- Introduction – explanation of privacy and the policy
- What information we collect
- Sensitive Personal Data
- How we collect data
- How we use your information
- Where we store your personal data
- Disclosure of your information
- Security and Data Retention
- Users under 18
- Your rights
- Accuracy of information
- Access to information
- Contact us
- Your Information
- Introduction – explanation of privacy and the policy
What information we collect
- 1.1 We, Cornwall Council, are committed to protecting and respecting your privacy. The Data Controller for all the information you provide is Cornwall Council, County Hall, Treyew Road, Truro TR1 3AY. Data Protection Registration Number: Z1745294.
- 1.3 You have created an account to book onto relevant training courses, set-up a cpd record and indicated if you would like to receive marketing materials. We need the details listed in parts 2 and 3 of this document in order to set up your provision. Without them we will not be able to provide you with the service. In some instances we also require dietary requirements. This is to ensure we have the necessary information to ensure you are adequately catered for. We are processing this data under the lawful basis of legitimate interests, these interests being providing relevant courses and retaining a record of training for the client.
Sensitive Personal Data
- 2.1 We may collect and process the following types of information provided by you:
- 2.1.1 name;
- 2.1.2 address;
- 2.1.3 email addresses
- 2.1.4 telephone number;
- 2.1.5 course attendance history;
- 2.1.6 employment history;
- 2.1.7 school admission details; and
- 2.1.8 any other data as notified to you from time to time together with Personal Data.
How we collect data
- 3.1. Sensitive Personal Data we may collect may include:
- 3.1.1. physical or medical information;
- 3.1.2. religious beliefs or similar beliefs of a similar nature;
- 3.1.3. racial or ethnic origin information;
- 3.1.4. whether you are a member of a trade union;
- 3.1.5. political opinions and political affiliations;
- 3.1.6. your sexual orientation; and
- 3.1.7. the commission or alleged commission by you of an offence.
- 3.2. If we collect Sensitive Personal Data we will either obtain your prior explicit consent to do so or ensure that we are permitted to process your Sensitive Personal Data, without obtaining your express consent, provided that we are legally permitted to do so under the Act.
Information provided by you
- 4.1. Information that you provide by:
- 4.1.1. registering to use our site;
- 4.1.2. subscribing to our services;
- 4.1.3. requesting further goods &/or services;
- 4.1.4. posting material;
- 4.1.5. filling in forms on our site. This includes information provided at the time of registering to use our site, subscribing to our service, posting materials or requesting further services;
- 4.1.6. correspondence between us, including e-mails;
- 4.1.7. responding to surveys that we may from time to time ask you to complete for us, although you are not obliged to complete these;
- 4.1.8. entering a competition or promotion sponsored by us;
- 4.1.9. reporting problems regarding our service or site; and
- 4.1.10. during transactions you carry out through our site and the fulfilment of your orders.
Automatic Information and Cookies:
- 4.2. We may capture and store some information about your computer, such as your IP address, operating system and browser type, for system administration. This information is purely statistical and does not identify you as an individual. we use this data to help us understand our users’ browsing patterns and to shape our marketing.
- 4.3. For the same reason, we may obtain information about your general usage of the site by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver better and more personalised service. They enable us:
- 4.3.1. to estimate our audience size and usage pattern;
- 4.3.2. to store information about your preferences, and so allow us to customise our site according to your individual interests;
- 4.3.3 to recognise you when you return to our site.
- You can read more about the cookies we use and how to maintain them.
How we use your information
- 4.5. We may keep records of any contact you have with us.
- 4.6. We may record details of any calls that you make to us expressly for the purposes of maintaining customer service standards and assisting with staff training.
