Privacy Information

You have rights to obtain and reuse your personal data for your own purposes across different services. E.g. if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

InSchool Media Limited (ISM) Privacy Policy

LAST UPDATED: October 2021

ISM has created this privacy policy to demonstrate our firm commitment to privacy by describing how we collect, look after, and use your personal information, your privacy rights, and how the law protects you.

About FIRM NAME

In provides ISM for customers. ISM is the controller and is responsible for your personal information (collectively referred to as “we”, “us” or “our” in this privacy policy).

What does this privacy policy cover?

We have created this privacy policy to demonstrate our firm commitment to data privacy by explaining how we collect, look after, and use your personal information, your privacy rights, and how the law protects you.It is important that you read this privacy policy together with any other data protection policy or fair processing notice we may provide on specific occasions when we are collecting or processing your personal information so that you are aware of how and why we are using your personal information. This privacy policy supplements such other notices and is not intended to override them.

This privacy policy:

Sets out the types of personal information we collect about you.
Explains how we collect your personal information.
Explains when, why and with who we will share your personal information.
Explains how we look after your personal information.
Explains how we use your personal information and the legal bases we have for using your personal information.
Explains how we use your information to make automated decisions.
Explains what happens if you choose not to give personal information.
Explains how long we keep your personal information.
Sets out your legal rights.
Explains how to get a copy of your personal information.
Explains how to contact us.
Explains our use of cookies and how you can disable such cookies.

What personal information we collect about you

Personal information means any information relating to an identified or identifiable natural person. This does not include information that has been anonymised or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

These are some of the types of personal information that we may collect, use, store and transfer:

Type of Personal Information	Description
Identity	Your Title, First Name, Surname, Date of Birth
Financial	Your Bank Account Details
Contact	Where you live
Contractual	Our services to you
Behavioural	Details of how you use our Services
Communications	What we learn about you from communications between us
Consent	Any Permissions, Consent or Preferences you gave us

Where we collect personal information from

We may collect personal information about you from any of these sources:

Direct interactions, which includes personal information you give to us:

When you apply for our products and services.
When you talk to us on the phone.
When you use our websites, mobile device apps or web chat services.
In emails and letters.

Who we share your personal information with

We may share your personal information with:

Regulators and other authorities (including the Information Commissioner’s Office).
Companies who perform marketing services on our behalf such as third-party vendors including Google.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

This privacy policy addresses only our use and handling of personal information we collect from you in connection with providing our services. If you disclose your information to a third party, or visit a third party website via a link from our services (including those listed below), their privacy notices and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to review their privacy notices and practices.

International transfers

We may transfer your personal information outside of the European Economic Area (‘EEA’) to:

Comply with a legal or regulatory obligation.
Work with our agents/suppliers for contractual purposes.

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

How we look after your personal information

We are committed to ensuring your personal information is secure. To minimise the risk that there is unauthorised access to or disclosure of your personal information, we put in place, where practicable, appropriate physical, electronic and managerial procedures to safeguard and secure it.

We also limit access to your personal information to those employees, agents, contractors and other third parties on a “need to know” basis. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have 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.

How we use personal information and how the law protects you

Data Protection law only allows us to use personal information if we have a proper reason to do so. The law recognises four proper reasons for using personal information:

To fulfil a contract, we have with you.
When it is our legal duty.
When it is in our legitimate interests.
When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of ways that we may use your personal information, which of the reasons we rely on to do so and our legitimate interests.

Types of Data	Purpose	Legal Purpose
Clients Name	Identity Contact Transactional Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Clients Address	Identity Contact Transactional Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Clients Email Address	Identity Contact Transactional Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Clients Phone Number	Identity Contact Transactional Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Clients Web-site Address	Identity Contact Transactional Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Employees Name	Identity Contact Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Employees Bank/Account Details	Identity Contact Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Employees Address	Identity Contact Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Employees Phone Number	Identity Contact Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service
Employees Account Details	Identity Contact Contractual	Performance of a contract Necessary to comply with legal obligations Necessary for our legitimate interests such as: Keeping records up to date Gathering feedback to improve our service

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean by ‘marketing’. We may use this personal information to form a view on what we think you may want or need, or what may be of interest to you, and therefore which products, services and offers may be relevant for you.

We will only:

Use your personal information to send you marketing messages

if you have given your consent for us to do so.

You can ask us to stop sending you marketing messages by contacting us at any time.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, we may not be able to fulfil our legal or contractual obligations. This may mean we cannot issue you an insurance policy and we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

How long we keep your personal information

We will keep your personal information for as long as you are a customer of ISM

After you stop being a customer, we may keep your data for up to 6 years for one of these reasons:

To respond to any questions or complaints.
To show that we treated you fairly.
To maintain records according to rules that apply to us.

Your legal rights

You have the following rights in relation to your personal information:

1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.

2. The right of access

You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we’re using your information in accordance with data protection law.

3. The right to rectification

You’re entitled to have your information corrected if it’s inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.

4. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

5. The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. E.g., if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

7. The right to object

You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).

If you wish to exercise any of the rights set out above, please email info@inschool-media.co.uk.

How to withdraw your consent

You can withdraw your marketing consent at any time. To do so send us an email to info@inschool-media.co.uk.

How to contact us

Please let us know if you are unhappy with how we have used your personal information. You can write to us at info@inschool-media.co.uk.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO).