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PRIVACY STATEMENT


OPTIMUS PRIVACY STATEMENT


YOUR PRIVACY

Optimus Education is committed to protecting your privacy when you use our
services.

This privacy statement explains how we use information about you and how we
protect your privacy.

From 25 May 2018, your personal information will be processed, held and/or
controlled in accordance with the General Data Protection Regulations
(2016/679).

We have a Data Protection Office which makes sure we respect your rights and
follow the law.  You may contact us at any time to:

 * - Request access to information which Optimus Education has about you
 * - Correct any information which Optimus Education has about you
 * - Ask for any information which Optimus Education has about you to be deleted
 * - Discuss any concerns or ask any questions about how we look after your
   personal information

Please contact the Data Protection Office at DPO@optimus-education.com or by
writing to:

Data Protection Office, Optimus Education, Black Country House, Rounds Green
Road, Oldbury, England, B69 2DG


INFORMATION WE COLLECT


DO YOU KNOW WHAT PERSONAL INFORMATION IS?

We may collect personal information about you including audio and video
recordings. This can be anything that identifies and relates to a living person
and can include information that when put together with other information can
then identify the person. For example, this could be your name, contact details,
e mail address and/or telephone number.


DID YOU KNOW THAT SOME OF YOUR PERSONAL INFORMATION MIGHT BE ‘SPECIAL’?

Some information is ‘special’ and needs more protection due to its sensitivity.
It’s often information you would not want widely known and is very personal to
you. This is likely to include anything that can reveal your:

 * - sexuality and sexual health
 * - religious or philosophical beliefs
 * - ethnicity
 * - physical or mental health
 * - trade union membership
 * - political opinion
 * - genetic/biometric data
 * - criminal history


WHY DO WE NEED YOUR PERSONAL INFORMATION?

We may need to use some information about you to:

 * - deliver services and support to you
 * - manage those services we provide to you
 * - train and manage the employment of our workers who deliver those services
 * - help investigate any worries or complaints you have about your services and
   to answer your questions and enquiries
 * - allow you to participate in online training and interactive features of our
   services if you choose to
 * - check and improve the quality of our services
 * - help with research and planning of new services
 * - send you information which we think might be of interest to you if you have
   agreed to this
 * - third parties where we have retained them to provide services that we, you
   or our client have requested
 * - monitor compliance with our equal opportunities policy
 * - carry out our obligations arising from any contracts entered into between
   you and us
 * - market our related products and services to you, where you have given your
   consent for us to do so

We reserve the right to transfer your data if Optimus Education is sold, goes
into a merger, liquidation or receivership or transfers all, or substantially
all, of its assets to a new owner. This will only take place if the third party
agrees to adhere to the terms of this privacy statement. We will let you know of
any such transfer and you will be able to opt-out if you wish.


HOW THE LAW ALLOWS US TO USE YOUR PERSONAL INFORMATION

Optimus Education processes personal data, both as a Data Controller and as a
Data Processor, as defined by relevant Data Protection Legislation: the General
Data Protection Regulations 2016/679, the Data Protection Act 1998, the EU Data
Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000,
the Telecommunications (Lawful Business Practice) (Interception of
Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications
Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications
(EC Directive) Regulations 2003 and all applicable laws and regulations relating
to processing of personal data and privacy, including where applicable the
guidance and codes of practice issued by the Information Commissioner.

There are a number of legal reasons why we need to collect and use your personal
information. Generally, we collect and use personal information where:

 * - you, or your legal representative, have given consent
 * - you have entered into a contract with us
 * - it is necessary to perform our statutory duties
 * - it is required by law
 * - it is necessary for employment purposes
 * - you have made your information publicly available
 * - it is necessary for legal cases
 * - it is to the benefit of society as a whole
 * - it is necessary for archiving, research, or statistical purposes

If we have consent to use your personal information, rather than legal or
contractual reasons, you have the right to remove it at any time. If you want to
remove your consent, please contact DPO@optimus-education.com and tell us which
service you’re using so we can deal with your request.


WE ONLY USE WHAT WE NEED

We’ll only collect and use personal information if we need it to deliver a
service or meet a requirement.

If we don’t need personal information we’ll either keep you anonymous if we
already have it for something else or we won’t ask you for it. For example, in a
survey we may not need your contact details we’ll only collect your survey
responses.

If we use your personal information for research and analysis, we’ll always keep
you anonymous or use a different name unless you’ve agreed that your personal
information can be used for that research.

We don’t sell your personal information to anyone else.


WHAT YOU CAN DO WITH YOUR INFORMATION

The law gives you a number of rights to control what personal information is
used by us and how it is used by us.


YOU CAN ASK FOR ACCESS TO THE INFORMATION WE HOLD ON YOU

We would normally expect to share what we record about you with you, whenever we
assess your needs or provide you with services.

