Privacy Policy

Book Clubs in Schools (BCiS) Schools Limited: Privacy Policy 

This Privacy Policy explains how we use the personal information that BCiS collects or generates both in relation to this website and our products and services. 

The list below sets out what is covered in this Privacy Policy: 

  1. Background 
  2. The products and services we provide  
  3. The types of personal data we collect  
  4. How we use your information 
  5. Disclosure of your information to third parties 
  6. How we safeguard your information 
  7. How long we keep your personal data 
  8. Your rights 
  9. Designated representative 
  10. Questions and concerns 

1. BACKGROUND 

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.  

1.2 At BCiS we respect the privacy of our clients and we are  committed to keeping all your Personal Data secure. This Privacy Policy governs the  handling of Personal Data by BCiS in the course of carrying on  our work.  

1.3 We use the following definitions in this Privacy Policy:  

“BCiS”, “we or “us” means Book Cubs 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 

2.1 This Privacy Policy concerns the following categories of information that we collect about  you when providing the following products and services: 

(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 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.  

Cookies.  

– 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:  

  • we need to do so in order to perform its contractual obligations;
  • we have obtained your consent; 
  • we have legal and regulatory obligations that we have to discharge;  
  • we may need to do so in order to establish, exercise or defend our legal rights or for  the purpose of legal proceedings; 
  • the use of your Personal Data as described is necessary for our legitimate business  interests, such as:  
    • allowing us to effectively and efficiently manage and administer the operation of our  work; 

– 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

4.3 We will take steps to ensure that the Personal Data is accessed only by employees, third  parties and contractors of BCiS that have a need to do so for the  purposes described in this Privacy Policy. 

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: info@bookclubsinschools.org 

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: info@bookclubsinschools.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. 

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