Privacy Policy 2019-05-08T14:19:03+01:00

PRIVACY POLICY

Introduction

At Form the Future CIC (“FTF”), we respect your privacy and are committed to protecting your personal information. This Privacy Policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure in accordance with the General Data Protection Regulation ((EU) 2016/679) and, when enacted, the Data Protection Act 2018 (UK) (together referred to as the “GDPR”).

This Privacy Policy applies to current and former clients (including, but not limited to, schools, industry partners and students), members of our workforce (including employees and consultants, agency workers, advisers and self- employed consultants), vendors, other third parties with whom we work and other persons.

This Privacy Policy was last updated on 1st February 2019. This policy may change from time to time so please check this page occasionally.

Controller

FTF is the controller and responsible for your personal data (collectively referred to as “FTF”, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please get in touch with our data privacy manager using the contact details set out below:

Data Privacy Manager: Michaela Eschbach
Company Name: Form the Future CIC
Telephone: 01223 781296
Email: info@formthefuture.org.uk
Address: Future Business Centre, 47 Norfolk Street, Cambridge CB1 2LD

The data we collect about you

“Personal data” is any information about a living individual from which they can be identified such as name, ID number, location data, any online identifier, or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.

There are “special categories” of sensitive personal data which are more private in nature and therefore require a higher level of protection, such as genetic data, biometric data, sexual orientation, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and health information.

When we refer to “processing,” this means such processes as collecting, using, storing, transferring, disclosing, altering, or destroying personal data.

The information we hold about you will fall into one or more of the following indicative categories:

  • Name, title, address, phone number(s), email address, photograph, social media contact details;
  • Date of birth, nationality, marital status, family details;
  • Unique pupil Identifyer/ number
  • Current and previous employment details, tax status, job title, salary, pension, and insurance details;
  • Academic and other education details;
  • Medical details or Special Need Status;
  • Travel details for business travel;
  • PC login and other electronic password details;
  • Phone and internet use history;
  • Details regarding meetings of a business nature;
  • Criminal records and convictions; and
  • Disciplinary records.

Some of this information may fall within the special categories of information mentioned above.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

How is your personal data collected

We use different methods to collect data from which we have explained below:

A. Personal data you give to us

This is information about you that you provide to us voluntarily in the following ways:

  • through your instructions to us;
  • when joining FTF as an employee, consultant, volunteer, mentor, mentee or partner;
  • via our website (formthefuture.org.uk); or
  • corresponding with us by phone, surveys, personal interactions, email or otherwise.

Please note that when you sign up as a volunteer or mentor, or register to work with us as an individual, school or business, you are stating that you are over 18 years of age, or a minor acting with parental consent. You agree that any information you provide to us about yourself upon registration or at any time is true.

B. Personal data third parties give to us in respect of other individuals

 This is information about individuals that third parties provide to us voluntarily in the following ways:

  • through instructions to us;
  • when joining FTF as an employee, consultant, volunteer, mentor, mentee or partner;
  • via our website (formthefuture.org.uk); or
  • corresponding with us by phone, surveys, personal interactions, email or otherwise.

Third parties that provide us with individual information agree that any information provided to us about the individuals upon registration or at any time is true and that you have consent or authority to disclose such information about the individual.

C. Personal data we collect about you electronically

When you use our website or our services, or as an employee of FTF, the categories of personal data that we may collect about you may include: details of your visits to our website, including, but not limited to traffic data, location data and other communication data and any electronic resources you access. Any information collected via our website will include data provided to us at the time of registering to use our website, subscribing to the services we provide or requesting further information. We may also ask you for information when you report a problem with our website. If you complete any survey for us for research purposes, we will collect information in such circumstances as well. The personal data you may give us includes, but is not limited to, your name, address, email address, phone number, DBS certificate numbers and issue dates, gender and any responses to any surveys.

We may automatically collect technical information, including anonymous data collected by our hosting server for statistical purposes, the Internet Protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform or other identification tags. Please see cookies below for further information.

We may collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system, and platform. We also collect contact information from email communications addressed to us.