- 5.1. We use the information held about you in the following ways:
- 5.1.1. to ensure that content from our site is presented in the most effective manner for you and for your computer;
- 5.1.2. to plan and manage our activities, possibly through researching and analysing your use of the site;
- 5.1.3. to provide you with information about new ideas and facilities;
- 5.1.4. to process your order for our goods and/or services and fulfil any contractual obligations with you that arise from any order you place. This may include passing on your personal data to third parties so that your order may be processed;
- 5.1.5. to provide you with further or new information about, or access to, our goods and/or services;
- 5.1.6. to assess your request for delivery of goods and/or services from us. When doing so we may make enquiries about you including searching records held by organisations like Equifax and credit reference agencies. At all times where we use or disclose your information it will remain secure;
- 5.1.7. to notify you about changes to our service;
Where we store your personal data
- 5.2. We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you
- 5.3. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sales to you.
- 5.4. We will ask for your consent if we wish to use your personal information for any other purpose.
- 5.5. We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected.
Disclosure of your information
- 6.1. The data that we collect from you will not be transferred to, or stored at, a destination outside the European Economic Area ("EEA").
- 6.2. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Security and Data Retention
- 7.1. We may disclose your information to third parties:
- 7.1.2. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- 7.1.3. If Cornwall Council or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Users under 18
- 8.1. The transfer of information via the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access and protect your personal data against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period of time or as long as the law requires. Accounts classed as current (accessed within the last 7 years) will have course data/ cpd records retained for a period of 7 years. Following that period the information will be destroyed in a secure manner.
- 9.1. A Childs privacy is very important to us and we have a specific policy for users under the age of 18 accessible at.
- 9.3. We encourage Parents and Guardians to monitor their childrens’ use of the website at all times and encourage the activation of parental control software.
- 9.4. If you are under 16 the following apply:
- 9.4.1. If you are under 16 you must ensure that you have obtained your parent/guardian's permission before you provide personal information to us.
- 9.4.2. We do not collect personal information from any child under 13, unless the child's parent or guardian has specifically consented. You must not provide any personal information without your parent/guardian being present.
- 9.4.3. If you provide personal information to us with the consent of your parent/guardian you will be required to enter their email address so that they can receive copies of all emails and information sent or received by you.
- 9.4.4. The purpose of collecting a parent/guardian’s email address is to allow them to supervise your use of the site and any information you provide to us. If the parent/guardian refuses to provide an email address for this purpose, their consent will be revoked and you will not be permitted to provide us with personal information.
Accuracy of information
- 10.1. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Access to information
- 11.1. You are responsible for informing us when your personal details have changed. Please note that notification of any change must be in writing. It is then our responsibility to update our records accordingly.
- 12.1. The Act gives you the right to access information held about you in accordance with the Act. Any access request will be subject to a fee of £10 to meet our administrative costs in providing you with details of the information we hold about you.
- 14.1. For the purposes of the Act, the data controller is Cornwall Council of New County Hall, Treyew Road, Truro TR1 3AY.
- 14.3. If you do not want to receive offers or contact from us please contact the admin team on telephone number 01872 327900 or by emailing firstname.lastname@example.org
Your personal information belongs to you and you have the right to:
- be informed of how we will process it
- request a copy of what we hold about you and in commonly used electronic format if you wish (if you provided this to us electronically for automated processing, we will return it in the same way)
- have it amended if it’s incorrect or incomplete
- have it deleted (where we do not have a legal requirement to retain it)
- withdraw your consent if you no longer wish us to process
- restrict how we process it
- object to us using it for marketing or research purposes
- object to us using it in relation to a legal task or in the exercise of an official authority
- request that a person reviews an automated decision where it has had an adverse effect on you
If you would like to access any of the information we hold about you or have concerns regarding the way we have processed your information, please contact:
Data Protection Officer
Tel: 01872 326424
Complaints, Compliments and Comments
Our complaints team can be contacted via the following address:
Quality Assurance Business Manager
Children, Schools and Families
We would prefer any complaints to be made to us initially so that we have the opportunity to see if we can put things right. However, if you are unhappy with the way we have processed your information or how we have responded to your request to exercise any of your rights in relation to your data, you can raise your concerns direct with the Information Commissioner’s
Office Tel No. 0303 123 1113 https://ico.org.uk/concerns/