Inclusive Working Limited
Privacy Notice
Last updated September 2022
This privacy notice tells you how we look after your information when you visit our website at or use our online platform (as a learner or adult with responsibility for a learner).
It explains what information we collect about you, what we use it for and who we share it with. It also explains your rights and what to do if you have any concerns.
We sometimes need to make changes to this notice, to reflect changes in the way we do business or updates in the law. We will notify you of any important changes before they take effect.
1. Who we are and other important information
We are Inclusive Working Limited, registered in England and Wales with company number 13164265 whose registered address is 192a Dalling Road, London W6 0EU (we / us / our).
Inclusive Working Limited is the controller for your information (which means we decide what information we collect and how it is used).
We are registered with the Information Commissioner’s Office (ICO), the organisation responsible for ensuring that we follow the law when we use your information, under number ZB252559
2. Respecting our learners and their information
If you are one of our learners with special educational needs and have an adult who is responsible for you, you should know that your legal guardian can ask us about your information.
If you are ever worried or have questions please let us (or another adult you trust) know. We are here to encourage our learners – so we are always happy to answer your questions
3. How to contact us
If you have any questions about this privacy notice or the way we use information, please get in touch
using the following details:
Data Protection Manager Josh Hodgson & Oscar Suarez
Email Address :
Josh@inclusiveworking.com
Oscar@inclusiveworking.com
4. The information we collect about you
Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we collect and where we receive it from below:
Learners’ personal data
Received from
Identity – name, date of birth, gender, language
- learner
- responsible adult
Education – No information required
- learner
- responsible adult
Account – username, password, preferences
(including language), chat logs, modules completed,
scores on quizzes, videos watched
- learner
- learner (via cookies and similar things)
- responsible adult
- tutors
Feedback – responses you give when you rate how much you enjoyed a lesson or like our website
- learner
Technical information – about the phone or device you used to visit our website or log into our online platform
- learner (via cookies and similar things
How you use our website and online platform – how often you visit our website, which pages you view and for how long and how you use our online platform (e.g. which types of content you viewed and for how long and what options you choose)
- learner (via cookies and similar things
Responsible adults’ personal data
Identity – name, date of birth, gender, language
Contact – email address, telephone number, home address
Financial – bank account and sort number
Account – username, password, preferences (including language), chat logs
Feedback – information and responses you provide when completing surveys and questionnaires
Marketing Data – information you submit to confirm whether you wish to receive marketing from us and which method you prefer to be contacted by (e.g. text, email)
Technical information – about the phone or device you used to visit our website or log intoour online platform
How you use our website and online platform – how often you visit our website, which pages you view and for how long and how you use our online platform (e.g. which types of content you viewed and for how long and what options you choose)
Website visitors’ personal data
Marketing Data – information you submit to confirm whether you wish to receive marketing from us and which method you prefer to be contacted by (e.g. text, email)
Technical information – about the phone or device you used to visit our website or log intoour online platform
How you use our website and online platform – how often you visit our website, which pages you view and for how long and how you use our online platform (e.g. which types of content you viewed and for how long and what options you choose)
5. How we use your information
We must show a legal reason (also known as a lawful basis) for collecting and using your personal data. There are six legal reasons which organisations can rely on. The ones we rely on to use your personal data are:
● we need to use your information to do something that we’ve agreed to do, or require you to do something that you’ve agreed to do, under any agreement between us, for example, under the terms that apply when you use our online platform (contract)
● you (the responsible adult or website visitor) have given us permission to use your information for a specific reason (consent)
● we need to use your information to comply with the law (law)
● we need to use your information where we’ve a good reason for doing so, if we’re sure that you would expect this, and that your rights won’t be affected (good reason) This table explains which legal reason we rely on for which activity. If we plan to use your personal data for a new reason that is not listed in the table, we will update our privacy notice and send you a notification
Activity
Personal data used
Legal reason
Taking steps to enter into the contract with the responsible adult
Performance of contract (with responsible adult) Legitimate interests (for use of learners’ personal data, as necessary to conclude our contract with the responsible adult)
Providing you with a trial version of our products and services so that you can assess whether you want to proceed with purchasing our products and services
Performance of contract (with responsible adult)
Providing you with our products and services.
