Privacy Notice

As part of our ongoing commitment to keeping you informed, here is our Privacy Notice which sets out how we store and use your information. We encourage you to read this Privacy Notice in full.

 

DATA CONTROLLER

The Data Controller in respect of the information used and processed in the context of this website is Strictly Education 4S Limited (referred to in this notice as ‘Strictly Education 4S, ‘we’ or ‘us’), a company registered in England & Wales. Our Registration Number in the Data Protection Public Register is Z8569260 and our registered address is Strictly Education 4S Limited (“Strictly Education 4S”), 50 Curzon Street, London, W1J 7UW.

 

OVERVIEW

Strictly Education 4S is committed to protecting your personal information in accordance with applicable data protection law. This Privacy Notice explains how your personal information is processed and used by Strictly Education 4S, and for what purposes it is held.

Strictly Education 4S works with academies, schools and settings, Surrey County Council and other Local Authorities and with a range of regional and national bodies. Strictly Education 4S provides a single integrated service; this enables us to understand more fully the needs of customers and to deliver the best services to meet those needs in a coherent way.

As part of this website, we might provide you with a comprehensive range of compliance information, guidance, templates, employment law updates and other resources to support you to get your job done effectively, whether you are a school governor, a people manager operating at a strategic level or busy working day-to-day in an HR advisory or administrative role.

This is a policy document and does not have contractual effect. We may update or amend this notice at any time.

 

WHAT INFORMATION DO WE HOLD AND WHERE DOES IT COME FROM?

We collect information about you when you register with us or place an order for products or services. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in any competitions we promote. Website usage information is collected using cookies.

Depending on our relationship with you, some or all of the information below is collected by us for the purposes described in more detail below:

• Personal information you provide us for the purpose of registering with us (such as Full name, Email, Job Title, Role, Mobile and other Phone number(s));
• Information that you send to us in order to obtain a quotation for our services;
• School Information (such as Establishment name, Address, Type of School (e.g. maintained or Academy), Phase (e.g. primary or secondary), DfE Number, Local Authority details, Registration Code, Number FTEs);
• School Governor Information (such as Governor Status, Governor Type)
• Account information (such as username and password);
• Dietary requirements;
• Information that you provide to us in order to deliver consultancy services such as education, finance, governance, facilities management, HR and MIS strategic consultancy;
• Limited information about you relevant to any application for free school meals which you submit through our eligibility checking service;
• Billing information (such Card holder name, Address, Town, Postcode, Country, Email, Telephone, Customer order number). Please note, Strictly Education 4S does NOT collect or store credit/debit card details. This information is processed by selected third party online payment merchant services;
• Marketing preferences to receive specific training, information and newsletters;
• NQT information you may provide us for the purpose of registration including Home Address, Telephone, National Insurance No, Date of Birth and Teacher Reference Number.

Dependent on which goods or services (if any) you purchase on the Strictly Education 4S website, the team delivering the service will inform you if any additional personal information is required to deliver the service to you. Examples of services which may require additional personal information include our DBS service, HR services and NQT, HLTA, ICT, Schools Finance and Safeguarding services.

 

LEGAL BASIS FOR PROCESSING YOUR DATA

We will only process your information where we have a lawful reason to do so. In most cases, this will be where it is necessary for us to collect and process your personal information for the performance of a contract during the exchange of goods or services you purchase from Strictly Education 4S. For example, your online purchase information is shared with the relevant Strictly Education 4S team who will actually deliver the service. Your personal information will be used by the team to acknowledge your purchase and inform how, when and by whom the service will be delivered. There may be other times when we need to collect, share or use data about you using other lawful bases as listed below:

• We will seek consent for using your personal information for the purpose of directing marketing products and services or if we need to use your ‘special category data’ (such as health data), unless we have another lawful justification for sending you this material or using this type of data;
• We have a legal obligation to use your personal information for the purpose of detecting or preventing fraud or other crime; or
• We have a legitimate interest to use your personal data for a certain purpose and where these interests are not outweighed by any contrary interests you have. We highlight in the list below where this legal basis would apply.

