WORKING EYE LTD DATA PRIVACY, FAIR PROCESSING & COOKIES POLICY
Working Eye Limited is a company created to provide services to the Education Sector. When we put ‘Working Eye’, ‘we’ or ‘us’ in this Notice, we mean Working Eye Ltd. When we put “you” we mean customers, employees, suppliers, organisational representatives or in case of persons under the age of consent their parent or guardian with legal responsibility.
Looking after personal data you share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us and understand how we use it to offer you a better and more personalised experience. At Working Eye we believe in being transparent about what data we are collecting and how it will be handled. The information contained within this document sets out our privacy policy in summary and detail.
Summary
Our Fair Processing Notice explains your privacy rights and how we gather, use and share information about you. You can get in touch with our Data Protection Officer by email at dpo@workingeye.com, by post to The Data Protection Officer, Working Eye Ltd., 80 Long Acre, LONDON WC2E 9NG or by telephone at 07522 859108.
Your Rights
- Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
- For more information or to exercise your data protection rights please contact us in any of the ways described above.
- You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data at ico.org.uk or by post at The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
How We Gather Personal Information
In addition to the information you provide to us directly we collect personal information in a number of ways, for example from third parties and from looking at how you have used other products and services we offer. Sometimes for your safety, training, quality control and for legal reasons we collect personal information by recording and monitoring calls and from CCTV. See section 5 for more details about how we gather personal information.
How We Use Your Personal Information
We use your personal information to provide you with products and services to comply with the law and enforce our legal rights (including debt recovery), and to improve and market our products and services. Sometimes we need to use sensitive personal information such as medical details to ensure that we are catering for your individual needs and to keep you safe during activities. Find out more about how we use your personal information in section 6.
We need some personal information before we can provide our products and services to you, for example to allow us to check your identity. In some cases, we won’t be able to provide products and services to you if we don’t have all the personal information we need, for example our curriculum data support facility.
FULL FAIR PROCESSING NOTICE
1. Introduction
We take data privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you and the further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the products and services we provide to you. In the first instance if you have any questions about how we use your personal information please contact the Working Eye customer services team on 07522 859108.
Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the best standards to protecting your personal information and can be reached by email at dpo@workingeye.com, by post to The Data Protection Officer, Working Eye Ltd., 80 Long Acre, LONDON WC2E 9NG or by telephone at 07522 859108.
See section 3 ‘Your Privacy Rights’ for more information about your rights and how our DPO can help you. This Privacy Notice provides up to date information about how we use your personal information (also referred to as personal data). We will update this Privacy Notice if we make any significant changes affecting how we use your personal information and if so we will contact you to let you know about the change.
2. About Us
We are what is known as the ‘controller’ of personal information we gather and use.
3. Your Privacy Rights
3.1 You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else. You can click here to exercise any of the following privacy rights:
3.2 Right to object: You can object to our processing of your personal information. Please contact us as noted above, providing details of your objection.
3.3 Access to your personal information: You can request access to a copy of your personal information that we hold along with information on what personal information we use, why we use it, who we share it with, how long we keep it and whether it has been used for any decision making. You can make a request for access free of charge by post to The Data Protection Officer, Working Eye Ltd., 80 Long Acre, LONDON WC2E 9NG. Please make all requests for access in writing and provide us with evidence of your identity.
3.4 Right to withdraw consent: If you have given us your consent to use personal information, you can withdraw your consent at any time. Withdrawing consent to hold personal information may mean that we can no longer provide activities where there is a health and safety risk.
3.5 Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
3.6 Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
3.7 Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured commonly used electronic form so it can be easily transferred.
3.8 Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
3.9 Make a complaint: You can make a complaint about how we have used your personal information to us by email at dpo@workingeye.com, by post to The Data Protection Officer, Working Eye Ltd., 80 Long Acre, LONDON WC2E 9NG or by telephone at 07522 859108. You can also make a complaint to the data protection supervisory authority, The Information Commissioner’s Office, at https://ico.org.uk. To make enquires for further information about exercising any of your rights in this Privacy Notice please contact our DPO as detailed above.
4. What Kinds Of Personal Information We Use
We use a variety of personal information depending on the products and services we deliver to you. For all products and services, we need to use your affiliated organisation name, your name, address and contact details. For some products and services, we might need additional information, for example: date of birth, health details for certain catering or residential services to help support our customers who have a vulnerability; and convictions information to meet legal obligations. Sometimes where we ask for your personal information needed to enter into a contract with you or to meet a legal obligation (such as an enhanced disclosure and barring services check), we will not be able to enter into an agreement without that personal information.
5. How We Gather Your Personal Information
We obtain personal information:
- Directly from you, for example when you fill out a booking request;
- By observing how you use our products and services for example from accessing our residential/curriculum facilities;
- From other organisations such as Local Education Authority, Diocese, Department for Education or from the organisation you are affiliated for example education provider. We also may obtain some personal information from monitoring or recording calls and when we use CCTV. We may record or monitor phone calls with you for regulatory purposes, for training and to ensure and improve quality of service delivery, to ensure safety of our staff and customers, and to resolve queries or issues. We also use CCTV on our premises to ensure the safety and security of our staff and customers.
