Whisper Service: Notice to Users

What Whisper can be used for and how it works

Whisper is an open route made available to you by your school (the School) and managed by South West Grid for Learning Trust Limited (SWGfL).

Your message will be relayed to a nominated email account at the School. If you give your name this will show to the School.

Each message string will be linked by a unique reference so that you can check responses. If you have entered your email address into Whisper you will be notified about responses.

You will see the first name of the person at the School responding to you where replies are sent.

You are able to use Whisper as the School has designated you as being within the School Community.

The School is responsible for providing the School Community with information about:

• What they would like Whisper to be used to report;
• How the School processes personal data provided to them in a message once they have saved it off the Whisper system;
• Data protection rights related to use of Whisper including how long messages processed by them are kept;
• How the School acts upon the information provided in a message (this may relate to information about the person sending the message or another individual identified in the message) – such as in line with School policies on anti- social behaviour, safeguarding, bullying, cyber bullying and any other use of social media.

The School is responsible for any action that it takes (including no action) on the information provided in a message.

Data Protection Information

SWGfL and the School are joint controllers in respect any of personal data within a message and if you disclose your name when making a message (Message Data).

SWGfL

As Controller – we process the Message Data as part of the services but we do not review, monitor or act on the contents of any message. We process Message Data in order to give functionality to the Whisper service. We delete Message Data regularly at intervals agreed with the School unless there is a reason given by law for its retention or we are required to keep it due to a court order or order of any competent authority (the Retention Policy).

School

As Controller – processed the Message Data as required by the message and may store this outside of the Whisper system. The School will provide you with the appropriate notices including privacy notice information in respect of this.

SWGfL is the Controller in respect of Contact Data provided outside of the message and we use this to alert you to a reply from the School and to notify you of the unique number assigned to the message string. We process this in order to give functionality to the Whisper service. We delete Contact Data in accordance with the Retention Policy.

SWGfL is the Controller and also processes some other data (which may be personal data) relating to the IP address of the machine sending the message and related data. We call this Meta Data. We process this in order to give functionality to the Whisper Service and delete it in accordance with the Retention Policy except where we have completely anonymised the data and use this for analytical purposes.

Sharing Data

Message Data: the School will advise you how and when it may be required to disclose Message Data to any other party in order to act on the contents of a Message.

Message Data, Contact Data, Meta Data: as above, SWGfL is the Controller of this data.

Message Data: We share this with the School as this is the basis of the Whisper Service agreement we have with them.

Outside of this we will only ever share Message Data, Contact Data or Meta Data with any other third party where:

• We are ordered to do so by a court order;
• We are ordered to do so by a competent authority including social services and the police;
• You agree we can do so;
• We consider that there are reasonable grounds for such disclosure to protect the vital interests of any data subject;
• 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;
• 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 data held may be one of the transferred assets;

Your Data Protection Rights

As we use or store personal data relating to you, you have the following rights:

1. • the right to be informed that your personal data is being used or stored by us. This User Notice advises you of this;
   • the right to access the personal data we hold which relates to you – please use the contact details below;
   • the right to object to direct marketing by unsubscribing from it – we do not do this in respect of your personal data;
   • the right to object to processing carried out on the basis of legitimate interests – we do not do this in respect of your personal data;
   • the right to erasure of information we use or hold that relates to you – we can do this subject to the Retention Policy and any order requiring us to keep your data;
   • the right to data portability; - this is not relevant to the services here
   • the right to object to decisions being taken by automated means – this is not relevant to the services here;
   • the right to have your data rectified if its inaccurate or incomplete; and/or
   • the right to have your data restricted or blocked from our processing – this is not relevant to the services here.
2. 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 data, 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