THE SCHOOLS HR CO-OPERATIVE LTD – PRIVACY POLICY & COOKIES POLICY


Effective Date: 25 May 2018

Last Update: 31 October 2019


PRIVACY POLICY


Definitions

“Data Protection Legislation” refers to the General Data Protection Regulation (GDPR) and Data Protection Act 2018, and any subsequent amendments to this legislation.

“Personal Data” has the same meaning as the definition in Article 4(1) of the General Data Protection Regulation and includes ‘special categories of personal data’ as defined in Article 9(1) of the General Data Protection Regulation. For the purposes of this definition “personal information” has the same meaning as “personal data”.

“Secure Section of Our Website” refers to the secure section of the website that requires a user account to access restricted content, features, and functionality in relation to our services.

“The Website” or “Our Website” refers to www.schoolshrcooperative.co.uk and includes the secure section of our website.

“The Services” or “Our Services” or “Services” refers to any of our services that may enable you to access restricted content, features, and functionality in the secure section of our website.

“User Account” refers to any account on our website that you may register, or be registered for, in order to use certain aspects of our services.

“We”, “Us”, and “Our” means The Schools HR Co-operative Limited (“The SHRC” or “SHRC”) and should be construed accordingly.

“You” and “Your” refers to any individual accessing the website.

Put Simply: These definitions clarify how to interpret certain phrases used in our privacy policy and who we are referring to.

1. Introduction

www.schoolshrcooperative.co.uk is a website owned and operated by The Schools HR Co-operative Limited (SHRC). The SHRC is a specialist provider of education specific HR & recruitment solutions, we provide a range of HR-related services to schools, and recruitment related services to recruiting organisations and job seekers. Our Website acts as a medium that enables us to provide such Services, in part or in totality. To provide certain services and/or certain aspect of Services, we must process Personal Data including sensitive Personal Data (referred to as ‘special categories of personal data’ for the purpose of this policy) – in doing so, the SHRC may act as data controller or data processor as defined in Data Protection Legislation.

This Privacy Policy explains how we use the Personal Data we collect about You when You use Our Website, the legal basis on which we rely to collect such information, how We process, share, and store Your information, and what Your rights are in relation to managing or removing information held by Us.

Put Simply: By reading this privacy policy you can expect to understand what we do with information you share with us.

2. What personal information we collect from you

The categories of personal data (personal information) that we collect from You, are determined by Your use of Our Website and Services, and the Services that You use.

The categories of personal data that we may collect from you include:

  • Personal information such as name, address, telephone numbers, email address
  • Device information such as information about the device you have used to access our website, this includes information such as the device type, operating system and hardware/ software version used, screen resolution (this information is anonymised and aggregated i.e. not personally identifiable when collected)
  • Network and usage information such as information about the network you use to access our website, and what content you interact with when you visit our website, this includes your IP address, the name of your internet service provider, language, time zone, country, city (this information is anonymised and aggregated i.e. not personally identifiable when collected).
Put Simply: Personal information can be placed in a number of categories. This section describes the different types of information we may collect from.

3. How we collect your personal information

GENERAL USE OF OUR WEBSITE

This category of users includes any individual accessing Our Website, with or without a registered User Account of any kind. We collect the following category of personal data (personal information) when any user accesses Our Website, at any time and for any purpose:

  • Device information
  • Network and usage information.

We collect such information from Our Website and through the use of cookies set by us and/or our third-party service providers. Further information about Our use of cookies can be found in Our Cookies Policy.

REGISTERED USERS

When You use any Services that require registration for a user account, We collect the following categories of personal data (in addition to any category noted under ‘General Use of Our Website’):

  • Personal information.

We collect such information from Our Website, when You complete and save, or submit, any registration form, user account, or other personal information on Our Website.

Put Simply: We can collect different types of personal information from you when you use our website, register with us, submit forms through our website or are involved in a recruitment process that we are supporting.

4. Why we collect your personal information and how we use it

GENERAL USE OF OUR WEBSITE

We collect anonymised statistical information on all users of Our Website, for the purpose of monitoring user interaction and behaviour on Our Website. Such information is collected and stored in the aggregate, and completely anonymised. We use this data for the following purposes:

  • to assist us in making improvements to Our Website and/or Our Services
  • to generate internal reports about the use of Our Website and/or Our Services
  • to provide Our customers, advertisers, and suppliers, with statistical information.