Performance of contract (with responsible adult)
Processing payments and collecting and recovering monies owed to us
Performance of contract Legitimate interests (as necessary to recover debts due to us)
Handling requests for technical support
Performance of contract (requests from responsible adult) Legitimate interests (requests from learners, as necessary to perform our contractual obligations to provide technical support)
Administering and protecting our website, online platform and systems (and those of our supply chain)
Legitimate interests (necessary to provide our products and services, monitor and improve network security and prevent fraud)
Providing insight on how a learner is using our online platform
Performance of contract (with responsible
adult) Legitimate interests (to provide an overview to responsible adults of learners’ engagement with the online platform)
To improve our online platform
Legitimate interests (to understand how users use the platform with a view to improving it for all users)
Sending you marketing communications by email
Consent (responsible adult and website visitors)
Asking you to participate in surveys and other types of feedback
Legitimate interests (necessary for product and service improvement purposes)
Notifying you about changes to our privacy notice
Legal obligation (necessary to comply with our obligations under data protection law)
6. Marketing
Our marketing messages always include a link so that you can unsubscribe at any time. You can also update your marketing preferences by logging into the platform and updating your settings. We market to learners. If you are a learner and you receive a marketing message (this might include some prices or information about discounts) please tell us or your responsible adult so we can stop straight away.
7. Who we share your information with
We share (or may share) your personal data with:
- Our personnel: Our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations. All personnel whose role may require them to interact with learners is required to undergo a DBS check.
- Your employer or education establishment:
- Responsible adults: we share information about learners with the responsible adult registered to the account.
- Our service providers: other organisations help us provide our services. We ensure these organisations only have access to the information required to provide the support we use them and have a contract with them that contains confidentiality and data protection obligations.
- Regulatory authorities: such as HM Revenue & Customs, the UK tax authority
- Our professional advisers such as our accountants or legal advisors where we require specialist advice to help us conduct our business
- Any actual or potential buyer of our business If we were asked to provide personal data in response to a court order or legal request (e.g. from the police), we would seek legal advice before disclosing any information and carefully consider the impact on your rights when providing a response.
8. Where we keep your information
We keep your information on big computers that can accessed over the Internet called ‘servers’. These belong to other organisations. Most of the servers we use are based somewhere in the UK or Europe, but some of these servers may be based in other countries. Where any servers are based outside the UK or Europe, we make sure that the organisations which own them agree to follow similar rules to us when it comes to how your information is handled.
9. How we keep your information safe
We do lots of different things to make sure that your information is safe:
- making sure that the link between your phone or device and our servers is secure so that no-one can ‘listen in’ on us
- using strong passwords on all our systems
- only allowing a small group of people to access our systems
- entering into agreements with our staff and service providers which require them to keep your information safe and not share it with anyone
- having a plan in place to deal with what happens if your information is accessed by someone who shouldn’t have access to it or if your information is lost or changed in any way
We know that online safety can be a worry so we publish links to trusted content (e.g. government guidance or national charities’ awareness campaigns) so you can learn more about how to keep yourself, your loved ones and your information safe. If you notice anything strange on your account (or believe your account has been used by someone without your permission) please let us know by emailing us at help@inclusiveworking.com
10. How long we keep your information
We only keep personal data for as long as we need it to complete the activities we collected it for (described in the table above).
To decide how long to keep personal data (also known as its retention period), We consider the how much, what type and how sensitive the personal data is, the potential risk of harm to you if something went wrong, whether we need the personal data to do our activities or whether we can do those activities another way (e.g. by using anonymous information instead), and any laws we must abide by (e.g. minimum accounting records for HM Revenue & Customs).
11. Your legal rights
You have specific legal rights in relation to your personal data.
Adults and children have the same rights, but adults can also act on behalf of the children they have parental responsibility for.
We don’t charge you anything to exercise (use) your rights, although we are sometimes allowed to – if this happens we’ll let you know first
Access (get a copy of): You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it to make sure we are abiding by the law
Correct: You can ask us to correct your personal data if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
Delete: You can ask us to delete or remove your personal data if there is no good reason for us to continuing holding it or if you have asked us to stop using it (see below). If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
Restrict (stop or limit): You can ask us to restrict how we use your personal data and temporarily limit the way we use it (e.g. whilst you check that the personal data we hold for you is correct)
Object (say no): You can tell us you want us to stop using your personal data. We will always stop if you ask us to stop sending you marketing communications but in other cases, we decide whether we will continue. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision
Transfer: You can ask us to send you or another organisation an electronic copy of your personal data
Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the ICO but we hope that we can help first.
12. What are cookies?
We uses cookies and similar things (such as beacons and pixels) on our website and online platform.
Cookies are small text files stored on your phone or device and are used to ensure our website works as it should and help us tell you apart from other visitors to our website.
To find out more about cookies, how to refuse them and how to change your phone or device’s cookie settings, you should read the ICO Cookie Guidance.
13. What do We use cookies for?
We use cookies to:
- to track how you use our online platform or website
- to check whether you have seen specific messages we display
- to record the conversation thread when you use any chat function within live sessions
- to record your answers to surveys and questionnaires on our online platform while you complete them
- to keep you signed into our online platform
- where we post content and links to content, we use cookies to capture and analyse information such as number of views and shares
The cookies and similar tools we use are:
Identifier
Set by
What it does
When it gets deleted
Further
information