If you don’t provide us with your personal data, we may not be able to fulfil our contract to provide goods or services to you, or otherwise enable you to use all the features on this website.

 

HOW DO WE USE YOUR DATA?

We use your personal data:

• For administration and operational support for our website. We would do this for our legitimate interests;
• To improve your browsing experience by personalising the website and enabling you to make use of the features on our website. We would do this for our legitimate interests;
• To send you general (non-marketing) related communications, including where we might contact every registered user to provide information on planned maintenance or service disruption. We would do this for our legitimate interests;
• Billing information for processing purchases or other services such as subscription services on our website;
• For administration, operational support and delivery of our products and services. For example, we might use your dietary information on individual bookings in order to provide suitable refreshments if required;
• For service desk function to manage, support & report on incidents and service requests;
• To monitor and report on contract delivery progress;
• For customer surveys to assess the quality of our services. We would do this for our legitimate interests;
• For marketing products and services which may be of interest to you and updates on our products and services including our Annual Service Level Agreement (SLA) Directory. Where we do not need your express consent to do so under applicable data protection law, we would do this for our legitimate interests;
• To maintain the accuracy of information during the duration of the contract;
• To deal with enquiries and complaints made by you relating to the website. We would do this for our legitimate interests.

When someone visits our website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the website. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting this website. We will not associate any data gathered from this site with any personally identifying information from any source.

We will not process personal information for any further processing other than the purpose it was obtained for (as described above).

 

AUTOMATED DECISION MAKING PROCESS

The Free School Meals Eligibility Checking Service application will be processed using an automated decision making tool on Department for Work and Pensions website. Manual checks can also be requested by you (using the contact details above) if and when necessary. For more information, please see the information provided on the Department for Work and Pensions website.

 

DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with Strictly Education 4S, plus any additional period permitted by law or regulation, as further described below.

More specifically, this means that, where applicable, we will hold your data until we are notified that you have left the establishment or there has been a five year period of non-activity on your registered account.

We will delete your personal information as soon as possible after you request your account to be terminated. This may take up to 10 working days to action although it will usually be less.

If you have raised a complaint or concern regarding a product or service offered by us, we will retain your information for one full academic year (September to August) following the date of resolution of that complaint or query.

Further, for NQT induction, the DfE Statutory Guidance advises ‘Appropriate Bodies’ such as us to retain information for seven years. Strictly Education 4S will retain information for this length of time or until the end of the contract with Surrey County Council, whichever is the soonest.

If you exercise your right to erasure, we will retain a core set of personal data where permitted by applicable data protection law which will include your name, postcode and email so that we do not contact you inadvertently in future. We will always respect a request by you to stop contact by any or all methods of communication, or for any specific purpose, unless we have another legal justification to continue doing so under applicable data protection law.

The only exception to the data retention periods mentioned above is where the law requires us to hold your personal information for a longer period or delete it sooner, where you have raised a complaint or concern regarding a product or service offered by us (in which case we will retain your information for a period of 3 years following the date of that complaint or query) or where we otherwise need to retain it in order to defend or exercise legal claims.

 

WHO DO WE SHARE YOUR INFORMATION WITH?

To facilitate the provision of some goods and services purchased on the Strictly Education 4S website and where applicable we share personal information with organisations listed below insofar as reasonably necessary for the purposes as set out in this Privacy Notice.

• Capita Education Services for SIMS and FMS incident and problem management;
• During the performance of a relevant contract, information is shared with authorised individuals as prescribed in the SLA/ASLA;
• Autotask cloud based CRM system to process IT incidents and service requests;
• Payment card transactions are processed by Barclay Card Merchant Services;
• Our IT supplier Redstor use personal information for billing purposes in relation to the provision of an online backup facility which it provides to us;
• NQT’s assessments, which hold personal details, may be shared with other ‘Appropriate Bodies’ where an NQT has not completed their induction period with Strictly Education 4S and transfers to a different ‘Appropriate Body’;
• the Department for Education (DfE) on a statutory basis;
• the Department for Work & Pensions (DWP) for Free School Meals Eligibility checks or other statutory basis.

We will ensure that our personnel only have access to your personal information where necessary in the context of the role they perform.

