Please note that this policy contains information on how we process personal data as a data controller, including personal data of our customers, suppliers and business contacts. Where we are a data processor and process a controller’s personal data including where the controller uses our products to manage pupil’s personal data, we will process that data in accordance with the relevant data processing agreement between us and the data controller and in accordance with the data controller’s instructions. Article 28 of GDPR stipulates minimum requirements for what information and provisions a data processing agreement should contain and we use a template document that meets those requirements.
Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
- Our company name is The Children’s Health Project CIC
- Our site address is www.childrenshealthproject.com
Our registered address is Meadowcroft House, 182 Balcombe Road, Horley, Surrey, RH6 9ER
- We are currently not required to have a Data Protection Officer, however, we have appointed a contact for data protection – Ms. Ilse Fullarton, and she can be contacted at email@example.com
What we may collect
We may collect and process the following data about you:
- Information you put into forms on our site at any time:
- contact name
- email address
- school name
- school address
- school postcode
- job role
- phone number
- number of pupils on role
- A record of any correspondence between us
- Details of transactions you carry out through our site
- Information you put into surveys on our site at any time:
- school’s needs for health and wellbeing education
- school strategy for health and wellbeing education
- staff appointed for health and wellbeing education
- pupils’ year group
- pupils’ gender
- pupils’ preferences and opinions relevant to the topic
- teachers’ year group
- teachers’ gender
- teachers’ preferences and opinions relevant to the topic
- Please note, we do not ask for the names of pupils or teachers in these surveys
- Surveys are optional and are filled in by you to support your role as a subject leader for health and wellbeing in your school
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) Processing is necessary for compliance with a legal obligation to which we are subject;
d) Processing is necessary to protect the vital interests of you, or of another natural person;
e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
How we use what we collect
We use information about you to:
- Provide information, products and services that you request, or which we think may interest you
- Carry out our contracts with you.
- Allow you to use our services if you want to.
- Tell you our charges.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
Where we store your data
We will do what we reasonably can to keep your data secure. We store data on a server located in a secure location in the UK and our IT security measures include firewall, SSL encryption, secure access server, data only stored on server outside application, back up of data, usernames and encrypted passwords. Although we provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts. We only keep personal data that is necessary for the relevant purpose and we only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it or in case where we are required to store your personal data by law. In any event, we will conduct a periodical review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
We may transfer your personal data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil our obligations, services, your order and deal with payment.
Disclosing your information
We are allowed to disclose your information in the following cases:
- We can disclose it to other consultants within our company, and other businesses in our group.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
We can exchange information with others to protect against fraud or credit risks. We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.
These are the third parties that have access to your information;
- Primary PE Passport – the education company we work with to deliver our website and the CHP Academy, where your data is collected.
- MailChimp – for email marketing purposes such as newsletters and updates.
- Zoom – the online meeting/webinar software we use to deliver training and online meetings.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at firstname.lastname@example.org
Under the GDPR, you have the right to:
- Request access to, deletion of, or correction of, your personal data held by us at no cost to you,
- Request that your personal data be transferred to another person (data portability);
- Be informed of what data processing is taking place;
- Restrict processing;
- Object to processing of your personal data;
- Complain to a supervisory authority.
Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Automated Decision-Making and Profiling
We do not use personal data for the purposes of automated decision-making or profiling.
If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation. If the parties are unable to agree upon a mediator, or if the mediator agreed upon is unable or unwilling to act and an alternative mediator cannot be agreed, any party may within 14 days of the date of knowledge of either event apply to LawBite to appoint a mediator under the LawBite Mediation Procedure.
Within 14 days of the appointment of the mediator (either by mutual agreement of the parties or by LawBite in accordance with their mediation procedure), the parties will meet with the mediator to agree the procedure to be adopted for the mediation, unless otherwise agreed between the parties and the mediator.
All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration by an arbitrator to be appointed by LawBite under the Rules of the LawBite Arbitration Scheme.
© 2020 The Children’s Health Project CIC