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POMS DATA POLICY

1. Purpose

This policy explains how the Plowright One Health Mentoring Scheme (POMS) manages data in relation to its mentoring activities, including the VLE (Moodle), file sharing platforms (SharePoint), and contact databases (Outlook, Google etc.). It ensures transparency, compliance with GDPR, and responsible use of personal data.

2. Data Controller

The Data Controller is the POMS Network Coordinator. For any data protection queries, please contact: asherratt@rvc.ac.uk

3. Basis for Processing

POMS processes personal data on the basis of:

• Consent – members must agree to this policy on joining the POMS VLE, and will be asked to provide additional informed consent if we seek to collect any additional specific personal data.
• Legitimate interest – data is used to run the mentoring programme and support collaboration. Anonymised data and outcomes may also be used to prepare reports to funders and for publication of academic outputs.

4. Scope

This policy applies to all POMS mentees, mentors, organisers and volunteers using Moodle, shared drives, or related digital tools.

5. Principles

• Transparency – members know how data will be used
• Data minimisation – only information essential to mentoring and network activity is collected
• Security – data is stored safely, access is restricted
• Confidentiality – mentoring discussions and personal reflections are private unless participants provide mutual informed consent to share them
• Equity and Inclusion – data use supports fair participation
• Accountability – members must handle shared data responsibly

6. Data Collected

• Contact lists containing Subject Identifiable Data (SID) including name, age, email, gender, institution, country, discipline, employment
• Qualitative feedback: preferences, goals, progress logs, surveys
• Participation data (attendance, Moodle activity, meeting contributions)
• Files and resources (including images, recordings and transcripts)

7. Data Use

• To pair mentors and mentees
• To communicate about POMS activities
• To evaluate and improve the programme (deliver anonymised reports to funders; prepare anonymised data for publications)
• To maintain a resource library

8. Data Sharing

• SID will not be shared outside POMS without consent
• Within POMS, member details may be visible for collaboration purposes
• Contact lists must only be used by organisers for specific POMS activities
• Members must not upload or circulate sensitive data without prior agreement of all individuals who may be identified either explicitly or implicitly.

9. Storage and Security

• Moodle and drives are hosted on secure servers with controlled access
• Access to contact data is restricted to authorised organisers and mentors
• Regular reviews of permissions will be carried out
• Users must keep their login details private and use strong passwords

10. International Data Transfer

POMS members are based worldwide. While servers are hosted in the UK/EU, data may be accessed internationally for mentoring purposes.

11. Rights of Members

Under GDPR, members have the right to:

• Access their personal data
• Correct inaccurate information
• Request deletion (right to be forgotten)
• Withdraw consent and leave the network
• Ask how their data is being used

12. Retention

SID is kept for the duration of the mentorship programme and will be destroyed on or before five years after the programme concludes.

Logs, lists and evaluation data containing SID may be anonymised and retained for reporting and for preparation of publications.

Key shared resources may be kept for the long term.

13. Breaches

Any suspected data breach must be reported immediately to the Network Coordinator. Serious breaches may be reported to the UK’s Information Commissioner's Office (ICO).

14. Review

This policy will be reviewed annually by the POMS Network Coordinator. Updates will be communicated to members.