This policy covers data protection, electronic marketing, and the retention of information within the administration of the School of Philosophy Kingston (“the Branch”), a branch of the School of Philosophy and Economic Science (“the School”).
The Branch’s policy is to adhere to the Data Protection Act 2018 (incorporating the requirements of the General Data Protection Regulation (“GDPR”)), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and such other legislation as may be applicable.
The School also aspires to follow best practice in so far as it relates to its activities.
2. Data Protection
The Branch needs to hold information about:
· enrolled students; and
· members of the public who (1) attend events undertaken or arranged by the Branch; or (2) express an interest in their activities; or (3) visit the Branch’s website; or (4) otherwise wish to receive materials published or distributed by the Branch.
Hereinafter, the following terms shall have the following meanings:
· “we” and “us” shall mean the Branch;
· “you” and “your” shall mean or apply to all those persons listed above;
3. How we collect your information
We may collect your personal data in a few limited ways, namely:
· Directly from you, when you enrol on a course or an event or otherwise participate in the same, when you make enquiries on our website, when you interact with us during your time as a student or recipient of communication in various other ways (for example, where you alert us to a change in your contact details).
· From someone else who has enrolled you on a course or signed you up to an event on your behalf or (for example a family member, or a fellow student who has provided us with your contact details for that purpose).
· From a third party organisation in specific circumstances such as Paypal if you enrol online or others when they are assisting with or organizing an event or activity in conjunction with us.
We will not store or capture personal data through our website(s) without your prior knowledge and consent. Where personal information is so captured it will be used for the purposes set out in this policy.
When collecting data generally we will endeavour, whether by reference to this policy or otherwise, to ensure that you:
· understand why the information is needed, what it will be used for and what the consequences are in the event you decide not to give consent to processing;
· so far as reasonably practicable, grant specific consent, either written or verbal for data to be processed; and
· have received sufficient information on why your data is needed and how it will be used.
4. The types of information we collect
We may collect the following types of personal data about you:
· Contact and communications information, including your contact details (including name, address, email address, phone numbers) and records of communications and interactions we have had with you);
· Demographic information, such as postcode, preferences and interests;
· Website usage data;
· Other information relevant to course enquiries;
· Certain other information, which you volunteer when participating as a student in our activities (for example, when attending courses, or events or in volunteering to assist in the operations of the School).
We may also collect data about your health or medical conditions, where you have volunteered this, for example so that we can cater for you when you attend a course or event or act as a volunteer for and on our behalf.
This is held electronically by the Branch’s administrator familiar with the rights and obligations surrounding your data.
Mailing groups are used for communications with students, and subscribers for events, activities, notifications and publications.
Emergency Contact data is held by the Lead Tutor or administrator of a residential course for the duration of the course and may be used for emergency contact purposes.
5. How we use personal data
Unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, personal data provided to us will be used for the purposes set out at the time of collection (which may consist of those purposes set out in this policy) and, where relevant, in accordance with any preferences you express.
If you require any information as to how processing for the new purpose is compatible with the original purpose, please contact Peter Reddell (Branch Leader) by email to firstname.lastname@example.org.
We will only use your personal data where the law allows. In general terms, save as set out elsewhere in this policy:
· personal data we hold is used for the purposes of administering or improving courses or events or other activities and publications; and
· your details will not be passed to any other organisation for any purpose.
If we are so permitted, you may receive from us details of activities run by or in conjunction with other organisations by post or email. You are free to opt out of receiving such communications from us at any time.
Where we have your consent and / or (if within the law) where this is necessary for our legitimate interests (or the legitimate interests of a third party), as applicable, we use your personal data for the following purposes:
· in the administration of courses, events, and activities including: a. general notifications to you about them; and b. receiving payment of course fees and other charges;
· research and statistical analysis about the courses or events or activities we offer;
· communication about our activities or events and activities outside of the School and its branches that we think may be of interest to you;
Please note that we may also use your data and share it with others where it is necessary:
· for us to comply with a legal obligation to which we are subject;
· to protect the vital interests of the data subject or of another natural person.
Personal data collected and processed by us may be shared, where necessary, with:
· our volunteers, for the purposes of administering courses, events, publications and activities organised by or in conjunction with us and giving you access to the benefits to which you are entitled.
· our contractors, professional advisors, auditors or suppliers, including those providing IT services or data management services.
Statistical information may be shared with the School for administrative purposes, but this will not include personal information.
We do not sell your personal data to/with other organisations to use and, save as set out above, do not otherwise share it with other organisations.
6. Cookies and how we use them
What is a cookie?
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.
Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
· Analyse our web traffic using analytics packages: Aggregated usage data helps us improve the website structure, design, content and functions.
· Identify whether you are signed in to our website: A cookie allows us to check whether you are signed in to the site.
· Test content on our website
· Store information about your preferences: The website can then present you with information you will find more relevant and interesting.
· To recognise when you return to our website: We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
7. Your marketing preferences
We will always respect your wishes in respect of what type of communications you want to receive from us and how you want to receive them. We wish to gain your prior consent to mailings. However, there are some communications that we may need to send you without your specific prior consent, for example, in order for us to fulfil our contractual obligations to you. Examples of these essential service communications are:
· Mailings directly concerning your participation on a course or at an event, notices of formal meetings, and notification about similar or related courses or events similar to one who are attending or have recently attended.
· Records of transactions, such as payment receipts or Direct Debit confirmations, booking confirmations (as applicable).
8. Controlling information about you
When you fill in an enrolment form, you will see a tick box allowing you to Opt‐in to receive marketing communications from us by email.
You are in control of how we communicate with you. If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods:
· Click the link on any email that you receive to unsubscribe from our email list
· Send an email to BRA
· Write to us at: The School of Philosophy Kingston c/o 11 Mandeville Place, London W1U 3AJ
If you do opt out of marketing communications but are enrolled on one of our courses, we will still contact you with relevant, non-marketing information pertaining to the course or event for which you have enrolled.
We will always hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards.
We also follow stringent procedures to ensure we work with all personal data in line with the relevant legislation.
10. Links from our sites
Our websites may contain links to other websites.
Please note that we have no control of websites outside of the Branch website.
The School website, www.schoolofphilosophy.org, and websites of other branches, adhere to similar data protection and privacy policies as those detailed in this policy. Links to their data protection and privacy policies are included on their websites.
If you provide information to a website to which we link, we are not responsible for its protection and privacy.
Always be wary when submitting data to websites. Read the sites’ data protection and privacy policies fully.
11. How long your information is kept
We keep your personal data only for as long as necessary for each purpose we use it. You can voluntarily unsubscribe from mailing groups at any time.
Financial records must be retained for a period of six years after your last interaction with us (for accounting, tax reporting and record-keeping purposes).
12. Your rights
Under certain circumstances, by law you have the right to:
· Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
· Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. You can also withdraw your consent, where this is the basis for our processing your data (without affecting the lawfulness of our previous processing based on consent).
· Request the transfer of your personal data to another party.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
13. Contact and complaints
· by email: PeterR@fses.org
· or by post: Peter Reddell, The School of Philosophy Kingston c/o 11 Mandeville Place, London W1U 3AJ
If you are not satisfied with the response, please contact the School’s General Manager
· by email: email@example.com;
· or by post: : Laura Counsell, General Manager, School of Philosophy and Economic Science, 11 Mandeville Place, London W1U 3AJ
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk.
Version last updated 24 June 2022