AUTOMATED DECISION-MAKING

We do not use automated decision-making on Our Website.

Put Simply: We collect your information in order to provide our services to you and communicate with you. We use statistical information to understand how our services are being used and to make improvements to our services. Automated decision-making is not used on our website.

5. The lawful basis on which we process this information

We rely on one or more of the following grounds to legally collect and process your personal information:

  • Processing is necessary to fulfil a contract – We will process Your personal information, where necessary, for the performance of the contract which we have with You or Your school
  • You have provided consent – We will process Your personal information, where You have consented to us doing so. For example, We rely on Your consent to send You marketing notifications by email. You have the right to withdraw this consent at any time. Where consent is the only legal basis for processing certain aspects of Your personal information, We will cease to process that personal information if You withdraw Your consent. Any such withdrawal of consent will not affect the lawfulness of any prior use of that personal information, before the date of withdrawal.
  • It is in our legitimate interests and these interests do not override your data protection rights - We may process certain aspects of Your personal information, when it is in our legitimate interests to do so, and where these interests do not override Your data protection rights. Our legitimate interests include:
    • Internal analysis and statistical reporting (of anonymised and aggregated data) based on the Services We provide and Our performance of those Services
Put Simply: We can only process information if we have legal grounds to do so, and these are our legal grounds.

6. How we store your information and how long we retain it

We take all reasonable steps to protect Your personal information from unauthorised access, accidental loss, destruction, and/or damage.

All personal information that we collect from You is, where possible, stored and processed inside the European Union (EU). There are certain circumstances that require us to transfer certain aspects of Your Personal Data outside the EU. In such circumstances, We take all reasonable steps to ensure that any personal information transferred is not excessive (We will only transfer information that is essential for the provision of Our Services), is treated securely, and in accordance with this Privacy Policy and Data Protection Legislation.

TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION (EU)

We use third-party service providers outside the EU for the following aspects of Our Services:

  • Email communications relating to Our Services including (but not limited to): notifications regarding our Service Level Agreement (SLA) purchasing and subscription process, newsletters and important notices, model policy updates, and training & development course booking registration and notifications
  • Email communications relating to invoicing for Our Services
  • Administrative notifications associated with Our Services (e.g. automated email notifications from the SHRC website)
  • Analytics information relating to Our Website traffic and usage
  • Optimisation of Our Website’s performance.

Countries outside the EU may not have the same level and standard of data protection legislation that is applicable to countries within the EU. We will only transfer your personal information to non-EU based third-party service providers where:

  • The third-party service provider is in a non-EU country that is recognised by the European Commission as a country that provides an adequate level of protection for personal data; or
  • The third-party service provider is based in the United States (U.S.) and can certify that it complies with the EU-U.S. Privacy Shield Framework, designed by the U.S. Department of Commerce and the European Commission, to ensure the transference of personal data complies with data protection requirements.

RETENTION OF PERSONAL INFORMATION

We will only keep your personal information for as long as we reasonably require it to provide Our Services. Our data retention periods are determined by the type of personal information we hold, and why we hold this information. Any personal information we retain is held in accordance with the principles of Data Protection Legislation, other relevant applicable legislation, and operational retention needs.

User Account – Retained until our provision of service ceases or you request deletion of your account.

  • Personal information that You provide to Us for the purpose of holding a User Account will be retained until it is no longer necessary to provide Our Services or until You or Your school (employer) request that We delete Your User Account or We cease to have a relevant contract with Your school (employer), whichever occurs first.

Finance-Related Information – Retained for a period of six (6) financial years.

  • Personal information relating to invoices that We have Issued to You or Your school (employer) for Services that We have provided to You or Your school (employer) will be retained for a period of six (6) financial years.
Put Simply: In most cases your information is stored and processed in the European Union (EU), but some aspects of our services require us to transfer some of your information outside of the EU. We take care to make sure your information is treated securely in all cases. We will not retain your information for longer than necessary and we have defined retention periods, where appropriate, to make you aware of how long we keep your information.

