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Privacy and Cookies Policy

Background:

ClassForKids understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.classforkids.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and you will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:  

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Data Protection Legislation”

means (i) the Data Protection Act 1998, until the effective date of its repeal (DPA) (ii) the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any national implementing laws, regulations and secondary legislation, for so long as the GDPR is effective in the UK, and (iii) any successor legislation to the Data Protection Act 1998 and the GDPR, in particular the Data Protection Bill 2017-2019, once it becomes law.

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by CLASS 4 KIDS LTD, a company registered in Scotland under number SC458210, whose registered office is at 6th Floor, Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ.

Data Protection Officer: Kevin Macdonnell

Email address: support@class4kids.co.uk

Telephone number: 0800 011 9443

Postal Address: Floor 3, 69 St Vincent Street, Glasgow, G2 5TF

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the GDPR as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies):

  • Name;
  • Date of birth;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • IP address;
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

7. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you or because you have consented to our use of your personal data. Your personal data will be used for the following purposes:

  • Providing and managing your Account;
  • Providing and managing your access to Our Site;
  • Personalising and tailoring your experience on Our Site;
  • Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
  • Personalising and tailoring our services for you.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by managing your account preferences.
  • Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use the following automated systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.

  • The following automated profiling may take place:
    • Recognising your child’s upcoming birthday and highlighting it to clubs that they attend
    • Using class, location, age, booking status, payment status and other status level information to enable filtering of information

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data

Retention Period or Criteria

Name and contact details for each data subject (parent)

5 years

Data subject (parent) and/or (child) address

5 years

Data subject (child) name, date of birth and gender

5 years

Name, telephone number and relationship to child for emergency contacts

5 years

Any medical information that a parent deems relevant to their child’s participation in classes

5 years

Answers to any additional questions that a specific club deem relevant to their Club or activity

5 years

Notes taken by a Club connecting to a specific data subject (child)

5 years

Technical activity tracking during use of Our Site

90 days

9. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. From time to time it may be necessary to store or transfer personal data outwith the EEA and where such storing or transferring is required we will only do so in accordance with the Data Protection Legislation.  

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Personal data may be transmitted over secure networks only, transmission over unsecured networks is not permitted in any circumstances;
  • Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
  • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using permanent deletion of the email from trash;
  • Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient; and
  • All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.
  • No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on our behalf requires access to any personal data that they do not already have access to, such access should be formally requested from Kevin Macdonell support@class4kids.co.uk ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. tel: 0800 011 9443;
  • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on our behalf or not, without the authorisation of Kevin Macdonell support@class4kids.co.uk ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. tel: 0800 011 9443;
  • Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
  • If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
  • Where personal data held by us is used for marketing purposes, it shall be the responsibility of Kevin Macdonell support@class4kids.co.uk ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. tel: 0800 011 9443 to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
  • All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must follow recognised industry best practises. All software used by us is designed to require such passwords;
  • Under no circumstances are passwords to be written down or shared between any employees, agents, contractors, or other parties working on our behalf, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. Our IT staff do not have access to passwords;
  • All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. Our IT staff shall be responsible for installing any and all security-related updates not more than six months after the updates are made available by the publisher or manufacturer;
  • No software may be installed on any of our owned computers or devices without the prior approval of the Kevin Macdonell support@class4kids.co.uk ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. tel: 0800 011 9443.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

11.1  In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account.

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the purposes described below. In addition, Our Site uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.

 

Type of Cookie

First / Third Party

Provider

Purpose

Functional

First

ClassForKids

ClassForKids use cookies and log file data to gather information on platform visitor activity. We use this information to facilitate the use of the platform and help to improve the services we provide to our users. They allow us to identify that you are moving from page to page and maintain data as you do so. This means we can, for example, keep you logged in as you browse the site.

Payment

Third

Stripe

We use Stripe to facilitate payments. Stripe cookies on Our Website enable secure payments. This means that we can, for example, process a credit card payment for your class booking. 

