Your Way Privacy Policy                    LPCo

 

1) About Your Way (Quality Young peoples services) Website

1.1) This Privacy Policy sets out how we collect, use and protect your personal information. Personal information’ is information which identifies you or another person, or which is capable of doing so.

1.2) your-way.org.uk is owned by The Learning Partnership for Cornwall & the Isles of Scilly (“LPCO”, “we” or “us”), a company registered in England under company number 04196040 whose registered office is at The Redruth Centre, 5-6, Station Road, Redruth., Cornwall, TR15 2AB.

1.3) The data controller (as defined under European Data Protection Legislation) is the LPCO. We are registered as a data controller with the Information Commissioner’s Office and our registration number is Z6339149.

1.4) Please take the time to read this Privacy Policy, which is part of our Terms and Conditions. If you have any questions about this Privacy Policy or our use of your information you can contact us at 01209 216136 or [email protected] . You also have the right to make a complaint to the relevant Supervisory Authority about our use of your information (in most cases under this Privacy Policy the relevant Supervisory Authority will be the Information Commissioner’s Office).

 

2) About this privacy policy

2.1) We take your privacy seriously and are committed to maintaining the privacy and security of information you provide to us, and the choices you have regarding our collection and use of your information. This Privacy Policy applies to information we collect about you through the Website and when you otherwise communicate with us. By visiting the Website you are accepting and consenting to the practices described in this Privacy Policy.

2.2) We process your personal data on the basis that you have provided your consent for us to do so for the purposes set out below when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at 01209 216316 or [email protected]. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.

2.3) If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.

2.4) This Privacy Policy may change from time to time and, if it does, the up-to-date version will always be available on the Website. Please note that by continuing to use the Website you are agreeing to any updated versions.

 

3) Information we may collect about you

3.1) We may collect and process the following data:

      • Information you give to us. You may give us information about you by filling in forms on our ‘Contact Us’ page, by contacting us. The information you give to us may include:
        • your name and title;
        • contact information, including telephone number and email address;
        • information such as postcodes, and your preferences and interests; and
        • a brief message explaining why you are requesting support
      • Information we receive from other sources.
        • We may also receive information about you if you use any of the other websites we operate (including, for example, cornwall-learning-partnership.org and mindyourway.co.uk) or the other services we provide (for example social media platforms).

 

4) Cookie Policy

4.1) The Website uses cookies to distinguish you from other users, to improve your experience on our Website, and, to recommend content that may be of interest to you. When you visit the Website, we will ask you whether you agree to our use of cookies. You can indicate your acceptance of our use of cookies by clicking “continue” in the appropriate place on the banner that appears on the Website. However, please note that if you do not click “continue” but continue to browse the Website, you will be deemed to have accepted our use of cookies in accordance with this Privacy Policy. If you do not agree to our use of cookies, then you may continue to use the Website but your browsing experience may be affected. You can find out more below about what cookies are, the cookies we use and how to switch off cookies.

 

4.2) What are cookies?

A cookie is a text file containing small amounts of information which is downloaded to your device when you access a website. The text file is then sent back to our server each time your browser requests a page from the server. This enables us to operate the Website more effectively and load the Website in such a way as to reflect your personal preferences based on your previous browsing on the Website, as well as keywords we may be able to gather from URLs of webpages from which you accessed the Website.

 

4.3) How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

 

4.4) What cookies do we use?

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the administration and operation of our Website. Some cookies that we use are necessary for our Website to function properly and to enable you to move around the Website and use its features.
  • Form related cookies. When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

 

4.5) Third party cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
  • From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
  • We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Twitter, Facebook, Instagram and YouTube, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

 

4.6) How do I turn cookies off?

If you would like to opt out of cookies, you can change the settings on your internet browser to reject cookies. For more information please consult the “Help” section of your browser or visit www.aboutcookies.org or www.allaboutcookies.org. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features of our Website.

