Privacy Policy

Last updated: February 2019

Introduction

Welcome to Reading Solutions UK Limited’s privacy policy for customer contacts at the schools who are customers, or potential or previous customers. The term ‘Customer Contact’ applies to employees and officers of schools with whom we engage in respect of the Reading Plus application and the support services.

Reading Solutions UK Limited is registered at Companies House under company number 09284598 and its registered office is 14 Emmbrook Close, East Rainton, Houghton Le Spring, Tyne and Wear, DH5 9SQ.

Reading Solutions UK Limited is the UK representative/reseller for Taylor Associates/Communications, Inc. (“Taylor Associates”) the owner of the Reading Plus application. Reading Solutions UK Limited respects your privacy and is committed to protecting your personal data. This privacy policy is provided to inform you, our customer contact, about how we look after your personal data when you:

make enquiries;
enter into discussions;
enter into a pilot agreement; and/or
enter into an agreement

(together referred to as “the Purposes”) to use the Reading Plus application and our support services at your school, and to tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED?

LAWFUL BASIS FOR PROCESSING

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS & PRIVACY SHIELD

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Reading Solutions UK Ltd collects and processes your personal data in respect of the Purposes.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We are a data controller

Under EU data protection laws (including those implementing the EU General Data Protection Regulation, or “GDPR”), when Reading Solutions UK Ltd (referred to as “Reading Solutions”, “we”, “us” or “our” in this privacy policy) processes the personal data we collect about you for the Purposes we are acting as a data controller.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. You should address questions or requests about how your personal data is handled to our data privacy manager.

Contact details

Our data privacy manager’s details are:

Name or title of data privacy manager: Matt Smith

Email address: info@readingsolutionsuk.com

Postal address: Unit 1B Enterprise House, Kingsway N, Gateshead, NE11 0SR

Telephone number: 0191 389 6078

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The ICO’s website is located at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us. We will investigate and seek to resolve any complaints as soon as reasonably possible.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and reserve the right to update this privacy policy or make changes to this privacy policy at any time. This version was last updated in February 2019. We will inform you of any material changes to our privacy policy and will indicate at the top of this policy when it was most recently updated.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data. For customer contacts we collect the following; first name, surname, job role, title and the name of the employer.
Contact Data. We collect the following contact data:
An email address for all customer contacts. This will be your professional email address if you do not have one a personal email address can be provided.
School email address
The business managers email address for payment details. (if different from above).
School Telephone Number
Personal telephone number if provided.
School Postal Address
School Website address
Other data. We collect the following data to assess your needs when contacting us:
School enrollment
Year Range/ Key Stage Range*
Lead Source
Ofsted Rating
Type of pupils you wish to target (SEN, EAL, FSM) *

*optional

If you fail to provide personal data

If you do not provide us with personal data that we request from you, we may be unable to fulfil the Purposes.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact, data by filling in forms or by corresponding or otherwise communicating with us in respect of the Purposes, or complaints by post, phone, email or otherwise.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Identity and Contact Data from publicly available sources such as from your employer’s website.
Identity Contact and Profile Data from your employer.
Identity and Contact Data from referrals via Taylor Associates whereby your initial registration of interest or enquiry was registered on their website.

LAWFUL BASIS FOR PROCESSING

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

To enter into or perform our obligations under a contract with your school.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Please note that while we always wish you to be aware of how we are using your personal data, this does not mean that we always require your consent to use it. We may use your personal data on grounds indicated in the bullet points above without your consent. We will only process your personal data without your knowledge in exceptional circumstances and where required by or in accordance with the law.

Any personal data relating to the users of the Reading Plus application (students, teachers and administrators) will only be processed by Taylor Associates (as a joint data controller with the school) in accordance with the Reading Plus Privacy Policy (https://privacy.readingplus.com/) and by us as a data processor for your school in accordance with Clause 5 of the SaaS Agreement and/or Clause 8 of the Terms of Service (as applicable) entered into by the school.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we use your personal data. The table also includes a description of the legal bases we rely on to use your personal data under EU data protection laws, including what our legitimate interests are where appropriate.