We may also collect, store, and use your special category personal data for a range of reasons, relying on a variety of different bases for lawful processing under the GDPR, as described below.

D. Personal data we receive from third parties about our (including prospective) employees, consultants, volunteers, schools, industry partners and ambassadors

We may obtain personal information and/or special category personal information about you from third party sources, such as recruitment agencies, job boards, benefits providers, companies and background check providers (including Disclosure and Barring Service). Where we receive such information we will only use it in accordance with this Privacy Policy. In some cases, the third party source will be acting as controller of your personal information and therefore, we advise you to read their privacy or data protection policy.

How and why we use your personal data

The purposes for which we use your information and the legal bases under data protection laws on which we rely to do this are explained below:

A. Where you have provided consent

We may use and process your personal information where you have consented for us to do so.

  1. For clients and prospective clients (including, but not limited to, schools, industry partners and students)This may include sending you information about our services or change of policies if you:
    • are an existing client;
    • sign up to receive communications from us (e.g. our newsletters or invitations to new opportunities); and
    • update your contact details or preferences when responding from a request for us to do so.
  2. For employees, consultants and prospective employees and consultantsThis may include:
    • information disclosed to a third party agency/mortgage provider relating to your pay details and/or employment history for the purposes of providing tenancy references/mortgage application;
    • information disclosed to a prospective future employer relating to your employment details for the purposes of providing a reference; and
    • generally, information disclosed to a third party at your request, such as for tax filings.

    You may withdraw your consent for us to use your information in any of these ways at any time. Please contact us using the contact details provided above to do so.

  3. How we use your special category informationConsistent with your consent, we may:
    • use details regarding allergies to ensure that catering provided at our events accommodates your needs; or
    • use your special category personal data in certain situations which we have explained the reasons for doing so e.g. to share a student’s medical or special requirements with a business so that they can accommodate them at a project day on-site.

    Where you have consented to specific processing of your personal or special category information, you have the unequivocal right to withdraw your consent at any time by indicating your withdrawal in a written format addressed to the data privacy manager using the contact details set out above.

B. Where there is a legitimate interest

We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business, or that of a third party.

  1. For clients and prospective clients (including, but not limited to, schools, industry partners and students)This may include sending you information about our services or change of policies if you:
    • for marketing activities (other than where we rely on your consent to contact you about our services);
    • for analysis to inform our marketing strategy and to personalise your client experience;
    • to correspond or communicate with you;
    • to verify the accuracy of data that we hold about you;
    • for the provision of services to you, including where the personal data relates to persons who are not our clients;
    • for the prevention of fraud or criminal activities;
    • to comply with a request from you in connection with the exercise of your rights;
    • invoicing you for our fees and disbursements;
    • for the management of queries, complaints or claims; and
    • for the establishment and defence of our legal rights.
  2. For employees, consultants and prospective employees and consultantsThis may include using your personal information:
    • appraisals and training to ensure you are properly managed and supervised;
    • information relating to the performance of your employment, such as disciplinary records;
    • to verify the accuracy of data that we hold about you;
    • for the prevention of fraud or criminal activities;
    • absence records and details, including holiday records, appointments and jury service;
    • carrying out a disciplinary or grievance investigation or procedure in relation to you or someone else;
    • monitoring and protecting your health and safety and other third parties; and
    • monitoring diversity and equal opportunities.
  3. How we use your special category informationFor clients, this may include details of allergies or disabilities for the purposes of ensuring that we accommodate them where possible.For employees and consultants and prospective employees and consultants, this may include:
    • information about your physical or mental health or disability status to ensure your health and safety in the workplace and to provide appropriate workplace adjustments; and
    • sickness absence records.

C. Where there is a legal requirement

We will use your personal information to comply with our legal obligations: (i) to assist a regulatory or public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.