 

5) How we will use your information

5.1) We may use your information for the following purposes:

      • To respond to any query that you may submit to us
      • Deliver services and support signposting you to access them via our partner organisations
      • Manage those services we provide to you
      • Recruit train and manage the employment of our workers who deliver those services
      • Help follow up any feedback or concerns you have about our services
      • Monitor the effectiveness of our services
      • Check the quality of services (internally and by external organisations)
      • Help with research and planning of new services.
      • If you volunteer with us, then we will collect extra information about you (for example: references, criminal records check, professional certificates, details of emergency contacts, medical conditions). This information will be retained for legal reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
      • to ensure that our Website’s content is presented in the most effective manner for you and your computer;
      • we may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided, but only if you have given us your consent to do so;
      • to send promotional emails about new products, special offers or other information which we think you may find interesting, but only if you have given us your consent to do so and you can opt out at any time;
      • from time to time, to contact you for market research purposes;
      • to customise the Website according to your interests;
      • to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses;
      • to allow you to participate in interactive features of our service when you choose to do so;
      • as part of our efforts to keep the Website safe and secure;
      • to comply with the law;
      • as we feel is necessary to prevent illegal activity or to protect our interests.

 

6) Disclosure of your information

6.1) We may share your personal information with any member of the Your Way partnership group, which includes CCDL, Pentreath & Young People Cornwall.

6.2) If we share your information with these organisations, they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the applicable data protection legislation.

6.3) We may disclose your information to third parties when:

      • you specifically request this, such as when you submit information to enquire about jobs or submit a job application through the Website
      • other services may interest you;
      • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
      • if the Website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of the Website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
      • Your Way has a legal duty to disclose some information including:
        • Safeguarding concerns will be reported to Children’s Services / Adult Social Care;
        • Drug trafficking, money laundering, acts of terrorism or treason will be disclosed to the police
        • In addition, where colleagues believe an illegal act has taken place it will be reported to the appropriate authorities.
        • If a court orders that we provide the information
        • In order to prevent crime and fraud
        • If there are serious risks to the public, our staff or to other professionals
        • Your Way services will always inform you of any disclosure.
      • The third parties include:
        • business partners, clients, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
        • analytics and search engine providers that assist us in the improvement and optimisation of the Website.

6.5) We may share some broader statistics and customer profiling information with third parties and other companies, but the data is anonymised, so you would not be identifiable from that data. We will not rent or sell our users’ details to any other organisation or individual.

 

7) Storage of your personal data:

7.1) The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. By using the Website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7.2) We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on this Website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data. So we cannot accept any liability for the loss, theft or misuse of the personal information which you have registered on the Website if there is a security breach.

7.3) We will keep your information stored on our systems for as long as it takes to provide the services to you. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law.

 

8) Your rights

8.1) Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at 01209 216136 or [email protected] .

8.2) The Website may, from time to time, contain links to and from the websites of advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8.3) From 25 May 2018, you will be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. The types of data that can be provided are those set out at paragraph 3.1 above. You can exercise this right from 25 May 2018 by contacting us at 01209 216136 or [email protected]

 

9) Access to information

9.1) European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared. In the event that an access request is unfounded, excessive or especially repetitive, we may charge a ‘reasonable fee’ for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information (that fee will be based upon the administrative costs of providing the information).  Sometimes you may be asked to provide proof of identity before we show you your personal information – that’s so we can prevent unauthorised access. Your rights to access, rectify such information, object or cancel the information we hold about you can be exercised at any time by contacting us at 01209 216136 or [email protected]

 

10) Contact

10.1 Questions, comments and requests regarding this Privacy Policy should be addressed to our Corporate Services Manager:

Name:              Helen Wilson-Prowse

Address:           The Redruth Centre, 5-6, Station Road, Redruth, Cornwall, TR15 2AB.

Email:               [email protected]

Telephone:        01209 216136

Alternatively, you can contact us through the “Contact Us” section of this Website.

 

11) Definitions

11.1 For the purposes of this Privacy Policy, (“European Data Protection Legislation”) is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”) or any equivalent legislation amending or replacing the GDPR.