Legislation surrounding Data Protection is changing; the current Data Protection Act (1998) is being superseded by the General Data Protection Regulations (2018) – ‘GDPR’ – which becomes effective from May 25th 2018.
The GDPR will have a number of impacts on 123 SOLEIL PLC. Whilst most will require changes to existing administration and management systems, one very important inclusion is to consider every member’s Consent for collection, storage and use of personal data, except in the following 3 cases:
Where we can provide evidence for justification of processing.
For organisations like ours, heavily reliant on members voluntarily giving their time to manage and run the School, this new process is potentially onerous in terms of the documentation and time involved. We have reviewed how we can best implement GDPR and have considered that Consent is not required because of the exception mentioned above.
|Maidenhead 25 May 2018
123 Soleil Plc – Privacy Notice
123 Soleil plc (‘the School’) is committed to protecting and respecting your privacy.
This privacy notice provides you with details of how we collect and process your personal data through your use of our online site www.123Soleil.co.uk, Google Drive @123Soleil.co.uk. Accounts, As well as any information you may provide through 123 Soleil paper forms or @123Soleil.co.uk e-mails.
By providing us with your data, you warrant to us that you are over 13 years of age.
123 Soleil Plc is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: 123 Soleil Plc
1.2.3. Soleil Plc Registered charity number is 1132936 – Registered Plc in England and Wales number is 6960170
Email address: email@example.com
Postal address Registered office
Arvers, Grubwood Lane
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@123Soleil.co.uk.
This policy sets out the basis on which any personal data the School collects from you, or that you provide to the School, will be processed by the School.
WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows: Personal data is defined as of the following:
- Identity Data: may include your first name, maiden name, last name, username, marital status, title, Child name, date of birth, gender, Nationality.
- Contact Data: may include your billing address, mail delivery address, email address and telephone numbers.
- Vital Data: may include health information staff and teachers need to know for the wellbeing of the child at 123 Soleil School. Medical information, including allergy and dietary details (purely so that your treatment may be given in an Emergency and only when specifically and voluntarily declared by yourself) and special needs / requirements / disabilities.
- Legal data: may include Teachers or Assistant DBS check (Disclosure and Barring Service).
- Financial Data: may include your bank account and payment details.
- Transaction Data: may include details about payments between us and other details of purchases made by you.
- Technical Data: may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data: may include your username and password, purchases or orders, feedback and survey responses.
- Usage Data: may include information about how you use our website, products and services.
- Communications Data: e-mails correspondance.
- We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health (except vital child health information) and genetic and biometric data. We do not collect any information about criminal convictions and offences.
HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when:
- You register your child at 123 Soleil or update his/her data
- Your respond to survey; or give us feedback.
- Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted or Vital Interest. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- 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.
We do not rely on consent as a legal ground for processing your personal data, other than in relation to sending newsletter or correspondence communications to you via email or text message.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing
|To register your child as a new pupil
To register you as a teacher
|Performance of a contract with
|To process and deliver your order
(a) Manage payments, fees and charges
(b) Collect and recover money owed to
(c) Vital data
(d) Legal data
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
(c) Necessary for the child vital interests
|To manage our relationship with you which will include:
(a) Notifying you about changes to our
(b) Asking you to leave a review or take
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how parents use our school services.
|To administer and protect our School and our site (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and
hosting of data)
|Necessary for our legitimate interests to study how parents use our School services, to develop them, to grow our School and to inform our strategy.
|To use data analytics to improve our
website, school services, Parents & Teacher relationships and experiences
|Necessary for our legitimate interests to define types of families for our school services, to keep our site updated and relevant, to develop our school, and to inform our strategy.
|To make suggestions and
recommendations to you about the School services that may be of interest to
|Necessary for our legitimate interests to develop our school services and grow our school.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we transfer, or merge parts of our school charity or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US
Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
This website may include links to third-party websites, 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.
For more information about the cookies we use, please see www.123soleil.co.uk/cookie-policy.