Skills for Care Ltd (with company number 03866683 and charity number 1079836) (“Skills for Care”) is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information. We will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) in respect of the personal data you pass to us unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, including the Data Protection Act 2018 (“DPA”) and any successor legislation to the GDPR and the DPA.
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by Skills for Care which is the data controller (as defined in GDPR) of your personal data.
Any questions you have in relation to this policy or how we use your personal data should be sent to email@example.com or addressed to The Data Protection Officer, Skills for Care Ltd, West Gate, 6 Grace Street, Leeds LS1 2RP or telephoning 07866 802990.
1. What information we collect
We may collect information you give us via the website, for example by completing enquiry forms or registering on our website or by updating your communication preferences. Please see list below and retention periods.
We also use Google Analytics on our website which collects some technical information, but this information will never identify an individual and so does not constitute personal data for the purposes of GDPR or the DPA.
2. How we use information
We only ever use your personal data with your consent, or where we are entitled to process the data:
- to enter into, or perform, a contract with you;
- to comply with a legal duty;
- to protect your vital interests;
- because it is in our (or a third party’s) legitimate interests for us to process the data, provided your rights don’t override these.
In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes). Those purposes may include
- fulfilment of our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested;
- sending you newsletters and marketing information if you have consented to us doing so or if there are other grounds in GDPR which mean we are entitled to send marketing communications to you;
- sending you surveys and reviewing your responses and feedback in respect of the services we provide to you;
- notifying you of products and services we offer that are similar to those you have purchased or enquired about;
- notify you of other products and services we feel may interest you, or permit third parties to do so if you have consented to us doing so;
- notifying you of changes to our services and products; and
- monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website.
We collect and process much of your personal information on the grounds of legitimate interests, which include some or all of the following:
- where the processing enables us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of our customers;
- to identify and prevent fraud;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- administer the website and carry out data analysis, troubleshooting and testing; and
- to determine the effectiveness of promotional campaigns and advertising.
If we require your personal data for fulfilment of a contract with you (for example to provide goods and services you have requested), we may be unable to fulfil the contract without your personal data.
If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.
You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information) from us please let us know by emailing us at firstname.lastname@example.org, or by using the unsubscribe option in any of the marketing materials we send to you. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.
For further information on this please see Section 4 (Marketing).
Third Party Sites
We use personal data to communicate with you and to promote the Skills for Care offer. This includes keeping you up to date with our news, updates, campaigns, events.
3. Disclosing and sharing information
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third-party products and services, but these
communications will always come from Skills for Care and are usually incorporated into our own marketing materials (e.g. in newsletters).
We may share personal data with subcontractors or suppliers who provide us with services. For example, if you order something from our shop, your name and address will be shared with the delivery company. We may also share your information with third parties that arrange for customer feedback surveys to be sent on our behalf. However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.
We may also share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may also need to disclose your personal information where we:
sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller;
are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.
4. Marketing and communications
We want it to be easy for you to get relevant information from us and unsubscribe when you choose. Where you are our client or customer we may rely on legitimate interests to send you marketing communications about products and services similar to those you have purchased from us.
If you wish to receive additional communications from us, please let us know by:
You can unsubscribe to our marketing communications by:
following the unsubscribe link at the bottom of our emails
logging into our website and selecting ‘my account’ then ‘marketing preferences’
contacting our marketing team on email@example.com or 0113 241 0977.
If you unsubscribe from our communications, we will only keep a record of the personal data we obtained from your for marketing purposes on a suppression list to ensure we don’t send you any further communications.
Cookies are small files that are added to your computer when you browse the internet. They’re stored on your computer to remember certain information e.g. items in your basket or if you’re logged in.
Registering on our website
When you register on our website you must agree to our terms and conditions. As part of these terms and conditions you must agree for us to process your data outlined within this policy.
By registering on our website you can:
purchase items from our bookshop;
purchase and view registered manager membership;
apply to become an “I Care…Ambassador”;
subscribe and unsubscribe from our communications; and
apply for and view the status of ASYE (assessed and supported year in employment) funding.
5. How we protect data
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
If you use a credit/debit card to purchase a membership or purchase something online your card details are passed directly to the payment provider Stripe.
Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.
We never store your payment card information.
6. Data storage
Where we store information
Skills for Care’s operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do if your data is adequately protected and the relevant contract clauses are in place.
Skills for Care may send surveys to you using software provided by a company located in the US which may be able to access your personal data as a result. That company is a registered member of the Privacy Shield scheme, which ensures appropriate safeguards are in place in respect of the transfer of personal data to them. If we use a different company in the future we will ensure appropriate safeguards remain in place.
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for.
We will retain information you give us via the website, for example by completing enquiry forms or registering on our website or by updating your communication preferences for a period of 2 years, however if you engage with one of initiatives the retention periods are as follows;
Registered Managers Network
2 years from lapsed membership
i-Care Ambassadors (ICA)
2 years from being inactive
2 years from being initial application
90 days from lapsed application
2 years since last log in
Email and communication preferences
2 years since from last communication
We continually review what information we hold and delete what is no longer required. We never store payment card information.
7. Your rights
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website. These rights apply for the period in which we process your data. Your rights are:
- access to your personal data (‘subject access request’)
- rectification of your personal data
- right of erasure
- right to restrict processing
- data portability
- right to object to us processing your personal data
- right to object to automated decision making (note that we do not carry out any automated decision making using your personal data)
If you have any concerns about the way your data is being used, please contact our Data Protection Officer on email firstname.lastname@example.org.
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can also report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website.