1.1 BCiS registered office is 50 Ashen Grove, London, SW19 6NT and may collect and use certain Personal Data. BCiS is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
“BCiS”, “we or “us” means Book Clubs in Schools .
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, BCiS (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of BCiS or any other person in respect of an individual.
2. THE PRODUCTS AND SERVICES WE PROVIDE
(A) Information we receive through our website, www.bookclubsinschools.org (“BCiS Website“);
(B) Information we receive through our programmes (this is including but not limited to the BCiS Book Club Programme and Mini Book Club) and services
(C) Information we receive through our support system for schools (“BCiS Services“).
3. THE TYPES OF PERSONAL DATA WE COLLECT
3.1 Many of the services offered by BCiS require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
● Information that you provide to BCiS. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
– basic Personal Data (such as first name; family name; position in your company or school; company or school name; your company or school email address; business phone number; business address; city; postcode; country; mobile number);
– Sensitive Data such as school bank details, FSM/EAL/SEN information of individual students for reporting (this can be anonymised);any information that you choose to share on BCiS internet forums and web-based forms which may be considered Personal Data. (Please note that BCiS does not collate information included on BCiS internet forums together with Personal Data from your Subscriber account or profile);
● Information that we collect or generate about you. This includes (by way of non exhaustive list):
– a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you and can contact you with additional related offers and services;
– Student registers for each school to enable us to report on attendance;
– Ethnic origin information in order to fulfill equal opportunity purposes, as the processing is necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment between persons of different racial or ethnic origins, with a view to enabling such equality to be promoted or maintained;
– through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.); and
● Information we obtain from other sources.
– When you visit the BCiS Website, cookies are used to collect technical information about the services that you use, and how you use them.
● Anonymised data
– In addition to the categories of Personal Data described above, BCiS will also process further anonymised information and data that is not processed by reference to a specific individual.
4. HOW WE USE YOUR INFORMATION
4.1 Your Personal Data and Sensitive Personal Data may be stored and processed by us in the following ways and for the following purposes:
● for ongoing review and improvement of the information provided on BCiS Website to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
● To collect feedback on BCiS Services and to help provide more information on the use of those products and services quickly and easily;
● to communicate with you in order to provide you with services or important information about BCiS Products and Services;
● to understand your needs and interests;
● to effectively report to our potential and current funders;
● for the management and administration of our organisation and the successful delivery of our programmes;
● to comply with Safeguarding laws;
● in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and
● for the administration and maintenance of databases storing Personal Data.
4.2 However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:
– maintaining compliance with internal policies and procedures, including our Child Protection and Safeguarding Policy and Photography and Sharing Images Policy; – monitoring the use of our copyrighted materials; and
– enabling quick and easy access to information on BCiS
5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
5.1 We may share your Personal Data within BCiS for the purposes described above, and will ensure that the third parties are authorised and enter into a written agreement with us to ensure they comply with our Data Protection Policies and Procedures:
5.2 We may also share your Personal Data outside of the BCiS for the following purposes:
● with our charity or business partners. For example, this could include our charities who purchase books on our behalf for schools. Personal Data will only be transferred to a charity or business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
● with third party agents and contractors for the purposes of providing services to us (for example, BCiS’s accountants, trustees, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this policy;
● to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
● if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
● if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
6. HOW WE SAFEGUARD YOUR INFORMATION
6.1 We have extensive controls in place to maintain the security of our information and information systems. All files containing personal and sensitive personal data are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
6.2 As a condition of employment, BCiS employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a BCiS employee or freelancer is prohibited and may result in disciplinary measures.
6.3 When you contact a BCiS about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
7. HOW LONG WE KEEP YOUR PERSONAL DATA
7.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:
● the purpose for which we are using it – BCiS will need to keep the data for as long as is necessary for that purpose to a maximum of five years; and
● legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
If you have any questions regarding how long specific personal data may be retained, please contact us using the details in Section 8.
8. YOUR RIGHTS
8.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
● the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
● the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation, such as mentor DBS information;
● in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to BCiS;
● the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
● the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
● the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
● the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
8.2 You can exercise your rights by contacting us using the details listed below.
9. DESIGNATED REPRESENTATIVE
9.1 BCiS’s registered office may be contacted using the following contact information:
Address: BCiS, 50 Ashen Grove, London, SW19 6NT
Email Address: email@example.com
10. QUESTIONS AND CONCERNS
10.1 If you have any questions or concerns about BCiS’s handling of your Personal Data, or about this Policy, please contact our Directors using the following contact information:
Address: BCiS, 50 Ashen Grove, London, SW19 6NT
Email Address: firstname.lastname@example.org
We are usually able to resolve privacy questions or concerns promptly and effectively.
If you are not satisfied with the response you receive from our Director, you may
escalate concerns to the applicable privacy regulator in your jurisdiction.
Upon request, BCiS’s Director will provide you with the contact information for that regulator.