Privacy policy

Introduction

This Privacy Notice explains the following:

• Who we are
• What information we collect
• How we collect your information, why we need it and how we use it
• What legal basis we have for processing your personal data
• When we share personal data
• Where we store and process personal data
• How we secure personal data
• How long we keep personal data for
• Your rights in relation to personal data including your rights to withdraw consent
• The use of automated decision making and profiling
• How to contact us including how to make a complaint with a supervisory authority
• The use of cookies and other technology
• Links to other websites and third-party contact
• How and when we review our privacy notice 

We recommend you read this privacy notice thoroughly. Please contact us with any questions or concerns regarding our privacy practices. Our contact details are on our website and also contained within this Privacy Notice.

1. Who we are

Forest School Swansea Neath Port Talbot (SNPT) is a registered Charity (1087964) and company (4194600).  We act as both a Data Controller and Data Processor in the following circumstances:

• Data Controller – data collected to enable us to conduct normal business as Forest School SNPT
• Data Processor – data collected as part of certain grant funds we may be in receipt of whereby the funding body would be the designated as the Data Controller 

You can contact us either by telephone on 01792 367118 or via e-mail on manager@forestschoolsnpt.org.uk

2. What information do we collect?

When we talk about personal data or personal information, we are only referring to information from which an individual person can be identified.  It does not include data where the identity has been removed.

Our engagement activities, delivered sessions and projects across Swansea, Neath & Port Talbot are fundamental to our commitment to our communities. We collect and process information with our partners, other funded initiatives and projects. We also have duties regarding employment, health and safety, and managing risk. This includes the following categories of information:

• Identity data which includes your name, date of birth, passport number, photo driving licence number, business interests and gender
• Financial data including billing address, account details, bank account holder details and bank card details
• Contact data (e-mail address, telephone number – including emergency contact information)
• Health and safety information including medical information and learner needs e.g. culture, diet and education
• Marketing and communications data – preferences for receiving marketing
• Special categories of data as part of our recruitment processes which may include:

1. Racial or ethnic origin supplied voluntarily during the recruitment process
2. Gender
3. Parental leave
4. Declaration of offences during the recruitment process under the Rehabilitation of Offenders Act

To put this in to context, it includes personal information collected as a result of:

• Data held for delivery of funded projects
• If you contact us
• If you attend/book an event/training organised by us either externally or at our venue
• If you are a stakeholder
• If you apply for a job/volunteer/provide sessional services with us
• If you supply goods or services to us
• All forms of communication with us, including e-mail, social media, verbal and telephone communication 

3. How we collect your information, why we need it and how we use it 

When you contact us regarding the work we do, we will handle your data with the utmost care and we are sensitive to the need to handle all data lawfully, fairly and transparently.

The methodology of collection varies but includes and is not exclusive to:

• Information gathered from e-mail or written contact;
• Information gathered from telephone contact;
• Information gathered via the completion of an online form on our website 
• Information gathered verbally or in writing at or in relation to events/sessions held by FSSNPT or others; and 
• Information gathered in support of special interest groups, programmes and projects.  
• Information gathered via social media e.g. Facebook, Instagram 
• Information gathered from cookies: IP address, web browser type and version, operating system, a list of URLs starting with a referring site, your activity on our site, and the site you exit to;

On occasion we may receive funding where the requirement to retain such data is governed under contractual arrangements from our funding bodies.  In these circumstances we act as the processors for the information and we will only use the information as instructed by those funding bodies. 

4. Use of automated decision making and profiling

FSSNPT does not conduct marketing profiling, however it does undertake targeted social media advertising.  This advertising is based on the activity of the individual and characteristics (age, gender, interests and their professional capacity) via their social media account (e.g. Facebook, Instagram).

5. Use of cookies and other technologies

By using our website, you consent to our use of cookies, so we recommend you read through the information below. This cookie policy may change at any time, so please check it regularly.

A cookie is a small file of letters and numbers which often includes an anonymised, unique identifier. This means that it can be used to identify you without revealing your personal information. When you visit a website, it asks permission to store a cookie in the cookies section of your hard drive. Cookies are widely used on the internet to make websites work more efficiently or to provide information about your usage of the site to the site owner/third parties. 

We use cookies to improve the way our website works, we also use third-party cookies set by Google Analytics to review our site functionality. Before third party Cookies that use your personal data are placed on your computer or device, you will be shown a popup requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may deny consent to the placing of Cookies; however certain features of our site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies which use your personal data.

6. What legal basis we have for processing your personal data?

The legal basis that applies to our data processing is as follows:

1. Where processing is necessary for the performance of a contract to which the data subject is party; or
2. Where the data subject has given consent to the processing of their personal data for one or more specific purposes; or
3. Where processing is necessary for compliance with a legal obligation to which we are subject; or
4. Where processing is necessary in order to protect the vital interests of the data subject or of another natural person; or
5. Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us (the controller); or
6. Where processing is necessary for the purposes of legitimate interests pursued by us or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data 

To put the use of the six legal basis we use for processing personal data in to context we will use the personal data and information we collect for the following purposes:

