Privacy Notice

South West Grid for Learning Trust Ltd (referred to as “SWGfL”, “We” and “Us”) is committed to protecting and respecting your privacy.

This Privacy Notice (together with our terms and conditions (at swgfl.org.uk/terms) and any other documents referred to on it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

SWGfL is a registered charity and company limited by guarantee. We may disclose your personal information to any member of our group, which includes any subsidiaries or holding companies as defined in section 1159 of the UK Companies Act 2006, should such subsidiaries or holding companies exist.

General

  1. This Privacy Notice explains how we use and protect your personal information for the purposes of marketing and communications and delivery of certain services. This includes data which we gather from you for email updates that we send, the use of our website(s) and at events run by us (or on our behalf) which you attend.
  2. For the purposes of UK data protection legislation, we are the Data Controller for personal information where you have:
    1. agreed to receive marketing and communications information from us;
    2. accessed our website(s);
    3. agreed to receive services from us via our website(s); and/or
    4. applied for and/or taken part in events run by us (or on our behalf).
  3. We do not provide personal information to third parties for commercial purposes. We will only disclose personal information obtained for marketing and communication and service delivery purposes if:
    1. required or authorised to do so by law;
    2. it is necessary to enforce or apply our terms and conditions and/or other agreements; or to protect the rights, property, or safety of SWGfL, our customers, or others;
    3. we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or if SWGfL or substantially all of its assets are acquired by a third party, in which case personal information held may be one of the transferred assets;
    4. it is required to arrange attendance at an event or similar benefit; and/or
    5. we have your consent to do so.
  4. We may employ third party companies and/or individuals to perform certain functions on our behalf (including delivering events, sending postal mail or email, academic/research projects related to our work, delivering certain aspects of SWGfL service(s), and processing card payments). To the extent that they require access to personal information (and where we are unable to achieve the desired outcome by providing them with this data in an anonymised manner), we will disclose your personal information only where:
    1. the third party agrees to use it only for the agreed function(s) and not for any other purposes; and
    2. the third party agrees to process the personal information in accordance with this Privacy Notice and as permitted by the UK’s data protection legislation.

Our Processes

Email

  1. When you subscribe to emails from us, we require:
    1. your name;
    2. your email address; and
    3. in some cases, information about your organisation and role.
  2. We will collect this information as part of your subscription to our mailing lists.
  3. A subscription to our mailing lists means that you will automatically receive email updates from us.
  4. Our use and storage of personal information for email marketing and communications is based on your consent for us to do so. Therefore you will only receive emails and other information that you have consented to receive.
  5. You may withdraw your consent at any time, by using the ‘unsubscribe’ links on any of our emails.
  6. If you unsubscribe from our emails or withdraw your consent for us to use your personal information in this way, we will retain your information within our systems to prevent emails from being sent to you by us. We will retain this information only for as long as we require is for these purposes. More information about how long we store information is available in our Retention Policy.
  7. We use external platforms to manage our email marketing and communications. Such platforms may be located outside the EEA, however any such platforms shall be compliant with the EU-U.S. Privacy Shield Framework. The details of MailChimp and Constant Contact, two platforms that we use, can be found at the links above.

    Our emails may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Website(s)

  1. When you use certain elements of our website(s), we may require:
    1. your name;
    2. your email address;
    3. in some cases, your postal address;
    4. in some cases, information about your organisation and role; and
    5. in some cases, payment information.
  2. We will collect this information as part of your registration to use our website(s), and/or purchasing or subscribing to services advertised via our websites, posting material or requesting further services.
  3. We will use this information:
    1. to prevent other people from accessing your data within our website(s) by creating an account that is specific to you;
    2. to deliver appropriate and accurate content to you and your device from within the website(s);
    3. to carry out our obligations arising from any contracts entered into between you and us; and/or
    4. to notify you of changes to our services, and to provide you with support in using our services. If you contact us for support in using our website(s), we may keep records of such contact.
  4. Our use and storage of personal information in relation to your use of our websites is usually based on a contract we have with you.
  5. Where we do not have a contract with you, the use and storage of any personal information within the website(s) will be based on legitimate interests. The legitimate interests we are pursuing are the operation of our website(s) and promotion of our services.
  6. We will retain this information only for as long as we require it for these purposes. More information about how long we store information is available in our Retention Policy.
  7. We will store information you provide to us on our secure servers or on secure servers provided by our service providers. All data will be stored within the EEA or with service providers that are compliant with the EU-U.S. Privacy Shield Framework.
  8. Our websites are:
    1. The SWGfL website (swgfl.org.uk);
    2. The 360 degree safe websites (360safe.org.uk; 360safecymru.org.uk/; and 360safescotland.org.uk);
    3. The Online Compass website (onlinecompass.org.uk);
    4. The Online Safety BOOST website (boost.swgfl.org.uk);
    5. The Whisper website (swgflwhisper.org.uk);
    6. The Digital Literacy websites (digital-literacy.org.uk; onlinesafetycymru.org.uk/);  
    7. The Self Review Pro website (selfreviewpro.com);
    8. The SWGfL Store (swgflstore.com);
    9. The Swiggle search engine (swiggle.org.uk);
    10. The Rethink Cloud website (rethinkcloud.org.uk/);
    11. The 360 data website (360data.org.uk);
    12. The Revenge Porn Helpline website (revengepornhelpline.org.uk);
    13. The Reporting Harmful Content website (reportharmfulcontent.online/); and
    14. The ICAlert website (icalert.com).
  9. Our websites may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Cookies

