Our Intent. We are committed to safeguarding the privacy of users to our website and we will only use the information we collect about you lawfully.

Transcription

1 PRIVACY NOTICE LGfL GENERAL OVERVIEW Our Intent. We are cmmitted t safeguarding the privacy f users t ur website and we will nly use the infrmatin we cllect abut yu lawfully. Changes t Data Prtectin Legislatin. Data Prtectin legislatin is currently ging thrugh a perid f change. The intrductin f the Eurpean Unin s General Data Prtectin Regulatin (GDPR) is the basis f change and will be applied frm 25 May This has just been brught int British law, with a new British Data Prtectin Act (2018), which has replaced the Data Prtectin Act (1998). This Privacy Ntice is therefre intended t cmply with GDPR and the new Data Prtectin Act Data Subject s Privacy Ntice. This Privacy Ntice shuld be read by Data Subjects, i.e. yu, r any identifiable persn using the Lndn Grid fr Learning (LGfL) services. The Data Cntrller. This website is wned and perated by LGfL. LGfL prvide a number f services fr Lndn Lcal Authrities (LAs) and schls (including nurseries and clleges), nrmally in the capacity f a Data Prcessr. This privacy ntice is intended t prvide an verview f hw LGfL manages persnal data, including n this website. Our cntact details are: dataprtectinenquiries@lgfl.net Mail: LGfL, CI Twer, St Gerges Square, New Malden, KT3 4TE. Data Prtectin Officer (DPO). LGfL have appinted a DPO wh can be reached at dataprtectinenquiries@lgfl.net. The LGfL DPO fulfils a number f rles, ne f which is t be the primary and independent pint f cntact fr Data Subjects, namely yu. The preferred mechanism fr Data Subjects t raise cncerns regarding the prcessing f their persnal data by LGfL is t r send a letter t ur cntact details abve, at which pint the enquiry will be frwarded t the DPO f the Data Cntrller r respective member f staff fr actin. Purpse f Prcessing Persnal Data When Visiting This Website. We cllect persnal data n this website primarily t supprt the delivery f infrmatin t users f this website. Lawful Basis f Prcessing Persnal Data When Visiting This Website. The lawful basis f prcessing yur persnal data when visiting this website is cnsidered t be Legitimate Interest, r what is reasnable t expect. See ur sectin n ckies belw t see the different types f ckies we use and fr what purpse n this website. Purpse f LGfL Prcessing Persnal Data Within Services. LGfL cre purpse is t help deliver educatin services fr LAs and schls. In this capacity we cllect persnal data t supprt eadmissins (see separate Privacy Ntice); Free Schl Meals Checker (see separate Privacy Ntice); StaffMail fr teachers and staff;

2 LndnMail fr pupils; and a range f educatinal tls. These are enabled by an identify access management tl, called Unified Sign-On (USO). Lawful Basis f Prcessing Persnal Data When Using LGFL Services. Unless cvered by a specific Privacy Ntice, LGfL services are nrmally delivered n the basis f Cnsent, r fr Staff, smetimes under Cntract (with the emplyer wh is the respective Data Cntrller). Categries f Persnal Data Prcessed by LGFL. The infrmatin we hld as a result f visiting this website is minimal and primarily related t the device which yu use. This may mean yu can be assciated and identified by this. Mre detailed persnal data is cllected when individual s use specific services. Acrss all LGFL prcesses and services we will seek t ensure all persnal data is accurate and up t date. The persnal data which we hld will be held securely and in accrdance with ur internal data prtectin and security plicies. Categry f Recipients f Persnal Data. LGfL acts as a Data Prcessr under the instructin f the Data Cntrllers, schls (which includes nurseries and clleges fr the purpses f this Privacy Ntice) and lcal authrities, t enable them t deliver educatin services. Data is shared with them in accrdance with their requirements. Transfer f Persnal Data Outside the EEA (Eurpean Ecnmic Area). Persnal data will nly be transferred utside the EEA r ther areas f adequacy determined by the EU, t supprt specific prcesses. If this is required, apprpriate measures will be put in place t supprt internatinal transfers. Sensitive Persnal Data. We will never cllect sensitive persnal data abut yu withut yur explicit cnsent r under the relevant lawful purpse. We will prvide a clear explanatin why it is required in the related Privacy Ntice. Sale r Passing f Persnal Data t Third Parties. We will nt sell r pass yur persnal data t any cmpany. Hwever, t supprt Safeguarding r Law Enfrcement investigatin LGfL may be required t pass persnal data utside nrmal prcesses, fr very specific and limited purpses. Retentin f Persnal Data by this Website. We will retain any data cllected n this website nly fr the perid f the sessin r n acceptance f ckies t enable yu t revisit the site again mre easily. Retentin f Persnal Data by LGfL. A master retentin plicy fr persnal data prcessed by LGfL is being cnstantly develped. This details the retentin f persnal data cllected frm yu fr different purpses. Data Subject s Rights. Under data prtectin legislatin yu have a number f Rights which we have utlined belw: Right f Access. Yu are entitled t access yur persnal data s that yu are aware f and can verify the lawfulness f the prcessing. This shuld be