Support

Third

Intercom

We use Intercom to provide customer support. Intercom cookies enable information about customer experience to be passed to our support team to help them better understand problems if you get in touch. This means, for example, that we can tell which web browser or device you are using.

Analytics

Third

Google

We use Google analytics to track traffic and usage patterns on Our Site. Google cookies on Our Site enable us to analyse how visitors are using Our Site and help us to make informed decisions on how to improve it.

Campaign management

Third

Google

We use Google advertising to track the incoming results of advertising that we run on Google’s advertising network. Google advertising cookies on Our Site enable us to analyse how our advertising is performing.

Social

Third

Social (Twitter, Facebook etc)

We use cookies from social sharing sites like Facebook and Twitter so that we can share content that you find interesting via your social networks.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: support@class4kids.co.uk

Telephone number: 0800 011 9443

Postal Address: Floor 3, 69 St Vincent Street, Glasgow, G2 5TF.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

 

Data Protection Policy

Please note: this version remains subject to any other additional revisals we might consider necessary between now and 25th May 2018

1. Introduction

This Policy sets out the obligations of CLASS 4 KIDS LTD, a company registered in Scotland under number SC458210, whose registered office is at 6th Floor, Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ (“the Company”) regarding data protection and the rights of customers (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject

2.2 Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes

2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

2.6 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

 3. The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details)

3.1 The right to be informed (Part 12).

3.2 The right of access (Part 13);

3.3 The right to rectification (Part 14);

3.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 15);

3.5 The right to restrict processing (Part 16);

3.6 The right to data portability (Part 17);

3.7 The right to object (Part 18); and

3.8 Rights with respect to automated decision-making and profiling (Parts 19 and 20).

4. Lawful, Fair, and Transparent Data Processing

4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies.

4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;

4.1.2 The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;

4.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;

4.1.5 The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

4.1.6 The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4.2 If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

4.2.1 The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

4.2.2 The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

4.2.3 The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

4.2.4 The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

4.2.5 The processing relates to personal data which is clearly made public by the data subject;

4.2.6 The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

4.2.7 The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

4.2.8 The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

4.2.9 The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); o

4.2.10 The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5. Specified, Explicit, and Legitimate Purposes

5.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:

5.1.1 Personal data collected directly from data subjects; and

5.1.2 Personal data entered by third-parties who are in contact with parents and children as part of activity provision.

5.2 The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).

5.3 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed

6. Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below

7. Accuracy of Data and Keeping Data Up-to-Date

7.1 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.

7.2 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8. Data Retention

8.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

8.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

8.3 For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

9. Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10.1 Accountability and Record-Keeping

10.1 The Company’s Data Protection Officer is Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443.

10.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.

10.3 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

10.3.1 The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;

10.3.2 The purposes for which the Company collects, holds, and processes personal data;

10.3.3 Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

10.3.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

10.3.5 Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and

10.3.6 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11. Data Protection Impact Assessments

11.1 The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.

11.2 Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

11.2.1The type(s) of personal data that will be collected, held, and processed;

11.2.2 The purpose(s) for which personal data is to be used;

11.2.3 The Company’s objectives;

11.2.4 How personal data is to be used;

11.2.5 The parties (internal and/or external) who are to be consulted;

11.2.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

11.2.7 Risks posed to data subjects;

11.2.8 Risks posed both within and to the Company; and

11.2.9 Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed

12.1 The Company shall provide the information set out in Part 12.2 to every data subject:

12.1.1 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

12.1.2 Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

12.1.3 if the personal data is used to communicate with the data subject, when the first communication is made; or

12.1.4 if the personal data is to be transferred to another party, before that transfer is made; or

12.1.5 as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

12.2 The following information shall be provided:

12.2.1 Details of the Company including, but not limited to, the identity of its Data Protection Officer;

12.2.2 The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;

12.2.3 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

12.2.4 Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

12.2.5 Where the personal data is to be transferred to one or more third parties, details of those parties;

12.2.6 Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);

12.2.7 Details of data retention;

12.2.8 Details of the data subject’s rights under the GDPR;

12.2.9 Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

12.2.10 Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);

12.2.11 Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

12.2.12 Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data Subject Access

13.1 Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

13.2 Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443.