7. Who we share your information with and why we share it

Personal information provided to Us by You, is not shared with third parties unless it is necessary for Us to do so for the purpose of the performance of contracts for Our Services, or We are permitted to do so with Your consent, or required to do so by law or in line with Our policies. In such cases, We may make personal information available to:

OUR SERVICE PROVIDERS

Certain aspects of personal information You provide to Us may be shared with third-party providers who assist Us to carry out Our business activities and therefore enable Us to provide and deliver those Services to You. Our third-party service providers include:

  • ICT (Information and Communications Technology) Systems and Website Support Service Providers
  • Email Delivery Service Providers (including those outside of the EU who comply with the EU-U.S. Privacy Shield Framework)
  • Data Storage and Hosting Service Providers.

OTHER CIRCUMSTANCES

In certain circumstances We may disclose Your personal information to other third parties such as governmental authorities, law enforcement agencies, and data protection regulators, if We are required to do so by law.

Put Simply: In the course of providing our services to you, we will need to share some aspects of your personal information. This section explains who we may share information with.

8. What rights you have for accessing and removing this information

Under Data Protection Legislation You have certain rights relating to the information we hold on You.

ACCESSING YOUR INFORMATION

You have the right to request access to information that we hold about You. To request such information, You will need to make a Subject Access Request (SAR). All SARs are processed in accordance with our Subject Access Request Policy.

RECTIFYING YOUR INFORMATION

You have the right to amend or delete any information that we hold on You that You believe is inaccurate. You can rectify information held in your User Account by Logging In or by contacting us.

If You believe any other information we hold on You is inaccurate e.g. an SLA form you have submitted, You will need to contact us.

OBJECTING TO YOUR INFORMATION BEING PROCESSED FOR DIRECT MARKETING PURPOSES

You have the right to withdraw your consent to receive communications from us relating to non-essential services. This currently relates to the following aspect of Services that may be offered by Us:

  • Marketing Email Alert.

If You have consented to receiving these communications, You can withdraw Your consent at any time by Logging In to Your User Account and amending your Marketing Email Alert preferences or by contacting Us.

DELETING YOUR INFORMATION

You have the right to close Your User Account You hold with Us at any time and have Us delete all of Your personal information. To request closure of Your User Account and/or removal of all personal information we hold on You, please contact Us. Please note that if You request Us to close Your User Account You will no longer have access to the Secure Section of Our Website and therefore You will not be able to access restricted content, features, or functionality on Our Website.

REPORTING CONCERNS

If You have a concern about the way We are collecting or using your personal data, We ask that You raise Your concern with Us in the first instance. Alternatively, You can contact the Information Commissioner’s Office (ICO) at: https://ico.org.uk/concerns/

FURTHER INFORMATION AND HOW TO CONTACT US

If You would like to discuss anything in this Privacy Policy, or contact Us about the information we hold on You, please contact our Data Protection Officer (DPO):

By email: dataprotection@schoolshr.net

In writing to: Data Protection Officer, The Schools HR Co-operative Ltd, Unit 1 Britannia Court, The Green, West Drayton, Middlesex, UB7 7PN

Put Simply: Data protection legislation gives you rights to access and manage the personal information that we hold on you. If you have any enquiries or requests relating to your personal information, please contact us and we would be happy to help.

9. Other websites and other data controllers

This Privacy Policy applies to this Website only. When You visit other websites and/or provide Your data to other data controllers you should review their own Privacy Policy.

Put Simply: Our privacy policy applies to our website only. We are not responsible for the privacy policies of other websites, or other data controllers.

10. Changes to this Privacy Policy

We will review this Privacy Policy regularly and reserve the right to make changes at any time to reflect changes to business and legal requirements. All updates are published on this webpage – please refer to the ‘Last Update’ date at the top of this Privacy Policy to see when this policy was last revised.

Put Simply: We may need to change this policy from time to time, if we do, we’ll post an updated version on this page.

 

COOKIES POLICY

 

1. What Are Cookies

As is common practice with most professional websites, this site uses cookies which are tiny files that are downloaded to your computer to improve your browsing experience. This page describes what information they gather, how We use it and why We sometimes need to store these cookies. We will also share how You can prevent these cookies from being stored however this may downgrade or 'break' certain elements of The Website features or functionality.

For more general information on cookies refer to http://www.allaboutcookies.org/

2. How We Use Cookies

We use two types of cookies on Our Website: cookies We set (www.schoolshrcooperative.co.uk) and cookies set by third-parties (i.e. other website and services).