3 achieved thrugh submitting the Subject Access Rights (SAR) t the Data Cntrller, which is either the schl r the hme Lcal Authrity. If yu are a data cntrller f an LGfL system and require any assistance, please lg this via the LGfL supprt website at supprt.lgfl.net. In summary, yu have the right t btain: Cnfirmatin that yur data is being prcessed; Access t yur persnal data (a cpy); and Other supplementary infrmatin, which crrespnds t the infrmatin in this Privacy Ntice. Fees and Timings. This infrmatin will be prvided withut charge; withut delay and within ne mnth. If an extensin is required r requests are cnsidered manifestly unfunded r excessive, in particular because they are repetitive, LGfL may chse t: charge a reasnable fee taking int accunt the administrative csts f prviding the infrmatin; r refuse t respnd. The reasns fr this will be frmally ntified t yu and yur rights t appeal t the apprpriate Supervisry Authrity, i.e. UK Infrmatin Cmmissiner s Office (ICO) will be highlighted. Identify Verificatin. T prtect yur persnal data, LGfL will seek t verify yur identity befre releasing any infrmatin, which will nrmally be in electrnic frmat. Right f Rectificatin. Yu are entitled t have persnal data rectified if it is inaccurate r incmplete. This can be achieved directly thrugh lgging int the LGfL USO accunt and amending the details abut yurself. Alternatively, LGfL will respnd within ne mnth f yur request. In the unlikely event LGfL des nt take actin t the request fr rectificatin, LGfL will infrm yu f yur rights t cmplain r seek judicial remedy. Right f Erasure. Yu may request the deletin r remval f persnal data where there is n cmpelling reasn fr its cntinued prcessing. The Right t Erasure des nt prvide an abslute right t be frgtten. Hwever, yu d have a right t have persnal data erased and t prevent prcessing in specific circumstances: Where the persnal data is n lnger necessary in relatin t the purpse fr which it was riginally cllected/prcessed; When yu withdraw cnsent (and this is the basis f prcessing); When yu bject t the prcessing and there is n verriding legitimate interest fr cntinuing the prcessing; The persnal data was unlawfully prcessed; The persnal data has t be erased in rder t cmply with a legal bligatin; and The persnal data is prcessed in relatin t the ffer f infrmatin sciety services t a child. Hwever, yu shuld nte LGfL prvide educatinal services which may nt be cnsidered infrmatin sciety services.

4 Right t Restrict Prcessing. When prcessing is restricted, LGfL is permitted t stre the persnal data, but nt further prcess it. In this event exactly what is held and why will be explained t yu. Right t Data Prtability. Yu may request t btain and reuse yur persnal data fr yur wn purpses acrss different services. This allws yu t mve, cpy r transfer persnal data easily frm ne IT envirnment t anther in a safe and secure way, withut hindrance t usability. The Right t Data Prtability nly applies: T persnal data yu have prvided t LGfL; Where the prcessing is based n yur cnsent r fr the perfrmance f a cntract; and When prcessing is carried ut by autmated means. In these circumstances LGfL will prvide a cpy f yur data in CSV frmat free f charge, withut undue delay and within ne mnth. If there is a delay t this, yu will be infrmed. Right t Object. Yu have the right t bject t: Prcessing based n legitimate interests r the perfrmance f a task in the public interest/exercise f fficial authrity (including prfiling); Direct marketing (including prfiling); and Prcessing fr purpses f scientific/histrical research and statistics. Autmated Decisin Making and Prfiling. LGfL des nt emply any autmated decisin-making r cnduct prfiling f Data Subjects. Ckies. This sectin utlines the type f ckies we apply t ur website and the services we ffer. By using the website, yu agree yur persnal infrmatin will be handled as described in this Privacy Ntice. The ckies we may use n ur website are described as belw: Strictly Necessary Ckies - These are ckies that allw yu t use different parts f ur website. Withut them different features that yu have requested cannt be prvided. These are usually set in respnse t an actin perfrmed by the user like clicking n a link r failing t enter the crrect passwrd t yur accunt. Functinal Ckies - These help us t make yur experience within ur site mre persnal. Fr instance, knwing if yu have been n the site befre s that messages fr new visitrs are nt displayed t yu. First Party Ckies - These are ckies that are set by ur website. And nly we can read them. Sessin Ckies - These are stred while yu brwse ur site and then deleted nce yu leave.

5 Persistent Ckies - These are saved n yur cmputer and wn t be deleted when yu clse the web page. We use these t prvide functinality when yu cme back t the site. Perfrmance Ckies - These help us t track hw peple are using ur site. They help us t knw what pages peple are using mst and hw users navigate arund the site, we use this infrmatin t make infrmed decisin abut hw we can imprve the user experience f ur site. The infrmatin we get using these ckies is cmpletely annymus and we will make n attempt t identify yu r influence yur experience f ur site while yu are n it. Third Party Ckies - These can be things like Ggle Analytics and ther embedded cntent. Hw D We Use Yur Data? We use the data that we cllect abut yu fr the fllwing purpses: T prvide services related t yur Accunt t yu, t cmmunicate with yu abut yur use f ur website, yur Accunt and/r Services we ffer r make available thrugh the website. T respnd t any enquiries, yu submit t us. T perate and imprve the website. T better understand hw users access and use ur website and their Accunts, bth n an aggregated and individualised basis, fr the purpses f imprving ur website. Third Party Website Links. Our website may cntain links t ther third-party websites. Any access t and use f such linked websites is nt gverned by this Privacy Plicy, but, instead, is gverned by the privacy plicies f thse third-party websites, and LGfL is nt respnsible fr the infrmatin practices f such third-party websites.