13.3 Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

13.4 All SARs received shall be handled by the Company’s Data Protection Officer.

13.5 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14. Rectification of Personal Data

14.1 Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

14.2 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

14.3 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

15. Erasure of Personal Data

15.1 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

15.1.1 It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

15.1.2 The data subject wishes to withdraw their consent to the Company holding and processing their personal data;

15.1.3 The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);

15.1.4 The personal data has been processed unlawfully;

15.1.5 The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

15.3 In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so)

16. Restriction of Personal Data Processing

16.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17. Data Portability

17.1 The Company processes personal data using automated means. Secure input and transmission of data over the internet, processing on secure servers, storage in encrypted format in secure databases, decryption and encrypted transmission over the internet to secure systems accessible only by authorised users

17.2 Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers)

17.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:

  17.3.1 security protected online forms, printed forms (by specific request)

17.4 Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.

17.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed

18. Objections to Personal Data Processing

18.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling).

18.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

18.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

19. Automated Decision-Making

19.1 The Company uses personal data in automated decision-making processes. Date of birth may be used to select an individual based on their age, class attendance data may be used to select an individual based upon their attendance activity.

19.2 Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge to such decisions under the GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.

19.3 The right described in Part 19.2 does not apply in the following circumstances:

19.3.1 The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;

19.3.2 The decision is authorised by law; or

19.3.3 The data subject has given their explicit consent.

20. Profiling

20.1 The Company uses personal data for profiling purposes. The ClassForKids Platform or any club using the platform may use age, location, communication activity, payment methods, payment date, gender, attendance, device details or other information relevant to understanding customer behaviour.

20.2 When personal data is used for profiling purposes, the following shall apply:

20.2.1 Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;

20.2.2 Appropriate mathematical or statistical procedures shall be used;

20.2.3 Technical and organisational measures shall be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and

20.2.4 All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 to 26 of this Policy for more details on data security).

21 Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

 

Data Ref.

Type of Data

Purpose of Data

Parent

Name and contact details for each parent

Clubs need to know who parents are and communicate with them

Location

Parent/Child address

Clubs understanding the location of their customers; ClassForKids understanding the location of platform users

Child

Child name, date of birth and gender

Clubs need to know each child and may make class or facility choices based upon age or gender

Emergency

Name, telephone number and relationship to child for emergency contacts

Clubs need to have instant access to direct contacts in case of emergency

Medical

Any medical information that a parent deems relevant to their child’s participation in classes

Clubs may make specific arrangements depending on the medical needs of children

Custom

Answers to any additional questions that a specific club deem relevant to their club or activity

Clubs may use the answers to these questions to make business or activity related decisions

Club notes

Notes taken by a club connecting to a specific child

Internal notes connecting to a specific child that help the club to make business or activity related decisions

Technical

Technical activity tracking during platform use

To understand platform usage for the purpose of improving the platform; To diagnose and correct technical issues arising through platform use

 

22. Data Security - Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

22.1 All emails containing personal data must be encrypted;

22.2 All emails containing personal data must be marked “confidential”;

22.3 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

22.4 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

22.5 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using permanent deletion of the email from trash;

22.6 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

22.7 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient; and

22.8 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”. 

23.  Data Security - Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

23.1 All electronic copies of personal data should be stored securely using passwords and data encryption;

23.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;

23.3 All personal data stored electronically should be backed up daily with backups stored offsite. All backups should be encrypted.

