Last updated: February 2019
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.
(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.
We are a data controller
Our data privacy manager’s details are:
Name or title of data privacy manager: Matt Smith
Email address: firstname.lastname@example.org
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.
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.
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:
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.
We use different methods to collect data from and about you including through:
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:
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.
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|
|Necessary for our legitimate interests (to promote and sell the Reading Plus application)|
|(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|
|(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|
|Necessary for our legitimate interests (to promote and grow our business)|
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 email@example.com to request that your details are removed from our marketing database.
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.
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.
We may also share your personal data with the parties set out below for the purposes set out in the table above.
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
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.
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.
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.
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 firstname.lastname@example.org for specific retention queries.
Individuals have the right to:
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.