• To reply to any enquiry you make and to provide you with information regarding the services we provide
• To deliver on any of our programmes/training and other services we offer
• To make a payment to you including a transfer of funds on completion of a transaction on which you have provided services to us
• To manage our relationship with you
• To comply with our legal and regulatory obligations
• To undertake checks we deem necessary to confirm your identity
• To deal with any client feedback or complaint you may make
• To administer, develop and improve our business
• To protect our business e.g. should it be necessary to commence debt recovery actions or defend any legal claim
• To make suggestions and recommendations to you about the services we undertake and which may be of interest to you
• To invite you to any events (physically and online) we may hold or of which we may be a party and which may be of interest to you

We must have a lawful reason for processing your personal information.  Most commonly, we will use your personal information in the following circumstances:

• Where we need to deliver a project/session/training or perform the contract for services we are about to enter into or have entered in to with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation
• Where you have given your consent to process your personal information

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Information is only held for as long as there is a legitimate reason to do so, information that is no longer required is destroyed in such a way that it cannot be reconstructed. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us

7. When do we share personal data?

We may need to disclose your information to a third party as part of ongoing management and audit requirements. Third parties include:

• External advisors or consultants who are bound by confidentiality requirements in their contracts
• Organisations who provide funding
• Our professional advisers (e.g. legal, finance)
• Third party service providers who provide administrative or delivery services to us
• HMRC

We will ensure that if information is required to be shared, then it will be shared securely. You will be informed that we have shared it, who we have shared it with and how we shared it. 

8. Where do we store and process personal data?

Data is stored within Mailchimp, Eequ, Zoom, Quickbooks, Google storage software and stored on a backup drive. We undertake regular security reviews of all our third party platforms to comply with our duty as a Data Controller. The systems identified are third party systems, which have not been created by or owned by us, and adhere to their own Privacy Policies. Please contact our Data Protection Officer (see point 15) for further information should you wish to understand how your data is processed by the relevant platform. 

9. How do we secure personal data?

We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised manner or otherwise used or disclosed. We operate up to date, and regularly review, policies for Data Protection and Confidentiality. This supports our business processes and ensures that all staff are aware of the importance of data security. Access to information is permitted on a need to know basis. 

10. How long do we keep your personal data for?

We only keep and process personal data for as long as there is a contractual or business requirement to do so or we are otherwise obliged to keep the same under any contractual, regulatory or legal requirement.  Once the requirement has expired, the information is deleted safely and securely from our systems in such a way that Information which is deleted is done so in accordance with current security regulations. 

11. Keeping us up to date

As part of our responsibility to ensure that information we hold about you is up to date, we rely on you to keep us updated.  We request that where any of your details change, that you inform us so that we may update our records accordingly.

12. Your legal rights in relation to personal data

As a data subject, you have rights in relation to your Personal data. These are:

• You have a right to access your personal information, 

• You have a right for incorrect information held about you to be rectified
• You have a right for information which you no long wish us to hold to be erased (also known as the right to be forgotten)
• You have a right for the processing of your information to be restricted 
• You have a right to data portability – for your personal information to be transported in a structured, commonly used, recognisable format 
• You have a right to object to the processing of your personal information, 
• You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

You also have the right to make a Subject Access Request. As part of this process you will be able to ascertain:

• Whether or not your data is processed, and if so why
• The categories of personal data concerned
• The source of the data if you have not provided the original data
• To whom your data may be disclosed, including outside the European Economic Area and the safeguards that apply to such transfers.

We reserve the right to validate your identity prior to release of information. We will not make any charges for such requests, unless the requests are made repeatedly and are considered excessive.  We will respond to your request within 28 days. We provide a form for you to fill in which we use to ensure that your rights are addressed in full.  

If you have provided consent to FSSNPT to process any of your data, then you also have a right to withdraw that consent unless we are contractually or legally obligated to retain data. Withdrawal of consent will also result in withdrawal of support from the FSSNPT services or programme(s) to which you are signed up to. In cases where we do not need to retain data for contractual or legal reasons, we will delete the data as soon as possible and at the very least within 28 days.  

13. Links to other websites and third party contact

FSSNPT does link to external sites and resources as part of our normal business activity.  This includes news stories and links to other websites as part of the information being shared on our website/social media. Use of those links may allow third parties to collect or share your personal information. As we have no control over how such third parties may collect and share your information we do not take any responsibility for their use of your information.

14. How to contact us, including how to make a complaint with a supervisory authority

You can contact Forest School SNPT via a number of different routes. We will deal with your enquiry in the same way regardless of how you choose to contact us. For further information on how FSSNPT process your data, please contact us in writing at:

Jackie Dorrian

Manager and Data Protection Officer

Forest School SNPT

Caswell

Swansea

SA3 3BS

or via e-mail to manager@forestschoolsnpt.org.uk

If you are unhappy with the way in which your personal data has been processed and wish to raise a complaint, please do so by one of the methods described above.  We will handle your complaint sensitively, and confidentially and will write to you with a response within 10 working days. If you are dissatisfied, you have the right to communicate directly to the Information Commissioner (ICO). The Information Commissioner can be contacted at the following address. We would appreciate it if you would let us try and resolve the matter first before referring it to the ICO.

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF 

www.ico.org.uk

This Privacy Notice was passed for use in Forest School SNPT

On: 19/07/2022

Presented by: Sophie Lacey (Previous Manager)

Approved By: Board of Trustees

Date of planned review: 19/07/2023