The Communicate Partnership
A partnership registered in England, whose registered office is at 61 Switchback Road South, Maidenhead, Berkshire, 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: 0845 331 1492
Postal Address: PO Box 2652, Maidenhead, SL6 8ZL.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) 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.
The personal data that we use is set out in Part 5, below.
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way
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 11.
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.
The only information we collect is information that you give us, either through our website forms, email, paper application forms or on the telephone. This may include some or all of the following data:
• Name (Title, First and Surname);
• Address (usually work address);
• Email address;
• Telephone number;
• Place of work;
• Job title/role;
• Payment information;
• IP Address;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
• Finance officer email address;
• Dietary Requirements or allergies (face to face courses);
• Access requirements or other special requirements (face to face courses)
• Date of birth (Access Arrangements Assessing only);
• Results of standardised tests (Access Arrangements Assessing only);
• Comments from teachers and support staff (Access Arrangements Assessing only);
• Reports from professional assessments by hospital consultants or educational psychologists (Access Arrangements Assessing only);
Your personal data may be obtained from the following third parties:
• A delegate from your centre giving your email address as the finance officer to which we should send an invoice;
• An employee from your centre booking you onto one of our courses;
• An employee from your centre giving your name and/or email address as a contact to receive information about Special Educational Needs training opportunities;
• An educational direct marketing company with mailing lists obtained in compliance with GDPR;
• School staff (Access Arrangements Assessing only);
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
• Supplying our courses, resources or membership account to you. Your personal details are required in order for us to enter into a contract with you.
• Communicating with you. This may include responding to emails or calls from you.
• Providing and managing your access to Our Site;
• Supplying you with information by email and post that you have opted-in to. You may unsubscribe or opt-out at any time by following the directions in the marketing e-mail or direct mail marketing communication from us. Please note that even though you may have opted out of receiving marketing communications, you may still receive business-related communications such as order confirmations, product recall information or essential updates or other organisational related communications.
• In the case of applying for Access Arrangements, to fill in JCQ Form 8.
• Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or post with information, news, and offers on our products or services. 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 GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. Where we rely on Legitimate Interests as our lawful basis for processing, you may request to see our full Legitimate Interests Assessment, including the 3-stage balancing test that we have completed.
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):
• Delegate’s name, places of work, addresses, and the courses they purchased (including their dates) will be kept for 8 years. This allows us to confirm training enquiries to centres and provide proof of training to delegates, which they often request years later;
• We never store credit card details;
• We will keep the names, addresses and email addresses of people who have asked us not to send them marketing communications for an indefinite time, so that we can fulfil our legal obligation to exclude them from marketing communications;
• We will keep the names, addresses and email addresses of people who subscribe to our mailing list for as long as they wish to remain on our mailing list, as they have the opportunity to unsubscribe with every communication. In the event that they unsubscribe, their details will be kept on the list above.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that 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 GDPR including:
• Having a written agreement with every data processor that we share data with, ensuring that they agree to comply with the letter and spirit of GDPR; and/or
• In the situation of using a U.S.-based data processor, only using data processors who participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework;
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:
• Only storing personal data in password protected locations;
• Not emailing sensitive personal data unless it is encrypted using S/MIME end-to-end encryption;
• Using SSL to ensure data passed between our web server and browsers remains secure;
• Keeping all software up to date (including, but not limited to, applications and operating systems);
• Securely deleting and disposing of any personal data no longer needed;
• Having strict, GDPR-compliant policies about Data Protection and Information Security, and ensuring all employees and contractors are appropriately trained in these policies;
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:
• Our associated limited company Include-ed, a limited company number 10070095 registered in England & Wales, with registered office: 61 Switchback Rd South, Maidenhead, SL6 7QF;
• In the case of assessing for Access Arrangements, your data will be shared with the school SENCo.
We may sometimes contract with the following third parties to supply our courses and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
• Website hosting adn support: Clystnet Ltd (UK, DPA signed)
• Credit/debit card payment processor: Stripe (U.S., subscribes to the EU-U.S. Privacy Shield Framework) NB. We do not store credit card details ourselves;
• Online Learning Environment: Digital Chalk (U.S., subscribes to the EU-U.S. Privacy Shield Framework, DPA signed)
• Email sending platform: Mailchimp (U.S., subscribes to the EU-U.S. Privacy Shield Framework, DPA signed);
• Envelope printers: Printique Limited (UK, DPA signed)
If any of your personal data is required by 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.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, 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 GDPR, as explained above in Part 8.
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.
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 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
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 within 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.
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
Telephone number: 0845 331 1492
Postal Address: PO Box 2652, Maidenhead, SL6 8ZL.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available through hosting the updated policy on our website and sent by email to any existing members who have an ongoing contract with us.