights
Under certain circumstances, by law you have the right to:
• Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
• Request erasure of your data. This enables you to ask us to delete or remove your 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 data where you have exercised your right to object to processing (see below).
• 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.
• 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 another party.
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 doing so would seriously impair the underlying research purpose of IMCM’s processing.
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, you should contact Oxford University’s Information Compliance Team at data.protection@admin.ox.ac.uk. The same email address may be used to contact the University’s Data Protection Officer. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the 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 Information Commissioner’s Office at https://ico.org.uk/concerns/.
K. Changes to this policy
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.
L. Contact
If you wish to raise any queries or concerns about this privacy policy please contact us at information.governance@ndm.ox.ac.uk or:
Institute of Computational and Molecular Medicine
Centre for Human Genetics,
Roosevelt Drive
Oxford
OX3 7BN
UNITED KINGDOM