We set our own cookies to help You stay logged in to Your User Account while using the Services we provide on Our Website, and to tailor information to Your site preferences.

We use cookies set by third-party providers to optimise the performance of Our Website and better understand how the features and functions of Our Website are used, so that We can improve Our Services.

As in most cases, there are no industry standard options for disabling all cookies without completely disabling the features and functionality they add to the website. It is recommended that you leave on all cookies, if You are not sure whether You need them or not, in case their purpose is to aid the provision of a Service that You may wish to use.

3. Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this).

Please be aware that disabling cookies will affect the functionality of This Website and usually result in also disabling certain features and functionality. Key functions and features that You will not be able to use, if You disable cookies on this website, include:

  • Registering for a User Account on Our Website
  • Logging in to a User Account on Our Website.

4. Cookies Set by SHRC

ACCOUNT RELATED COOKIES

If You create a User Account with Us then we Will use cookies for the management of the registration process and general administration. These cookies will usually be deleted when You log out, however, in some cases they may remain afterwards to remember Your site preferences when logged out.

LOG IN RELATED COOKIES

We use cookies when You are logged in so that We can remember this fact. This prevents You from having to log in every single time You visit a new page on Our Website. These cookies are typically removed or cleared when You log out to ensure that You can only access restricted content, features, and functionality when logged in.

FORM RELATED COOKIES

When You submit data to us through a form, such as those found on a contact page or a Service Level Agreement (SLA) form, cookies may be set to remember Your user details for future correspondence.

SITE PREFERENCES COOKIES

In order to provide You with a great experience on Our Website, We provide the functionality to set Your preferences for how The Website runs when You use it. In order to remember Your preferences, We need to set cookies so that this information can be called whenever You interact with a page that is affected by Your preferences.

5. Third-Party Cookies

In some special cases We also use cookies provided by trusted third parties. The following section details which third-party cookies You might encounter through The Website.

This Website uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics is one of the most widespread and trusted analytics solutions on the web helping Us to understand how You use The Website, and ways that We can improve Your experience.

The information generated by the cookie about Your use of Our Website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information for the purpose of evaluating Your use of Our Website, compiling reports on website activity, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google undertakes not to associate your IP address with any other data held by Google.

For further information on how Google uses data collected from its partners’ sites please follow this link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

You can prevent the setting of third-party cookies by adjusting the settings on your browser (see Your browser Help for how to do this). Alternatively, to opt out of Google Analytics please go to the following link: https://tools.google.com/dlpage/gaoptout

By using This Website, You consent to the processing of data about You by Google, in the manner and for the purposes set out above.

If You choose to disable third-party cookies, this may also affect Your ability to access the full features and functions of This Website.

6. List of Cookies

Please see the list below for details of cookies used on our website:

 

Cookie name

Purpose

Expiry

__cfduid

This cookie is necessary for security features on our website. It is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.

When session ends

*Required

__utma

Google Analytics Performance. This is one of the 5 main cookies set by the Google Analytics service which enables website owners to track visitor behaviourand measure site performance. This cookie lasts for 2 years by default and distinguishes between users and sessions. It is used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

__utmc

Google Analytics Performance. This is one of the 5 main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. It is set to enable interoperability with the older version of Google Analytics code known as Urchin.

End of browser session

__utmz

Google Analytics Performance. This is one of the 5 main cookies set by the Google Analytics service which stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update.

__utmt

Google Analytics Performance. This is one of the 5 main cookies set by the Google Analytics service used to throttle request rate.

10 minutes

__utmb

Google Analytics Performance.  This is one of the 5 main cookies set by the Google Analytics service used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

CKFinder_Path

Website performance. This cookie is strictly necessary for CKFinder File manager, wysiwyg editing tools and uploader developed by http://cksource.com to work

When session ends

PHPSESSIDPHP

Website performance. Default Expiration Time End of browser session. PHP uses this method to keep track of sessions. If cookies are enabled, it uses them.

When session ends

 

7. Cookies on Other Websites

Our Website may contain links to other websites which are owned and controlled by a third party. These external websites may use cookies not set or managed by Us, and different from those we use on Our Website.

8. More Information

If you would like more information, then please contact us.