We may disclose your personal information to others only in the following circumstances and/or for the following purposes:

• Where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements;
• To prevent and/or detect crime;
• For audit and debt collection;
• To our group companies where necessary for business performance and other types of monitoring and management purposes;
• To our professional advisors and other suppliers or partner organisations where necessary in the context of the work they do for us.

 

SECURITY & INTERNATIONAL DATA TRANSFERS

Information that we collect will be stored and processed in the UK and the EEA and not transferred outside the EEA. We will take reasonable technical and organisational precautions in accordance with applicable data protection law to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure servers using appropriate security controls. All electronic data associated with transactions you make on or in relation to our website will be encrypted using SSL technology. Unfortunately any data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

 

MARKETING

We would like to send you information about products and services which may be of interest to you and updates on our products and services including our Annual Service Level Agreement (SLA) Directory, in order for you to achieve the best from your SLAs. As part of this, we want to communicate with you in a way that meets your needs and requests and depending on the preferences you express, we might communicate with you by post, telephone, e-mail or text. We will do so when we have separately obtained your consent or if we have another legal ground on which we can do so. If you have consented to receive marketing, you may opt out at a later date.

We will send you non-marketing emails to notify you of planned or unplanned website availability disruptions or cancellation of training or conference events.

You have the right to ask us not to process your personal information for marketing purposes, which can be exercised by checking the relevant boxes when you complete an online form or by contacting us at any time at customercare@strictlyeducation4s.co.uk.

 

USE OF COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use the cookies below as part of the operation of this website:

 

Name	Purpose	Expires
DROME[cookiePolicy]	DROME[cookiePolicy]	30 days
IDE	Advertising cookie	1 year
_utma	Used to distinguish users and sessions	2 years
_ga	Used to distinguish users (.twitter.com)	2 years
_ga	Used to distinguish users	2 years
_gid	Used to distinguish users	24 hours
_twitter_sess	Session cookie	Expires when browser closes
autoLogin	DROME/admin cookie	30 days
educationHR	Session cookie	Expires when browser closes
eu_cn	twitter.com	1 year
external_referer	twitter.com	24 hours
guest_id	twitter.com	2 years
lang	Session cookie (cdn.syndication.twimg.com)	Expires when browser closes
lang	Session cookie (syndication.twitter.com)	Expires when browser closes
personlization_id	twitter.com	2 years
tfw_exp	twitter.com	2 weeks

 

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

By using our website, you agree that we can place the types of cookies referred to above on your device. These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

If you do not want your browser to accept cookies, you can turn off the cookie acceptance option in your browser settings. Note: By doing this some areas of the website, features, and information may not function or display properly.

 

LINKS TO OTHER WEBSITES

Our website contains links to other websites. This Privacy Notice only applies to this website so when you link to other websites you should read their own privacy policies.

 

YOUR RIGHTS

Under data protection legislation you have the right to request access to information we hold about you. To make a request for your personal information we hold about you please contact us using the contact details provided at the end of this document.

You also have the right (subject to certain conditions) to:

• have your personal data rectified if it is inaccurate or incomplete
• request that we remove your personal data
• restrict the processing of your personal data, for example, ask us not to contact you
• object to the processing of your data for specific purposes such as direct marketing
• ask for the transfer of your data electronically to a third party (known as the data portability right)
• lodge a complaint with the Information Commissioner’s Office

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Strictly Education 4S will never sell your data. Except as envisaged by this Privacy Notice or as we otherwise tell you at the time, we will also never share your data with anyone to use for their own purposes unless disclosure is permitted or required by law.

 

CHANGES TO POLICY

This Privacy Notice was updated in March 2019. It will be reviewed annually and we will publish any changes we make to the Privacy Notice on our website.

 

CONTACT US

If you have any questions, need further information about our privacy practices, or would like to let us know that your details require updating, please contact:

by email customercare@strictlyeducation4s.co.uk

write to us at Strictly Education 4S Limited, Privacy Notice Enquiry, Bay Tree Avenue, Kingston Road, Leatherhead, Surrey, KT22 7UE