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

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To contact you to discuss the school using the Reading Plus Application; to respond to any queries; to facilitate the entering into the pilot agreement or agreement for Reading Plus.	(a) Identity (b) Contact	Necessary for our legitimate interests (to promote and sell the Reading Plus application)
To administer and perform the contact with the school and to manage our relationship with you which will include notifying you about changes to our terms or privacy policy	(a) Identity (b) Contact	(a) Performance of a contract with the school, including the provision of the application and support services and enabling payments. (b) Necessary to comply with a legal obligations in relation to data protection such as notifying you of any changes to this policy and ensuring your data is secure. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect the Reading Plus application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation in ensuring your data is kept secure.
To send marketing communications to you.	(a) Identity (b) Contact	Necessary for our legitimate interests (to promote and grow our business)

Marketing

We use Identity Data and Contact Data of customer contacts to market and advertise Taylor Associates’ products and services to schools. You will always be given the option to unsubscribe from any marketing communication sent via email. Alternatively, you can email info@readingsolutionsuk.com to request that your details are removed from our marketing database.

Cookies

Our website cookie policy is posted online at https://readingsolutionsuk.co.uk/cookies-policy/.

You can set your browser to refuse all or some browser cookies, or to alert you when applications set or access cookies. If you disable or refuse cookies, please note that this may impact on the functionality of our website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose under EU data protection laws. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the process for the new purpose is compatible with the original purpose, please contact us.

Disclosures of your personal data

As owners of the Reading Plus application, Taylor Associates will have access to any personal data inputted by or on behalf of the school in the course of the school using the Reading Plus application and accessing the support services. Their Privacy Policy can be accessed here https://privacy.readingplus.com/.

We may also share your personal data with the parties set out below for the purposes set out in the table above.

External third parties such as:
service providers acting as processors based in the UK or the US who provide IT and system administration services. In particular, personal data of customer contacts or potential customer contacts is stored:
- on our own CRM database with Capsule (owned by Zestia Limited) which stores the information in the UK;
- by Wired Marketing Limited for the purposes of email marketing.

o professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

o HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances

Your employer
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
In some circumstances we may be required to disclose your personal data in response to valid requests from public authorities or governmental departments. This may be in order to meet legal obligations we are subject to (for example, we will disclose information to HM Revenue & Customs in relation to paying tax) or to meet national security or law enforcement obligations.

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

INTERNATIONAL TRANSFERS & PRIVACY SHIELD – EU PERSONAL DATA

Taylor Associates, the owner of the Reading Plus applications, is a US company.

We do not as a matter of routine share any customer relationship data with Taylor Associates, however in the event that a potential customer contacts Taylor Associates directly regarding their subscription or for a trial, Taylor Associates will provide details of that contact to us. To certify themselves with all GDPR compliance Reading Plus appear on the privacy Shield List at: https://www.privacyshield.gov/list to certify compliance with all GDPR requirements. Privacy Shield currently meets international standards for data transfer between the UK and the US.

Data Security

We have put in place reasonable and appropriate security measures designed to prevent your personal data from being accidentally lost or used or accessed, altered or disclosed accidentally or in an unauthorised way. In addition, we have put in place policies and protocols designed to limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. However, no method of transmission over the internet is completely secure, and we cannot guarantee the absolute security of your personal data.

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

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data; see Your Legal Rights below for further information.

Contact matt@readingsolutionsuk.co.uk for specific retention queries.

Your legal rights

Individuals have the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

Please visit the Information Commissioner’s Office website at www.ico.gov.uk to find out more about these rights.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights under data protection laws). However, you may be charged a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, your request may be refused in these circumstances.

What may be needed from you?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take 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.

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