Privacy Policy

SUPPORT SEND KIDS

PRIVACY NOTICE

Your privacy and trust are important to us. This Privacy Notice explains how Support SEND Kids collects, handles, stores and protects personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your personal information.

In this Privacy Notice, personal information means any information about an individual from which that person can be identified, such as name, telephone number, email address, or image. It does not include data from which someone’s personal identity has been removed and from which that identity cannot be gleaned (anonymous data).

WHO THIS PRIVACY NOTICE APPLIES TO AND WHAT IT COVERS

This Privacy Notice applies to any personal information that we receive or collect, which may be from individuals, companies or organisations who interact/work with us or use any website, platform, application (including mobile application (“app”)), product, software or service that we offer (our “Services”). Use of our Services may be directly through us, or through another organisation’s website, app, product, software or service.

Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which statements apply to which interactions and Services.

Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy notices and terms that apply to them.

WHO WE ARE

We are Support SEND Kids, a soon to be charity whose aim is to support the improvement or the experience and the outcomes for children with special educational needs and their parents and carers.

Support SEND Kids is incorporated in England & Wales under the name Support SEND Kids Limited with company number 13049161 and registered office 85 Great Portland Street, London W1W 7LT.

Where we are provided with (either directly by you or indirectly on your behalf) or we collect your personal information we will act as data controller.

HOW DO WE COLLECT/RECEIVE YOUR PERSONAL INFORMATION

We collect personal information (including in some cases special categories of personal information) about you from your interactions with us and from certain third parties and other sources (such as from publicly available sources, where permissible).

Personal information that you provide to us. Through your interactions with us and our Services, such as, when you use our Services, undertake interviews with us, provide us Educational and Health Care Plans (“EHCP”), register for an event, request information or call us for support (please note that we may record or monitor our telephone calls for compliance and quality assurance purposes) or make a donation to us.

Personal information that we collect automatically. Through your system/device and use of our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us provide, administer, protect and improve our Services, analyse usage and improve users’ experience.

Personal information collected from third party sources. We may also collect personal information (including in some cases special categories of personal information) about you from third parties such as:

the person(s) arranging for you to access our Services in order to set up a user account;
partners and service providers who work with us in relation to the Service you are receiving;
third parties that collect donations for us;
personal information (including special category personal information) provided to us by a parent, guardian or carer in relation to the Services that we provide; and
publicly available sources such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance the Services.

Failure to provide personal information. If you fail to provide personal information where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the Services that you have requested. In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

WHAT TYPES OF PERSONAL INFORMATION WE COLLECT

The type of personal information we collect depends on how you are interacting with us and which Services you are using.

In many cases, you can choose whether or not to provide us with personal information, but if you choose not to, you may not get full functionality from the Services.

The personal information we collect consists of the following, which we have grouped together as follows:

identity data and contact data: name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data;
profile data: account credentials, such as, passwords and other security information for authentication and access, your interests, preferences, feedback and survey responses;
user content: such as communications and files provided by you in relation to your use of the Services;
business content: when using our Services, you may provide information which is then made public and which may be able to identify you, whether from the context of the information you provide or otherwise;
technical data: device information, such as, information about your device, such as IP address, location or provider;
usage data: information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most;
location data: for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately;
transaction data: includes details about your interaction with us and our Services;
financial data: includes bank account and payment card details;
marketing and communications data: includes your preferences in receiving marketing from us and our third parties and your communication preferences; and
special categories of personal information: health and disability information that is provided to us, including during an interview, when an EHCP is provided to us or when such information is uploaded onto a Support SEND Kids website/platform.

Aggregated Data

We also collect, use and share ‘aggregated data’ such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this data will 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Notice.

Special Categories of Personal Information

We collect special categories of personal information about you or a child whose special category personal information you are providing (this includes details about your health and/or the health of the child). Where we know that we will receive special categories of personal information from you or a third party, we will obtain consent from you or that third party (where they are authorised to provide such consent) in relation to our processing of those special categories of personal information. If your special category personal information is uploaded to a Support SEND Kids platform without our prior knowledge, such upload shall be subject to our terms and conditions which you have agreed to and which include consent for us to process such special categories of personal information in relation to the hosting and displaying of such personal information.

Credit and Debit Cards

If you use your credit or debit card to donate to us, we or the third party collecting on our behalf will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. You can find our more information about PCI DSS here https://www.pcisecuritystandards.org/security_standards/index.php

We do not store your credit or debit card details at all, following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed. Only staff authorised and trained to process payments will be able to see your card details.

HOW WE USE PERSONAL INFORMATION

This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve our Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below.

Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:

necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract;
in our or a third parties’ legitimate interests: details of those legitimate interests are set out in more detail below;
where you give us your consent: we will ask for your consent in relation to the processing of your or your child’s special category personal information (such as health information). If you are a parent, carer or guardian of a child whose special category personal information you are providing, you must ensure that you have the authority to provide such personal information prior to providing it to us - please note that if consent is withdrawn we may continue to process any non-special category personal information where we have another legal basis for such processing; and/or
for compliance with a legal obligation: e.g., to respond to a court order or a regulator.

You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information. Please see the ‘HOW TO CONTACT US’ section below.

Purposes for which we collect and use personal information

We use personal information for a number of purposes, including to provide and improve Services, administer our relationship with you and us, for marketing and in order to exercise our rights and responsibilities.

Where you access any Support SEND Kids platforms at Supportsendkids.org (or such other URL as may be applicable from time to time), one of our principal uses for your personal information is to provide the functionalities and services that the platforms provide, which includes sharing your questions and answers to questions posed either by yourself or by others. When we share any such content your name may be associated with it.

We have set out below, in a table format, a more description of all the ways we may use your personal information, and which of the legal bases we rely on to do so.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose

To respond to your specific inquiry or request and to provide you with information and access to resources that you have requested from us.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription and Service information.

Lawful Basis

Performance of a contract with you (if applicable)
Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To administer our relationship with you, our business and our third-party providers.

Lawful Basis

Performance of a contract with you (if applicable)
Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To deliver and suggest tailored content such as news, research, reports and business information. We analyse the way you use our Services to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly.

Lawful Basis

Necessary for our legitimate interests

Purpose

To personalise your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant. We may sometimes share your personal information across our Services so that we can make all of the Services we deliver to you more intuitive (e.g., rather than requiring you to enter the same data many times).

Lawful Basis

Necessary for our legitimate interests

Purpose

To contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes.

Lawful Basis

Necessary for our legitimate interests

Purpose

To display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums (including in community and event profiles) and for related collaboration, peer connection, games and information exchange.

Lawful Basis

Necessary for our legitimate interests
Where we have consent (in relation to special categories of personal information)

Purpose

To provide any third party, who has made our Services available to you, insights about use of the Services.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

For internal research and development purposes and to improve, test and enhance the features and functions of our Services.

Lawful Basis

Necessary for our legitimate interests

Purpose

To provide you with marketing as permitted by law.

Lawful Basis

Where you have consented to receive such marketing

Purpose

To meet our and any third party provider’s internal and external audit requirements, including our information security obligations.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To enforce our terms and conditions.

Lawful Basis

Performance of a contract with you (if applicable)
Necessary to comply with a legal obligation

Purpose

To protect our rights, privacy, safety, networks, systems and property, or those of other persons.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

For the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

In order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work.

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

In order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Lawful Basis

Necessary to comply with a legal obligation
Necessary for our legitimate interests

Purpose

To process special categories of personal information in order to conduct interviews, receive, store and host special categories of personal information that is provided to us (including EHCPs), anonymise information that is provided to us and to host and display special categories of personal information on a Support SEND Kids website/platform

Lawful Basis

Where we have received consent

Purpose

To work with data foundations to undertake analysis of EHCPs (including special categories of information therein) in order to undertake analysis of special educational needs in the UK.

Lawful Basis

Where we have received consent

By using the Support SEND Kids platforms, you acknowledge that we will use your personal information as set out above. We also believe that each of these purposes is a legitimate interest for our use of personal information.

Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms.

SHARING YOUR PERSONAL INFORMATION

Transfer to Third Parties

We do not sell or loan personal information to any third parties; however, we may share your personal information with third parties only in the ways that are described in this Privacy Notice.

We have listed below the categories of third parties to whom we may share your personal information:

Third Party

Description

Our Service Providers

Our service providers include third parties that provide us services such as IT services (such as software and application service providers, third parties who host, store and manage data or provide programming or technical support), payment processing, donation collection, marketing services and otherwise help us provide our Services. Such third parties will act as our processors.

Our professional advisors

We may need to provide your personal information to our professional advisers that provide services to use. Our professional advisors include lawyers, accountants, bankers, auditors and insurers. Such third parties may act as our processors or independent controllers.

Our Group Companies and Entities

We may share your personal information with our group companies and entities and in such circumstances with ensure that all necessary protections are put in place as required by applicable law.

The person providing your access to our Services

If you are provided access to our Services via a third party, we will share your personal information with them.

The person providing your personal information to us

If there is a person providing your personal information to us (such as a parent, carer or guardian) we may provide your personal information back to that person.

Partners

We may share your personal information with our partners with whom we deliver co-branded Services, provide content, or to host events, conferences and seminars.