6. How We Use Your Personal Information
To provide you with any products and services we may need to know your organisations details, your name, address, contact details and potentially see a copy of identification documents (such as a passport or driving licence). We might also need health information to help support our customers who have a vulnerability. We sometimes need to gather, use and share additional personal information for other specified purposes which are set out in more detail below.
6.1 To operate and administer our products and services, including dealing with your complaints and fixing our mistakes, we will use: (a) Your contact details; (b) Your location data for fraud prevention and, if you have consented to it, mobile location services; and (c) Your IP address to identify you for security reasons. We might share all the information we use for this purpose with third parties who help us to verify your contact details and deliver our products and services, such as our subcontractors and regulators. We use your information in this way because it is necessary to perform our contract with you and to meet our legal obligations.
6.2 To administer payments to and from you, we will use: a) Your contact details and the payment details that you have provided to us; and b) Your location data to enable us to verify locations at which payments are made for fraud prevention purposes. We may give this information to our third-party payment providers to process the payment to you.
6.3 To comply with our legal obligations and to prevent crime we will use: a) Any information you have given us, that we have obtained from a third party, or that we have obtained by looking at how you use our services, where it is necessary for us to use that information to comply with a legal obligation; and b) This information may include name, address, date of birth, every country of residence/citizenship, personal identification (which may include passport number or driving licence number) your IP address, and information about any criminal convictions. We will give information to and receive information from third parties where that is necessary to meet our legal obligations, including the police, other law enforcement and government agencies and regulators.
6.4 To comply with our legal obligations, to support our vulnerable customers: a) Information you give to us which identifies a vulnerability (such as a health condition);and b) Information we may receive from another party which identifies vulnerability. All information will be held securely. We will give information to and receive information about a vulnerability from third parties where that is necessary to meet our legal obligations, for example from police, social services or someone acting on your behalf.
6.5 For financial management and debt recovery purposes, we will use: a) Your contact details; b) Information we obtain from looking at how you have used our services, including information about your location that we may find from reviewing your accounts. We will give information to and receive information from third parties where that is necessary to recover debts due by you to us, for example, debt recovery agents, credit reference agencies and sheriff officer or bailiff services. This might include passing personal information about you to a third party who we have transferred your debt to, and who will then contact you directly to collect that debt. If your debt is transferred to a third party, you will be advised of the identity of that third party. We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so.
6.6 To carry out market research and analysis to develop and improve our products and services we will use: a) Information about how you have used our products and services.
6.7 To market products and services to you from us or our partners, we will use: a) The contact details you have provided to us; b) Information we have gathered from your use of our other products and services to form a profile of you/your organisation which we will use to assess what other products and services would be most beneficial for you. We will pass your personal information to our service providers who help us with these marketing activities. Sometimes we work with other organisations to offer you the best products and services. We will sometimes share your personal information with our partners, and receive personal information about you from our partners, to make sure that we give you the best, most relevant offers when we market to you (if you have consented). We might also receive personal information about you from a third party and use it to market our products and services to you, where you have given that third party your consent to share the personal information with us. We may collect your name and address from other service providers for the purpose of providing suitable marketing to you.
7. Our Legal Basis For Using Your Personal Information
7.1 We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where: a) We have your consent (where consent is required); b) We need to use the information to comply with our legal obligations; c) We need to use the information to perform a contract with you; and/or d) It is fair to use the personal information either in our interests or someone else’s interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services. Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent.
7.2 Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your, age, health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership, qualifications/accreditations, criminal convictions or allegations. We will only use this kind of personal information where: a) We have a legal obligation to do so (for example to protect vulnerable people); b) It is necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises); c) It is in the substantial public interest; d) It is necessary for the prevention or detection of crime; e) It is necessary for insurance purposes; or f) You have specifically given us explicit consent to use the information.
8. Sharing Your Personal Information Or Getting Your Personal Information From Others
8.1 We will share personal information within our organisation and with others outside providers where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so. We will only share your personal information to the extent needed for those purposes.
8.2 Who we share your personal information with depends on the products and services we provide to you and the purposes we use your personal information for. For most products and services, we will share your personal information with our own service providers such as our IT suppliers.
8.3 Most of the time the personal information we have about you is information you have given to us or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties for example Local Education Authority, Diocese, Department for Education or the organisation you are affiliated for example education provider.
8.4 We do not share or transfer your data outside of the European Economic Area.
9. How Long We Keep Your Personal Information For
9.1 How long we keep your personal information for depends on the products and services we deliver to you. We will never retain your personal information for any longer than is necessary for the purposes we need to use it for. We will not use your personal information for marketing purposes once you no longer have any active products or services with us. We keep the other personal information we use for seven years after contract termination or from the date you last used one of our services. We may hold information relating to pension facilities for up to 15 years from the date of expiry of the account. In some circumstances we will hold personal information for longer where necessary for active or potential legal proceedings, to resolve or defend claims, and for the purpose of making remediation payments.
10. Keeping Up To Date
10.1 We will communicate with you about products and services we are delivering using any contact details you have given us – for example by post, email, text message, social media, and notifications on our app or website.
17th July 2020, reviewed on 23rd September 2022.