However, you also have the right to ask for all the information we have about
you and the services you receive from us. When we receive a request from you, we
must give you access to everything we’ve recorded about you.

However, we can’t let you see any parts of your record which contain:

 * - Confidential information about other people; or
 * - Data a professional advisor thinks will cause serious harm to your or
   someone else’s physical or mental wellbeing; or
 * - If we think that giving you the information may stop us from preventing or
   detecting a crime

This applies to personal information that is in both paper and electronic
records.

If you ask us for access to your information then we’ll ask you to provide
evidence so that we can verify your identity.

If you have any queries about access to your information please contact
DPO@optimus-education.com.


YOU CAN ASK TO CHANGE INFORMATION YOU THINK IS INACCURATE

You should let us know if you disagree with something written on your file.

We may not always be able to change or remove that information but we’ll correct
factual inaccuracies and may include your comments in the record to show that
you disagree with it.

If you ask us to change the information we hold about you then we’ll ask you to
provide evidence so that we can verify your identity.

The quickest way to inform us of any inaccuracies is to complete a form which we
can provide to you or you can talk to a member of staff, contact
DPO@optimus-education.com or write to us at:

Data Protection Office, Optimus Education, Black Country House, Rounds Green
Road, Oldbury, England, B69 2DG


YOU CAN ASK TO DELETE INFORMATION (THE RIGHT TO BE FORGOTTEN)

In some circumstances you can ask for your personal information to be deleted,
for example:

 * - Where your personal information is no longer needed for the reason why it
   was collected in the first place
 * - Where you have removed your consent for us to use your information (where
   there is no other legal reason for us to use it)
 * - Where there is no legal reason for the use of your information
 * - Where deleting the information is a legal requirement

Where your personal information has been shared with others, we’ll do what we
can to make sure those using your personal information comply with your request
for erasure.

Please note that we can’t delete your information where:

 * - we’re required to have it by law
 * - it is used for freedom of expression
 * - it is for, scientific or historical research, or statistical purposes where
   it would make information unusable
 * - it is necessary for legal claims

 


YOU CAN ASK TO LIMIT WHAT WE USE YOUR PERSONAL DATA FOR

You have the right to ask us to restrict what we use your personal information
for where:

 * - you have identified inaccurate information, and have told us of it
 * - where we have no legal reason to use that information but you want us to
   restrict what we use it for rather than erase the information altogether

When information is restricted it can’t be used other than to store securely the
data and with your consent; or, to handle legal claims and protect others, or
where it’s for important public interests of the UK.

Where restriction of use has been granted, we’ll inform you before we carry on
using your personal information.

You have the right to ask us to stop using your personal information for any
service we provide. You also have the right to unsubscribe from any materials we
may send you. However, if you make a request this may cause delays or prevent us
delivering services to you.

Where possible we’ll seek to comply with your request, but we may need to hold
or use information because we are required to by law or by contract.

If you wish to contact us with respect to these matters please contact the Data
Protection Office on DPO@optimus-education.com.


YOU CAN ASK TO HAVE YOUR INFORMATION MOVED TO ANOTHER PROVIDER (DATA
PORTABILITY)

You have the right to ask for your personal information to be given back to you
or another service provider of your choice in a commonly used format. This is
called data portability.

However, this only applies if we’re using your personal information with consent
(not if we’re required to by law).

You can ask to have any ‘computer-made’ decisions explained to you, or choose
not to be the subject of a decision which is based on automated processing. You
have the right to question decisions made about you by a computer, unless it’s
required for any contract you have entered into, required by law, or you’ve
consented to it.

You also have the right to object if you are being ‘profiled’. Profiling is
where decisions are made about you based on certain things in your personal
information, e.g. your health conditions.

If Optimus Education uses your personal information to profile you, to deliver
the most appropriate service to you, you will be informed.

If you have concerns regarding automated decision-making, or profiling, please
contact the Data Protection Office on DPO@optimus-education.com who’ll be able
to advise you about how we are using your information.


WHO DO WE SHARE YOUR INFORMATION WITH?

We use a range of organisations to either store personal information or help
deliver our services to you. Where we have these arrangements, there is always
an agreement in in place to make sure that the organisation complies with data
protection law.

We’ll often complete a data protection impact assessment (DPIA) before we share
personal information to make sure we protect your privacy and comply with the
law.

Sometimes we have a legal duty to provide personal information to other
organisations. This may be because we need to give that data to the courts.

We may also share your personal information when we feel there’s a good reason
that’s more important than protecting your privacy. This doesn’t happen often,
but we may share your information:

 * - to find and stop crime and fraud; or
 * - if there are serious risks to the public, our staff or to other
   professionals;
 * - to protect a child; or
 * - to protect adults who are thought to be at risk, for example if they are
   frail, confused or cannot understand what is happening to them

For all of these reasons the risk must be serious before we can override your
right to privacy.