23.4 No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Kevin Macdonell, CTO, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443, and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and

23.5 No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

24. Data Security - Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

25. Data Security - Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

25.1 No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443;

25.2 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443;

25.3 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

25.4 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

25.5Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Data Protection Officer to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

26. Data Security - IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

26.1 All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must follow recognised industry best practises. All software used by the Company is designed to require such passwords.;

26.2 Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

26.3 All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates not more than six months after the updates are made available by the publisher or manufacturer OR as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and

26.4 No software may be installed on any Company-owned computer or device without the prior approval of the Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443.

27. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

27.1 All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;

27.2 Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

27.3 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

27.4 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

27.5 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

27.6 Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

27.7 All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

27.8 The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

27.9All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

27.10 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

27.11 Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

28. Transferring Personal Data to a Country Outside the EEA

28.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

28.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

28.2.1 The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

28.2.2 The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

28.2.3 The transfer is made with the informed consent of the relevant data subject(s);

28.2.4 The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

28.2.5 The transfer is necessary for important public interest reasons;

28.2.6 The transfer is necessary for the conduct of legal claims;

28.2.7 The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

28.2.8 The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

29. Data Breach Notification

29.1 All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

29.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

29.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

29.4 Data breach notifications shall include the following information:

29.4.1 The categories and approximate number of data subjects concerned;

29.4.2 The categories and approximate number of personal data records concerned;

29.4.3 The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

29.4.4 The likely consequences of the breach;

29.4.4 Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

30. Implementation of Policy

This Policy shall be deemed effective as of 25/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

CLASS 4 KIDS LTD

Data Retention Policy

Please note: this version subject to any other additional revisals we might consider necessary between now and 25th May 2018 

1. Introduction

This Policy sets out the obligations of CLASS 4 KIDS LTD, a company registered in Scotland under number SC458210, whose registered office is at 6th Floor, Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

b) When the data subject withdraws their consent;

c) When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i.e. in breach of the GDPR);

e) When the personal data has to be erased to comply with a legal obligation; or

f) Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company for activity booking, payment, management, analysis and promotional purposes, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.

 

2. Aims and Objectives

2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.

2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

3. Scope

3. 1 This Policy applies to all personal data held by the Company for activity booking, payment, management, analysis and promotional purposes and by third-party data processors processing personal data on the Company’s behalf.

3.2 Personal data, as held by the Company is stored in the following ways and in the following locations:

a) The Company’s servers, located in Glasgow, Scotland;

b) Third-party servers, operated by Amazon Web Services, Inc and located in Dublin, Ireland;

c) Computers permanently located in the Company’s premises at Glasgow, Scotland;

d) Laptop computers and other mobile devices provided by the Company to its employees;

e) Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Bring Your Own Device (“BYOD”) Policy

f) Physical records stored in Glasgow, Scotland;

4. Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.

4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in Parts 12 and 13 of the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling , as set out in Parts 14 to 20 of the Company’s Data Protection Policy.

5. Technical and Organisational Data Security Measures

5.1 The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:

a) All emails containing personal data must be encrypted;

b) All emails containing personal data must be marked “confidential”;

c) Personal data may only be transmitted over secure networks;

d) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

e) Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;

f) Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

g) Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure delivery service;

h) All personal data transferred physically should be transferred in a suitable container marked “confidential”;

i) No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Protection Officer.

j) All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;

k) No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

l) Personal data must be handled with care at all times and should not be left unattended or on view;

m) Computers used to view personal data must always be locked before being left unattended;

n) No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise;

o) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;

p) All personal data stored electronically should be backed up every day with backups stored offsite. All backups should be encrypted;

q) All electronic copies of personal data should be stored securely using passwords and encryption;

r) All passwords used to protect personal data should be changed regularly and should must be secure;

s) Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

t) All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

u) No software may be installed on any Company-owned computer or device without approval; and 

v) Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.

a) Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in Parts 12 and 13 of the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

b) Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling , as set out in Parts 14 to 20 of the Company’s Data Protection Policy.

w) Technical and Organisational Data Security Measures

a) The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:

