Privacy Policy

PRIVACY NOTICE

Breakthrough Education Support Ltd is an educational support service which provides our clients (children, schools, parents & learners) with timely, professional and bespoke Behaviour, Learning and Dyslexia support and/or assessment at all times.

Our promise to our clients:

We will…

  • only process and store data with your agreement
  • use and continue to update safeguards around data handling
  • not sell your data.
  • give you ways to manage and review your marketing choices at any time
  • not retain data that is no longer used or needed and will destroy in line with GDPR regulations and legal requirements.

Introduction

Welcome to the Breakthrough Education Support Ltd privacy notice.

Breakthrough Education Support Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you engage with our services, visit our website and inform you of your privacy rights and how the law protects you.

  • Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you make a request for support.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Breakthrough Education Support Ltd is a Data Controller and responsible for this website. This means we will ask our clients (schools/academies/settings or individuals) for a main contacts name and some details to allow you to do business with us.

In line with GDPR legislation, Breakthrough Education Support Ltd has updated this privacy statement in order to demonstrate our firm commitment to the privacy of our clients and visitors to our site.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Full name of legal entity: Breakthrough Education Support Ltd

Name data privacy manager: Maria Bani

Email address: mb@breakthroughed.co.uk

Third-party links

This website may include links to third-party websites in the future, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit

How we use your personal information

This privacy notice is to let you know how we promise to look after your personal information. This includes about yourself/school/setting and learner, what is included in the Request for Involvement form, what we learn by having you as a client, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

  • To keep your data safe and private.
  • Not to sell your data.
  • To give you ways to manage and review your marketing choices at any time.

If you have any questions, or want more details about how we use your personal information, you can ask us using mb@breakthroughed.co.uk

How the law protects you.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Breakthrough Education Support Ltd. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Types of data we collect

Client/learner information

When a client/learner contacts us for specialist support or an assessment and during the process of our work we collect a range of information to enable us to fulfil that service provision.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Any personal information that received will be processed in accordance with the General Data Protection Regulations (GDPR). May 2018. These regulations require registration with the Information Commissioners Office (ICO).

  • Contact details – for example home address, email address and telephone number
  • Sensitive personal data – for example, details of why an individual seeks an assessment, details of a disability or specific learning difficulty, details of support a client/learner may have had in the past, assessment data, and notes written during and after support or assessment sessions or after other contact with client/learner
  • Dates of meetings/sessions held with a client/learner
  • Family Details – for example details of other family members with whom a client/learner or a client/learner’s school/college/workplace have given me consent to liaise
  • Assessment information – including standardised scores achieved in assessments used.
  • School information – this include school email addresses, telephone numbers and addresses.

Final reports, scanned test papers and accompanying information with responses will be stored electronically and this will be password encrypted and safely stored. Any test papers, accompanying information and the electronic folders will be deleted or shredded after certain time limits in accordance with legal requirements and PATOSS guidelines.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in ‘Request for Involvement Forms’ or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU.

Why we collect this information?

We collect only information for one/more of the following reasons:

  • Fulfilling contracts.
  • Our legitimate interests.
  • Our legal duty.
  • Your consent

The main purpose for information collection is to plan and provide the assessment, specialist support or another service that the client/learner has requested.

Where there is any other purpose for sharing information then consent will be obtained.

How we may use your personal information

If you make a request on our website, we may collect and store the following information from you: name and job title, contact information, including email address and mobile number and demographic information such as postcode.
We will not collect any personal data from you we do not need in order to provide and oversee the service we offer.

We may collect, store, and use your personal information for the following purposes:

  • to make this website available to you and to provide you with content which is tailored to your individual tastes;
  • to provide you with services that you request and to respond to any enquiries you submit through the website; and
  • monitor, develop and improve the services and/or your experience
  • internal record keeping
  • to send promotional emails and information we think you might find interesting using the email address you have provided.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into 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.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

  • To register you as a new client
  • To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To use data analytics to improve our website, services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about services (such as any courses/resources we offer in the future) that may be of interest to you

Contact Information

Our site’s registration form requires you to provide us with some contact information (e.g. name and email address). We sometimes use this contact information from the registration form to send you information about our company and our products and services by email, post etc. This contact information is also used to contact you when necessary. If at any time you wish to stop receiving information from Breakthrough Education Support Ltd, please contact us and we will update our records accordingly.

This site may contain links to other sites. Breakthrough Education Support Ltd is not responsible for the privacy practices or the content of such websites.

Our site uses a form to help us manage requests. We collect contact information (like email addresses). Contact information is used to respond to enquiries, or get in touch with you when necessary.

Email

Breakthrough Education Support Ltd respects the privacy of email accounts and we store your email addresses just as securely as other information on our site.
However, we may use email to keep you up to date with news about products, services and offers that we think may be of interest to you. If you do not want to be kept informed in this way by email, please let us know. Please email mb@breakthroughed.co.uk and request to be ‘opted out’ of marketing.

Who might we share this information with?

Once assessments are completed they will be emailed to the person who has commissioned the assessment. It will be password encrypted.

Any report produced following an assessment is private and confidential and will not be shared with third parties by Breakthrough Education Support Ltd. without the clients explicit consent.

Assessments will not be shared with a third party without written permission from the person who has requested the assessment. Email threads will be deleted regarding information provided for the assessment.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long we keep your personal information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will keep your personal information for as long as you continue working with Breakthrough Education Support Ltd.  After you stop being a client, we may keep your data for up to 10 years for one of these reasons:

  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to rules that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.  Similarly by law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

Report/Assessment Information

 

It is recommended that records should be kept for as long as the time limit for civil proceedings would apply:

  • Where a service is contractually agreed, for 6 years.
    If it is a matter of a service contractually agreed, records will kept for younger learners until they reach the age of 24, or for 6 years after the contract finished for those over 18 at the time of the contracted service.
  • For personal injury, for 3 years.
    In this context ‘personal injury’ can be construed as psychological. If the individual is under 18 then the 3 year period starts from the individual’s 18th birthday.

Paper or electronic records will be securely stored.  Paper records will be keep in a locked storage.  Electronic records will be stored on a secure password encoded/encrypted memory device.

Access to your personal information

Under GDPR, the data subject has the right to access and amend any of their personal data that we hold.  You are also entitled to view, amend, or delete the personal information that we hold. Please email your requests to mb@breakthroughed.co.uk.

Please Note: Requests from clients/earners to delete data relating to an individual will be considered on a case by case basis but we may be unable to remove information from reports, assessment records or support notes for legal reasons.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

Marketing

From time to time we may use your personal/school/setting information to tell you about relevant products and offers.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services we have provided or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information see our cookies policy below.

Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Changes to this Privacy Policy/Notice

This Privacy Notice was reviewed on 01.09.2018 and will be reviewed as required according to legislation set out by the ICO.

The updated version will be indicated by an updated “Revised” date and will be effective as soon as it is accessible.

We are always working to improve the way your data is stored and shared and we encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

If you have any questions regarding this privacy notice please do not hesitate to contact Maria Bani at mb@breakthroughed.co.uk