If we’re worried about your physical safety or feel we need to take action to
protect you from being harmed in other ways, we’ll discuss this with you and, if
possible, get your permission to tell others about your situation before doing
so.

We may still share your information if we believe the risk to others is serious
enough to do so.

There may also be rare occasions when the risk to others is so great that we
need to share information straight away. If this is the case, we’ll make sure
that we record what information we share and our reasons for doing so. We’ll let
you know what we’ve done and why if we think it is safe to do so.


HOW DO WE PROTECT YOUR INFORMATION?

We’ll do what we can to make sure we hold records about you (on paper and
electronically) in a secure way, and we’ll only make them available to those who
have a right to see them. Examples of our security include:

 * - Encryption, meaning that information is hidden so that it cannot be read
   without special knowledge (such as a password). This is done with a secret
   code or what’s called a ‘cypher’. The hidden information is said to then be
   ‘encrypted’
 * - Controlling access to systems and networks allows us to stop people who are
   not allowed to view your personal information from getting access to it
 * - Training for our staff allows us to make them aware of how to handle
   information and how and when to report when something goes wrong
 * - Regular testing of our technology and ways of working including keeping up
   to date on the latest security updates (commonly called patches)

You can find more details of our Information Security expectations on our online
policy.


WHERE IN THE WORLD IS YOUR INFORMATION?

The majority of personal information is stored on systems in the UK. But there
are some occasions where your information may leave the UK either in order to
get to another organisation or if it’s stored in a system inside the EU.

We have additional protections on your information if it leaves the UK ranging
from secure ways of transferring data to ensuring we have a robust contract in
place with that third party.

We’ll take all practical steps to make your personal information is not sent to
a country that is not seen as ‘safe’ either by the UK or EU Governments.


WE WILL ONLY KEEP YOUR INFORMATION FOR AS LONG AS WE NEED IT

We will retain your personal information only for as long as we need it in order
to fulfil the purposes for which we have initially collected it, unless
otherwise required by law or contractual requirements.


WHERE CAN I GET ADVICE?

If you have any worries or questions about how your personal information is
handled please contact our Data Protection Office, the details of which are at
the top of this page.

For independent advice about data protection, privacy and data sharing issues or
if you would like to make a complaint if you think we have done something wrong
with the data we hold about you, you can contact the Information Commissioner’s
Office (ICO) at:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Alternatively, visit www.ico.org.uk or email casework@ico.org.uk.


CHANGES TO OUR PRIVACY STATEMENT

From time to time we may make changes to this privacy statement. Any changes be
posted on this website so you are always aware of what information we collect,
how we use it, and under what circumstances, if any, we disclose it. If at any
time we decide to use personal data in a manner significantly different from
that stated in this privacy statement, or otherwise disclosed to you at the time
it was collected, we will notify you by email, and you will have a choice as to
whether or not we use your information in the new manner.


LINKS TO OTHER WEBSITE

Our website may contain links to other websites of interest. However, once you
have used these links to leave our site, you should note that we do not have any
control over other websites. Therefore, we cannot be responsible for the
protection and privacy of any information which you provide whilst visiting such
sites and such sites are not governed by this privacy statement. You should
exercise caution and look at the privacy statement applicable to the website in
question.


COOKIES (NOT THE EDIBLE ONES) AND HOW YOU USE THIS WEBSITE

To make this website easier to use, we sometimes place small text files on your
device (for example your iPad or laptop) called cookies. Most big websites do
this too.

They improve things by:

 * - remembering the things you’ve chosen while on our website, so you don’t
   have to keep re-entering them whenever you visit a new page
 * - remembering data you’ve given (for example, your address) so you don’t need
   to keep entering it
 * - measuring how you use the website so we can make sure it meets your needs

By using our website, you agree that we can place these types of cookies on your
device.

We don’t use cookies on this website that collect information about what other
websites you visit (often referred to as privacy intrusive cookies).

Our cookies aren’t used to identify you personally. They’re just here to make
the site work better for you. You can manage and/or delete these files as you
wish.

To learn more about cookies and how to manage them, visit www.AboutCookies.org
or watch a video about cookies.


OTHER PEOPLE’S COOKIES

We use videos from YouTube and feeds from other websites such as Facebook and
Twitter. These websites place cookies on your device when watching or viewing
these pages.

Below are links to their cookie policies:

 * - Google and YouTube
 * - Facebook
 * - Twitter


TURNING OFF COOKIES

You can stop cookies being downloaded on to your computer or other device by
selecting the appropriate settings on your browser. If you do this you may not
be able to use the full functionality of this website.

There is more information about how to delete or stop using cookies on
www.AboutCookies.org.

Further guidance on the use of personal information can be found at
www.ico.org.uk.

ABOUT US

About Optimus
About Shaw Trust
Cookie Policy
Partners
Privacy Statement
Terms and Conditions

CONTACT US

T: +44 (0) 208 315 1506
E: customer.services@optimus-education.com
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