5.1.2.1 All emails containing personal data must be encrypted;

5.1.2.2 All emails containing personal data must be marked “confidential”;

5.1.2.3 Personal data may only be transmitted over secure networks;

5.1.2.4 Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

5.1.2.5 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;

5.1.2.6 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

5.1.2.7 Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure delivery service;

5.1.2.8 All personal data transferred physically should be transferred in a suitable container marked “confidential”;

5.1.2.9 No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Protection Officer.

5.1.2.10 All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;

5.1.2.11 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

5.1.2.12 Personal data must be handled with care at all times and should not be left unattended or on view;

5.1.2.13 Computers used to view personal data must always be locked before being left unattended;

5.1.2.14 No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise;

5.1.2.15 No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;

5.1.2.16 All personal data stored electronically should be backed up every day with backups stored offsite. All backups should be encrypted;

5.1.2.17 All electronic copies of personal data should be stored securely using passwords and encryption;

5.1.2.18 All passwords used to protect personal data should be changed regularly and should must be secure;

5.1.2.19 Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

5.1.2.20 All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

5.1.2.21 No software may be installed on any Company-owned computer or device without approval; and

x)

5.2 The following organisational measures are in place within the Company to protect the security of personal data. Please refer to Part 27 of the Company’s Data Protection Policy for further details:

a) All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Data Protection Policy;

b) Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;

c) All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

d) All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;

e) All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;

f) Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

g) The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

h) All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Data Protection Policy;

i) All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Data Protection Policy;

j) Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

2. Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

2.1 Personal data stored electronically (including any and all backups thereof) shall be deleted securely using the sql update statement with anonymised data method; 2.2 Personal data stored in hardcopy form shall be shredded;

3. Data Retention

3.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

3.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

3.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

a) The objectives and requirements of the Company;

b) The type of personal data in question;

c) The purpose(s) for which the data in question is collected, held, and processed;

d) The Company’s legal basis for collecting, holding, and processing that data;

e) The category or categories of data subject to whom the data relates;

f) The convenience of future bookings with any club using the ClassForKids platform for a child or their siblings as they progress through childhood.

3.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

3.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

 

Data Ref.

Type of Data

Purpose of Data

Review Period

Retention Period or Criteria

Parent

Name and contact details for each parent

Clubs need to know who parents are and communicate with them

Each time a new booking is made on the ClassForKids platform

5 years

Location

Parent/Child address

Clubs understanding the location of their customers; ClassForKids understanding the location of platform users

Each time a new booking is made on the ClassForKids platform

5 years

Child

Child name, date of birth and gender

Clubs need to know each child and may make class or facility choices based upon age or gender

Each time a new booking is made on the ClassForKids platform

5 years

Emergency

Name, telephone number and relationship to child for emergency contacts

Clubs need to have instant access to direct contacts in case of emergency

Each time a new booking is made on the ClassForKids platform

5 years

Medical

Any medical information that a parent deems relevant to their child’s participation in classes

Clubs may make specific arrangements depending on the medical needs of children

Each time a new booking is made on the ClassForKids platform

5 years

Custom

Answers to any additional questions that a specific club deem relevant to their club or activity

Clubs may use the answers to these questions to make business or activity related decisions

Each time a new booking is made with the specific club who asked the questions

5 years

Club notes

Notes taken by a club connecting to a specific child

Internal notes connecting to a specific child that help the club to make business or activity related decisions

Each time a child is booked onto a new term or camp

5 years

Technical

Technical activity tracking during platform use

To understand platform usage for the purpose of improving the platform; To diagnose and correct technical issues arising through platform use

None. The data will be automatically recorded and reflect the technology and network activity during each user session.

90 days


4. Roles and Responsibilities

4.1 he Company’s Data Protection Officer is Kevin Macdonell, support@classforkids.co.uk, ClassForKids, Floor 3, 69 St Vincent Street, Glasgow, G2 5TF. 0800 011 9443.

4.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.

4.3 The Data Protection Officer shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.

4.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.

5. Implementation of Policy

This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.