Educafe Privacy and Data Protection Policy
This document describes how and why we collect, store, protect, process and share personal information about you. We do this to process your enrolment forms when you apply to participate in a learning, support or volunteering activity and to otherwise support the delivery of Community Learning and Educafe.
Who we are
Here at Educafe we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a "data controller" for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 ("Data Protection Law"). This means that we are responsible for, and control the processing of, your personal information.
Educafe CIC is the Data Controller. This means it is ultimately responsible for the data it holds about you.
Contact Address
Educafe CIC, 14 West Mills, Newbury, RG14 5HG
The Data Protection Officer for Educafe CIC is Clare Middleton
Contact details: info@educafeuk.co.uk
How will we collect data?
When you interact with us directly: This could be if you ask us about our activities, register with us for training or an event, donate to us, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, get in touch through the post or in person.
When you interact with us through partners or suppliers working on our behalf: This could be if you access a service which is delivered through a trusted organisation working on our behalf and always under our instruction.
When you interact with us through third parties: This could be if you provide a donation through a third party such as Just Giving or one of the other third parties that we work with and provide your consent for your personal information to be shared with us.
When you visit our website: We gather general information which might include which pages you visit most often and which services, events or information are of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use cookies to help our site run effectively. We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
Personal information is also collected from you when you complete:
• An enrolment and volunteering registration form
• An individual learning plan
• A post course evaluation form/survey
What data will we collect about you?
We are required to collect and hold the following information under government rules (see “What will we use your data for?” below for more information):
your name
gender
date of birth
ethnicity
address
telephone number
email address
nationality (including, where applicable, the length of time you have been resident in the UK or EEA).
Visa status
If you attend one of our accredited qualification courses, we are also required to collect and hold information about your household situation. This includes whether you are the only adult in the household, if any adults in the household are in work and if there are any children living in the household. It also includes your National Insurance number, employment status and the length of time you have been in this employment. Other types of information collected and held include your highest previous qualification, if you have achieved level 2 in maths or English and any learning difficulties and/or disabilities you have that may impact on your learning.
What will we use your data for?
Educafe CIC receives Adult Education Budget (AEB) funding from Local Authorities and the Department for Education via the Education and Skills Funding Agency (ESFA) to support the delivery of education to adults over the age of 19 years from the local authority. To receive the funds the service must comply with the ESFA Funding Rules which state we have to collect certain data from you when you enrol upon a course, draw up an individual learning plan or complete post-course evaluation forms or surveys. You can read the rules online at https://www.gov.uk/guidance/sfa-funding-rules.
We collect special category data in respect of any learning difficulties or disabilities you have to make sure that we can make adjustments for you to learn effectively. We only use this data for that purpose, and it is only shared with the express purpose of ensuring you can access learning that is in line with the requirements of The Equality Act 2010. We are required to collect and process this data as a condition of receiving funding under SFA funding rules. The data may also be used to carry out research on the impact of the courses and/or promote other courses or learning opportunities.
. We will use this information:
To provide the services that you have requested.
To update you with important administrative messages about an event or services you have requested or sought information for.
To keep a record of your relationship with us.
If you volunteer with us, to administer the volunteering arrangement.
If you do not provide this information, we will not be able to sign you up for a particular event or service you have requested.
We may also use your personal information:
To contact you about our work and how you can support Educafe
To invite you to participate in surveys or research.
Who will see your data?
Your data will be seen by Educafe, the Local Authority and authorised employees in the community learning service. If it is used for marketing and research purposes it may also be seen by third party organisations contracted by Educafe CIC to carry out this role. The ESFA reserve the right to access these records as part of any audit they undertake to satisfy themselves that learners exist and the funding is being used in accordance with the ESFA Funding Rules. The ESFA Privacy Notice is available here https://www.gov.uk/government/publications/esfa-privacy-notice
A note about Sensitive Personal Information we hold
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you contact us at Educafe, in person or via general communications with us such as blogs or emails, you may choose to provide details of a sensitive nature. We will only use this information:
For the purposes of dealing with your enquiry, training and quality monitoring or evaluating the services we provide.
We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
Where you have given us your express consent or otherwise clearly indicated to us that you are happy for us to use your data.
Legal basis for using your information - Why are we doing this?
We are legally processing your personal data through your contract (the enrolment form) to attend an adult education budget funded course. This part of the processing is necessary to provide you with the service you have requested. Educafe CIC is working with local authority community learning services acting in the public interest. As such, some processing will take place for these purposes. There is also a legal basis for the processing we undertake as the Apprenticeships, Skills, Children and Learning Act 2009 requires the school to create and maintain a unique learner number (ULN). You are under no obligation to give the school permission to use your data for marketing and research purposes; it’s your choice. This is clearly marked on the enrolment form as an “opt-in”. If you don’t wish to be contacted, simply leave the relevant boxes blank. If you opt-in and subsequently decide you don’t wish to hear from the school in the future, just let us know by responding to the emails you receive and we’ll remove you from the distribution list.
In most cases, we will only use your personal information where we have your consent or because we need to use it to fulfil a contract with you.
However, there are other lawful reasons that allow us to process your personal information and one of those is called 'legitimate interests'. This means that the reason we are processing information is because there is a legitimate interest for Educafe to process your information to help us to achieve our vision of ensuring that everyone using our services gets both support and respect.
Whenever we process your Personal Information under the ‘legitimate interest' lawful basis we make sure that we consider your rights and interests and will not process your personal information if we feel that there is an imbalance.
Some examples of where we have a legitimate interest to process your personal information are where we contact you about our work via post, use your personal information for data analytics, to conduct research to better understand who our supporters are, to improve our services or for our legal purposes (for example, dealing with complaints and claims).
How long will your data be kept?
You have several rights when it comes to the data we hold about you. These are detailed on our request form that also allows you to make a request for us to take action about something. Data will be kept for a maximum of 5 years.
How is your data stored and processed?
All your data is put on Educafe’s records system, which is a secure database and management information system. Your paper records are initially stored securely in locked filing cabinets at either Educafe CIC or at the local authority.
Transfer overseas
Your data will not be stored or sent outside of the UK.
Marketing
We will only contact you about our work and how you can support Educafe by phone, email or text message, if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address, we may send you information about our work and how you can support Educafe by mail unless you have told us that you would prefer not to hear from us in that way.
Complaints
If you’ve already told us we need to do something, but we haven’t responded in a way you’re satisfied with, you can complain to the Information Commissioner’s Office (the ICO). It’s easiest to do this online via the ICO website (https://ico.org.uk/concerns/handling/ ), but you can also do so in writing to: The Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire
SK9 5AF
Privacy and Data Protection policy approved by Educafe CIC Directors & Chair person