  1. For clients and prospective clientsThis may include using your personal information:
    • for the purposes of meeting your customer obligations; and
    • for the purposes of meeting tax obligations.
  2. For employees, consultants and prospective employees and consultantsThis may include:
    • your eligibility to work in the UK, as required by immigration laws (e.g. passport and visa documentation);
    • payroll records, social security, child maintenance, marital status, student loans and national insurance to comply with social security and tax requirements; and
    • pension benefits to comply with pension legislation.
  3. How we use your special category informationFor employees and consultants and prospective employees and consultants, to enable us to perform our legal obligations under employment, social security and social protection laws and to defend or exercise legal claims in any court of law, this may include:
    • information relating to leaves of absence;
    • information relating to you involving allegations of unlawful discrimination in order that an investigation may be conducted and appropriate action taken (where required); and
    • health information to assess and/or comply with our obligations under employment, equal opportunities and health and safety legislation.

D. Where it is required to comply with obligations under a contract

We may use and process your personal information where we have supplied you (or continue to supply you) with any services or where you are in discussions with us about any service. We will use this information in connection with the contract for the supply of services when it is needed to carry out that contract with you or for you to enter into it.

  1. For clients and prospective clientsThis may include:
    • your contact details; and
    • information you provide to us that we share with third parties on your behalf to meet our obligations under contracts.
  2. For employees, consultants and prospective employees and consultantsThis may include:
    • formal identification documentation relating to you (e.g. passport or driving licence);
    • bank details which are used to send/receive funds to/from you (e.g. for the payment of your salary, expenses or sick pay);
    • medical absence information; and
    • details about the terms and conditions of your employment.

E. Where it is in your vital interests

We will use your personal information to comply with our legal obligations: (i) to assist a regulatory or public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.

  1. For clients and prospective clients; and for employees, consultants and prospective employees and consultantsThis may include:
    • information about allergies or any medical conditions so as to prevent any unnecessary accidents and advise medical professionals in the event of an emergency.

Please note that some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Others who may receive or have access to your personal information

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include:

  • IT service providers (e.g. data centre and cloud hosting providers);
  • legal service providers;
  • governmental agencies (e.g. DBS Service);
  • administrative services;
  • finance/tax authorities for tax purposes; and
  • immigration authorities for immigration purposes.

When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we have an agreement in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

Other ways we may share your personal information

We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal or regulatory obligation, to detect or report a crime, to enforce or apply the terms of our contracts, or to protect the rights, property, or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

For our employees, consultants and prospective employees and consultants, we may also share your personal data and special category personal data internally. In particular, it may be shared with HR employees involved in and for the purposes of a recruitment process, administration of your employment; line managers; consultants; advisers or other appropriate persons.

Where we store your personal information

All information you provide to us is stored within the European Economic Area (EEA). If we transfer your information outside of the EEA, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.

How long we keep your personal information for

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under laws including legal, accounting and reporting requirements. We do not retain personal information in an identifiable format for longer than is necessary.

Data security and links to other websites

FTF takes great care in the selection and implementation of appropriate security measures and controls, to keep your data protected and safe. Our website is HTTPS secured and our SSL certificate can be viewed by clicking on the padlock icon next to our website address.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

Like many other websites, our website uses cookies (including Google Analytics cookies) to obtain an overall view of visitor habits and visitor volumes to our website. “Cookies” are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit. It is possible to switch off cookies by setting your web browser preferences. You can also delete cookies by clearing your web browser’s cache (history).

Marketing

We may collect your preferences to receive marketing information directly from us in the following ways:

  • Using contact details you have provided via our website.
  • From time to time, we may send you an email with instructions to update your contact details and preferences on the types of communication you receive from us.

We may contact you with targeted information delivered online through social media by using your personal data, or use your personal data to tailor marketing to improve its relevance to you, unless you object.

You have the right to opt-out of our use of your personal data to provide information to you in any of the ways mentioned below.

Your legal rights

Under certain conditions, you may have the right to require us to:

  • provide you with further details on the use we make of your personal data or special category personal data;
  • provide you with a copy of the personal data that you have provided to us;
  • update any inaccuracies in the personal data we hold;
  • delete any special category of data / personal data that we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your personal data whilst a complaint is being investigated.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests.

If you wish to exercise any of the rights, please contact our data privacy manager using the contact details provided above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Regulatory contact details

Depending on where you are resident or otherwise located, you have the right to make a complaint any time to the relevant national supervisory authority for data protection issues. In the UK, for example, you can make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk).  We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

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