Privacy Notice
Privacy Notice
Introduction
Steve Brown Behaviour Support & Training Ltd cares about protecting your privacy. We want you to be fully aware of your rights and how we collect and use your data. This Privacy Statement explains our views and practices concerning privacy, and how they may relate to you as a user of our website or services. The Nominated Representative for dealing with GDPR is Andrea Moore.
Steve Brown Behaviour Support & Training Ltd.
Steve Brown Behaviour Support & Training Ltd is a training and consultation provider based in the UK. For the purposes of this notice: You or Your means you as a participant in or as a user of the stevebrownbst.co.uk website. We or Our or Us means Steve Brown Behaviour Support & Training Ltd. Our site means stevebrownbst.co.uk.
We also refer to ‘Team-Teach’ – this means Team-Teach Ltd which is a separate training company based in the UK with its own website and data policies which we adhere to with regard to Team-Teach Training. Please refer to the Team-Teach Ltd data privacy notice which can be found on both the Team-Teach Ltd website or our website under Safeguarding and Data Protection.
The Legal Framework
The law on data protection sets out a number of different reasons why a company may collect and process your personal data.
• Consent - In specific situations, we can collect and process your data with your consent. (For example, when you tick a box to receive Team-Teach emails and/or newsletters, or when you sign up for a course).
• Contractual obligations - In certain circumstances, we need your personal data to comply with our contractual obligations. (For example, if you order training or an item from us for home delivery, we’ll collect your address details and pass them to the trainers delivering your course so that they can find you, or to a courier to deliver your parcel).
• Legal compliance - If the law requires us to, we may need to collect and process your data. (For example, we can pass on details of people involved in fraud or other criminal activity affecting our business to law enforcement. We may also be asked to provide information in relation to civil cases and child protection investigations).
• Legitimate interest - In specific situations, we may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business which does not materially impact on your rights, freedom or interests.
When we collect your personal data
Data can be collected in a variety of ways.
• When you communicate with us and/or purchase a product or service by email, text or phone.
• When you contact us by any means with queries, comments, compliments, complaints etc.
• When you complete signing-in sheets as part of a training course.
• When you complete course registration documents at the beginning of a training course.
• When you complete an evaluation at the end of a training course.
• When you complete a quiz as part of your training course.
• When trainers complete their training record of what was taught on your course.
• When trainers write out course certificates on successful completion of a training course.
• When you complete surveys or questionnaires we send to you.
• When you fill in any forms in relation to our business with you. For example, if an accident happens we may collect your personal data as part of the record.
• When you complete a consent form for working with your child
• When you discuss information related to your child’s needs either in person, on the telephone or via email or written correspondence.
What sort of personal data we collect
A variety of data may be collected.
• If you have a contact with us, your name, your child’s name, your child’s date of birth, your billing address, orders and receipts, email and telephone number may be recorded. This is often school based contact details but can be individuals if the school is not paying for services.
• Details of your interactions with us. For example, we may keep notes from our conversations with you, details of any compliments, comments or complaints you make and records of communications by email.
• Copies of any documents you provide to prove your age or identity, where the law requires this. (For example, your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality. This is likely only to be in the case of employees.
Why we need to collect your personal data
• We collect your personal data to enable us to process your training requests and comply with our legal obligations. Your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfill any contractual obligations such as refunds and so on. Training may be delivered on our behalf by independent contractors who are also responsible for complying with GDPR.
• We need to keep records to inform future communications (for example to respond to queries, refund requests and complaints and, more commonly, to provide references and support).
• We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service.
• We need to keep up to date with the needs of pupils in schools we support so that we can offer appropriate advice and liaise with other professionals to provide support to the school staff and families.
• We record assessment information, discussions and observations to aid writing of reports and support our contractual obligations.
How we protect your personal data
Data security matters to all our customers. We treat your data with the utmost care and take all appropriate steps to protect it. Access to your personal data is password-protected. Paper files are kept in locked cabinets. If files are used in schools or home visits they remain in the possession of the adviser during transportation and use in meetings and are then returned to locked filing cabinets.
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
Sending information over the internet is generally not completely secure, and we can’t guarantee the security of your data while it’s in transit.
Any data you send is at your own risk.
How long will we keep your personal data
Whenever we collect or process your personal data, we only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
Team-Teach Ltd retains business records, training summary evaluations, course registration documents and contracts for a period of 7 years after they expire. The tutor database is also retained for 7 years before inactive accounts are either deleted or rendered anonymous.
We retain school support records as long as we need them to support contractual obligations or in the event of potential legal challenges.
What Do We Do With Your Information
Email marketing: With your permission, we may send you emails about training and school support. If you are a previous customer implied consent is used (i.e. we presume you are happy to receive future details about services and training as a valued customer), but you can still email to request removal from the marketing list.
For School Support we may hold personal information whilst working with pupils and their families. This information is shared with selected school staff (those who requested involvement, Head Teachers or staff directly involved with pupils) with parental consent. Sensitive Personal Data may include information such as medical information and ethnicity if it has been received by a school or Local Authority as part of the support process.
Who do we share your personal data with
With regards to School Support we share personal information with the express permission of parents. This may be, for example with other outside agencies also working with the same pupil.
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
We use Accounting companies and Accounting software companies who would have access to employee and subcontractor data and contact details of finance managers or commissioners in settings where training has been purchased. This is usually a work email and work telephone number.
We sometimes need to share your personal data with trusted third parties. For example, consultants visiting you, and trainers all need your contact details. We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous. Examples of the kind of third parties we work with are:
• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers.
• Independent contractors delivering Team-Teach training and consultancy.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
• We may, from time to time, expand, reduce or sell Steve Brown Behaviour Support & Training Ltd and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Nominated Representative – Andrea Moore
Where your personal data may be processed
Sometimes Team-Teach Ltd may need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia. If you are based outside the UK the personal data that we collect from you will be held by Steve Brown Behaviour Support & Training Ltd in the UK. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What are your rights over your personal data
If we ask for your personal information for marketing messages we will ask you directly for your expressed consent and provide you with an opportunity to withdraw your consent.
You may withdraw your consent at any time by emailing andreamoorebst@gmail.com or stevebrownbst@gmail.com or calling 07947369701 and saying you do not wish to receive marketing emails.
When working with pupils we request signed parental consent to do so.
You have the right to request access to the personal data we hold about you, free of charge in most cases. You are also able to correct any of your personal data if it is incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
You have the right to request a copy of any information about you that Steve Brown Behaviour Support & Training Ltd holds at any time, and have that information corrected if it is inaccurate. To ask for your information, please email andreamoorebst@gmail.com. If we choose not to action your request we will explain to you the reasons for our refusal.
If you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113, or go online to www.ico.org.uk/concerns.
Information Technology
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will normally respect your wishes.
Many IT providers store data in servers which are located outside of the UK. (For example, iCloud, Dropbox). Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
Our website has been constructed using Google Sites. Please refer to Google Sites for cookie information. We do not request personal data through the website – it is an information site. Links to external sites from www.stevebrownbst.co.uk are clearly marked as re-directions e.g. Local Authority safeguarding procedure websites. Please see their privacy notices.
Changes To This Privacy Policy
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
Questions And Contact Information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us by email or in writing (again, see our contact page to find out how to do this.)
Steve Brown: stevebrownbst@gmail.com 07946728713
Andrea Moore: andreamoorebst@gmail.com 07947369701
19/3/18, last updated 8/5/18