Authorities

We may share your personal information with third parties where we have a duty to or are permitted to disclose your personal information by law (e.g., government agencies, law enforcement, courts and other public authorities).

Third parties related to corporate activities

We may share your personal information with third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we may disclose your personal information to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale.

Third parties related to charitable objectives

We may share your personal information with third parties in order to further the charitable objects of Support SEND Kids Limited.

Other users of Support SEND Kids platforms

Information you upload on the Support SEND Kids platforms is publicly available and will be shared with other users (excluding your personal account information).

Third party data foundations

We may share personal information (including special categories of information) with third party data foundations in order to undertake analysis of special educational needs in the UK.

Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us. We require our third party service providers to process your personal information only in accordance with our instructions and in accordance with applicable laws.

Other Disclosures

We will share your personal information with third parties only in the ways that are described in this Privacy Notice unless we obtain your consent otherwise, except in the following instances: (i) as required by law; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on us; (iv) to respond to any other government-related request; (v) to protect our rights and interests (including without limitation, for our own safety); (vi) to protect your interests (including without limitation, for your safety); (vii) to protect the interests of others (including without limitation, for their safety); or (ix) to investigate alleged or actual fraud, misrepresentation or other misconduct, provided always that such transfer and processing is in compliance with applicable laws.

CHANGE OF PURPOSE

We will only use your personal information for the purposes described above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and our charitable objectives.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose and our charitable objectives, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

MARKETING

We deliver marketing and event communications to you via various methods such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us.

If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future. Even if you opt out of receiving marketing communications by email, we may still send you service communications or important transactional information related to our Services that you use.

We will get your explicit consent before we share your personal information with any company outside of our group of companies for marketing purposes.

Honouring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.

INTERNATIONAL TRANSFERS

In order to provide certain of our Services it may be necessary for us to transfer your personal information outside of the United Kingdom (UK) or the European Economic Area (EEA). Where we do so, we will ensure that we have measures in place to ensure that when your personal information is subject to appropriate protections, as required by the applicable data protection laws of the UK and/or the EEA (as applicable). Often, these include contractual safeguards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK or EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

While we will use all reasonable efforts to safeguard your personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information that are transferred from you or to you via the internet. If you have any particular concerns about your personal information, please contact via a method set out in the ‘HOW TO CONTACT US’ section below.

DATA RETENTION

We calculate retention periods for your personal information in accordance with the following criteria:

the length of time necessary to fulfil the purposes we collected it for;
when you cease to use our Services;
the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations;
any limitation periods within which claims might be made;
any retention periods prescribed by law or recommended by regulators, professional bodies or associations; and
the existence of any relevant proceedings.

In some circumstances you can ask us to delete your data – please see the ‘YOUR RIGHTS’ section below for further information.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, where you have asked us to do so or where you have asked us to remove your personal information but we need to continue to use associated non-personal information, in which case we may use this information indefinitely without further notice to you, provided that it remain non-personal information.

YOUR RIGHTS

You may have rights under applicable laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.

We will honour your rights under applicable data protection laws. You should be aware that these rights are not absolute and they do not always apply in all cases.

In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.

You will not have to pay a fee to access your personal information (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 could refuse to comply with your request in these circumstances.

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

If you would like to exercise any of your rights please contact us using the details in the ‘HOW TO CONTACT US’ section below.

CONNECTING VIA SOCIAL NETWORKS

Some of our Services may include social networking features and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, LinkedIn®, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these Services. These Services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.

LEGAL PRODUCTS AND SERVICES

The Support SEND Kids platforms make available on-line spaces to the Special Educational Needs and Disability community, which may include professionals from across that community.

Support SEND Kids recognises and respects that many of its customers and users of our Services may be subject to ethical obligations to protect confidences with their clients. Where we act as a service provider in regard to the personal or confidential information that our customers or users input into the Support SEND Kids platforms, we do so in accordance with permissible law and we do not use any such information other than to provide, administer and improve our Services, provide user support or to meet our legal obligations.

HOW TO CONTACT US

If you have any questions, comments, complaints or suggestions in relation to data protection or this Privacy Notice, or any other concerns about the way in which we process information about you, please contact us at contact@supportsendkids.org

FILING A COMPLAINT

If you are not content with how we manage your personal information, you can lodge a complaint with a privacy supervisory authority. In the EEA, the relevant supervisory authority is the one in the country or territory where: (i) you are resident; (ii) you work; or (iii) the alleged infringement took place

A list of National Data Protection Authorities in the EEA can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html

The UK’s supervisory authority is the Information Commissioner’s Office (www.ico.org,uk)

UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated by us from time to time.

Any material future changes or additions to the processing of personal information as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on our website or email you to let you know of any such updates.