  1. Our website(s) place cookies on your computer. For more details, please see our Cookie Notice.

Events

  1. When you attend one of our events, we require:
    1. your name;
    2. your email address;
    3. in some cases, your postal address;
    4. in some cases, information about your organisation and role; and
    5. in some cases, payment information.
  2. We will collect this information as part of your confirmation of attending an event.
  3. Our use and storage of personal information in relation to events is based on your consent for us to do so.
  4. We use this personal information to effectively organise and administer the event. Personal information will only be shared with other organisations where it is necessary to do so for this purpose. This includes, for example, providing the names of attendees to venues we are using.
  5. We will retain this information only for as long as we require is for these purposes. More information about how long we store information is available in our Retention Policy.
  6. We may use external platforms to manage some of our events. Such platforms may be located outside the EEA, however any such platforms shall be compliant with the EU-U.S. Privacy Shield Framework. The details of Eventbrite, one platform that we use, can be found at the link above.
  7. If you attend our events as part of the group of presenters, sponsors or speakers, we may note your involvement in our emails relating to the event and on communication platforms, including social media. Such platforms may continue to store and use personal information according to their own processes.

How We Use Your Personal Information

  1. The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where there is a LEGITIMATE INTEREST

  1. We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
    1. for marketing activities;
    2. for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website);
    3. to correspond or communicate with you;
    4. to verify the accuracy of data that we hold about you and create a better understanding of you as a user of our services;
    5. for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access.
    6. for prevention of fraud and other criminal activities;
    7. to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
    8. to assess and improve our service to customers through recordings of any calls with our contact centres;
    9. for the management of queries, complaints, or claims; and
    10. for the establishment and defence of our legal rights.

Where there is a LEGAL REQUIREMENT

  1. We will use your personal information to comply with our legal obligations: (i) to identify you when you contact us; (ii) to verify the accuracy of data we hold about you; (iii) where we reasonably believe that you are or may be in breach of any applicable laws, we may disclose your personal information to relevant third parties, including to law enforcement agencies.

Where you have provided CONSENT

  1. We may use and process your personal information where you have consented for us to do so for the following purposes:
    1. contact you via email or text with marketing information about our services if you (i) register for an account with us online and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletters and marketing and communications emails via our website(s) or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so];
    2. contact you via email or text with marketing information about our services if you (i) register for an account with us online and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletters and marketing and communications emails via our website(s) or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so; and
    3. share your data with our recommended third party partners for them to contact you with marketing information about their products and services.
  2. You may withdraw your consent for us to use your information in any of these ways at any time.

Your Rights

  1. Where we use or store personal information relating to you, you have the following rights:
    1. the right to be informed that your personal information is being used or stored by us. This Privacy Notice advises you of this;
    2. the right to access the personal information we hold which relates to you;
    3. the right to object to direct marketing by unsubscribing from it;
    4. the right to object to processing carried out on the basis of legitimate interests;
    5. the right to erasure of information we use or hold that relates to you;
    6. the right to data portability;
    7. the right to object to decisions being taken by automated means;
    8. the right to have your data rectified if its inaccurate or incomplete; and/or
    9. the right to have your data restricted or blocked from our processing.
  2. These rights apply to certain situations, but do not apply to others. The Information Commissioner’s Office’s guidance on each of the rights can be found here.

Complaints

  1. If you are concerned about any aspect of our processing or personal information, please contact us. Contact details are provided below.
  2. Should we fail to resolve your concerns, you have the right to complain to the Information Commissioner’s Office.

Contacting Us

Please read this notice carefully and contact us if you have any queries by emailing us at: privacy@swgfl.org.uk.

Or by writing to:
The Head of Privacy
South West Grid for Learning Trust
Belvedere House
Pynes Hill
Exeter
EX2 5WS

Or by telephone on: 0345 601 3203

We reserve the right to change this Privacy Notice from time to time, and suggest therefore that you review it periodically.

This version of the Privacy Notice was last updated on 16 May 2018.