In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
The Communicate Partnership
A partnership registered in England, whose registered office is at 61 Switchback Rd South, Maidenhead, SL6 7QF, and whose main trading address is PO Box 2652, Maidenhead, SL6 8ZL.
Data Protection Officer: Katie Coles
Email address: katie at communicate-ed dot org dot uk
Telephone number: 0345 331 1492
Postal Address: PO Box 2652, Maidenhead, SL6 8ZL
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
|Data Collected||How We Collect the Data|
|Identity Information including name and title.||Received via course application or membership form filled in on Our Site. Received via contact form on Our Site. Names may be collected from school websites or when given by colleagues.|
|Contact information including address, email address, phone number.||Received via course application or membership form filled in on Our Site. Received via contact form on Our Site. Business email addresses may be collected from school websites or when given by colleagues.|
|Business information including your job title, place of work, work address.||Received via course application or membership form filled in on Our Site. Received via contact form on Our Site. Job titles may be collected from school websites or when given by colleagues.|
|Payment information including card details, finance officer email address (NB We do not store card details).||Card details taken for course or resource payment through Our Site (not stored). Finance officer email address received via course application or membership form filled in on Our Site.|
|Profile information including dietary requirements/allergies, and details of disabilities/difficulties requiring reasonable adjustment.||Received via email when requested for the purposes of attending a face to face course.|
|Technical information including IP address and URL string.||Collected by Our Site (see part 14 for full information).|
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|Enrolling you on one of our courses||Name, date of birth, home address, work address, home phone number, work phone number, email address, place of work, role title, requiring reasonable adjustment.||Consent|
|Enrolling you on our annual membership scheme||Name, email address, work address, phone number, card details.||Consent|
|Communicating with you||Name, email address, address, phone number.||Consent|
|Supplying our courses to you||Name, email address, work address, details of disabilities/difficulties requiring reasonable adjustment||Consent|
|Sending you course materials||Name, address, email address||Consent|
|Supplying refreshments at face to face courses||Details of dietary requirements/allergies||Vital Interests|
|Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by contacting us or clicking unsubscribe in the email).||Name, role title, email address, address||Consent|
|Supplying you with information by email or post related to your role or the course you completed with us if you did not opt out of communications (you may opt-out at any time by contacting us or clicking unsubscribe in the email).||Name, role title, email address, address||Legitimate Interests. It is Communicate-ed’s legitimate interest to supply you with update training information relevant to the course you completed.|
|Notifying you that we have collected your name, role title, work address and/or work email address, informing you of your rights and giving you an opportunity to opt out of communications.||Name, role title, work email address, work address||Legitimate Interests. To fulfil Communicate-ed’s aim to provide high-quality training to professionals working in the area of special needs, it is necessary for us to contact professionals in this area to let them know: a) That the training and resources existb) How they can access them|
|Invoicing you for our courses or resources.||Name, email address, address||Consent|
|Keeping a record of courses completed.||Name, email address, place of work, address, result of course||Consent|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and post with information, news, and offers on our courses and resources. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties (including Twitter and YouTube) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Full Name||8 years from last course undertaken unless exclusions apply. There is an expectation by delegates that course providers keep a record of training undertaken. Name kept indefinitely if individual subscribes to mailing list or opts out of communications.|
|Email Address||8 years from last course undertaken unless exclusions apply. In cases where students request a record of training, email address acts as a more unique identifier than name alone. Email address is retained indefinitely if individual subscribes to mailing list or opts out of communications|
|Address and Phone Number||6 years after last course undertaken unless exclusions apply. Retained if individual subscribes to mailing list.|
|Role||6 years after last course undertaken unless exclusions apply. Retained if individual subscribes to mailing list.|
|Place of Work||Indefinite unless exclusions apply. Retained for record keeping, accounting.|
|Dietary Requirements/Allergies||6 years from last course undertaken unless exclusions apply. Retained only on CRM.|
|Details of disabilities/difficulties requiring reasonable adjustment||6 years from last course undertaken unless exclusions apply. Retained only on CRM.|
|Transaction details||Indefinite unless exclusions apply (Credit card details are not stored on the website)|
|IP Adress||Indefinite unless exclusions apply. Stored with transaction data and forum posts. Used for fraud prevention.|
|URL String||1 minute – 2 years. Google analytics uses three cookies:|
_gat – expires after 1 minute
_gid – expires after 24 hours
_ga – expires after 2 years
In fulfilling the tasks outlined in part 7, we may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We do not sell, trade, rent or otherwise transfer your personal data to third parties. We may, however, share your personal data with selected third parties including:
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with the following third parties to supply certain products or services:
|Recipient||Activity Carried Out||Sector||Location|
|Stripe||Payment Processing for courses, resources or membership||Finance||U.S. see DPA here|
|Exe-Squared Limited||Website and CRM Hosting and Support||IT||UK, DPA signed|
|Online Storage: Microsoft, pCloud, Dropbox||Storing Data||IT||DPAs linked below|
Microsoft – U.S.
pCloud – EEA
Dropbox – U.S.
|Mailchimp||Email Marketing||Communications||U.S. see DPA here|
|Intuit||Accounting vis Quickbooks Online||Finance||U.S. see DPA here|
|Printique Limited||Envelope Printing||UK, DPA Signed|
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our and at the point of providing your details).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access Our Site without providing any personal data at all.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the playback of embedded YouTube videos, the embedded Twitter feed and the Facebook share buttons.
For more details, including a full list of Cookies used on Our Site, please see our Cookie page at https://www.communicate-ed.org.uk/cookies.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
When you first visit Our Site, you will be shown a Cookie prompt informing you about Cookies and linking you to our Cookie page with information about how to change your Cookie settings. By clicking “OK” on the Cookie prompt and signalling consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Katie Coles):
Email address: katie at communicate-ed dot org dot uk
Postal Address: PO Box 2652, Maidenhead, SL6 8ZL