Policies

Privacy Policy

Last updated: 18 May 2021

Introduction

Welcome to the Boarding School Survivors – Support’s privacy notice.

Boarding School Survivors – Support respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Boarding School Survivors – Support collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements any other notices and is not intended to override them.

Controller

Boarding School Survivors – Support is the controller and responsible for your personal data (referred to as “BSS-S”, “we”, “us” or “our” in this privacy notice).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO – so please contact us in the first instance.

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

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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 follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:
    • analytics providers such as Google based outside the UK;
    • advertising networks; and
  • Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the UK.

How we use your personal data

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:

Where we need to perform the contract we are about to enter into or have entered into with you.

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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 plan to use your personal data, and the lawful basis on which we rely to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you
To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. 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)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any company outside BSS-S for marketing purposes.

We operate an implied consent policy. This means that we assume that if you visit the website with your browser set to accept cookies that you are happy with their usage. If you are not happy you should not use the site or delete these cookies at the end of your visit.

What are cookies?

Cookies are small text files that are transferred by a website to your browser directory. They help the website identify your browser/device. They perform different tasks on a website, and certain aspects of the website will not function correctly without them. To find out more about cookies visit www.allaboutcookies.org

The cookies used on a website are:

Google Analytics

This gathers information about users, how they found and navigated the site as well as facts about which browsers they have used. The data gathered by this cookie is anonymous and is used to enhance the usability of the website. Further information is available from: http://www.google.com/intl/None/policies/privacy

Session cookies

Session cookies are used to remember you when you log in and also for the shopping cart. Disabling these cookies will stop this functionality working.
Further information about session cookies is available from: http://www.allaboutcookies.org/cookies/session-cookies-used-for.html

Equal Opportunities and Diversity Policy

Policy Statement

Boarding School Survivors – Support (“BSS-S”) is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. This Policy aims to remove unfair and discriminatory practices within BSS-S and to encourage full contribution from its diverse community. BSS-S is committed to actively opposing all forms of discrimination.

BSS-S also aims to provide a service that does not discriminate against its clients and customers in the means by which they can access the services and goods supplied by BSS-S. BSS-S believes that all employees and clients are entitled to be treated with respect and dignity.

Objectives of this Policy

  • To prevent, reduce and stop all forms of unlawful discrimination in line with the Equality Act 2010.
  • To ensure that recruitment, promotion, training, development, assessment, benefits, pay, terms and conditions of employment, redundancy and dismissals are determined on the basis of capability, qualifications, experience, skills and productivity.

Definition of Discrimination

Discrimination is unequal or differential treatment which leads to one person being treated more or less favourably than others are, or would be, treated in the same or similar circumstances on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. Discrimination may be direct or indirect, and includes discrimination by perception and association.

Types of Discrimination

Direct Discrimination

This occurs when a person or a policy intentionally treats a person less favourably than another on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

Indirect Discrimination

This is the application of a policy, criterion or practice which the organisation applies to all people but which is such that:

  • It is it detrimental to a considerably larger proportion of people from the group that the person the organisation is applying it to represents;
  • The organisation cannot justify the need for the application of the policy on a neutral basis; and
  • The person to whom the organisation is applying it suffers detriment from the application of the policy.

Example: A requirement that all employees must be 6ft tall if that requirement is not justified by the position would indirectly discriminate against employees with an oriental ethnic origin, as they are less likely to be able to fulfil this requirement.

Harassment

This occurs when a person is subjected to unwanted conduct that has the purpose or effect of violating their dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Victimisation

This occurs when a person is treated less favourably because they have brought or intend to bring proceedings or they have given or intend to give evidence.

Unlawful Reasons for Discrimination

Sex

It is not permissible to treat a person less favourably on the grounds of sex, marital status, civil partnership, pregnancy or maternity, gender reassignment or transgender status. This applies to men, women and those undergoing or intending to undergo gender reassignment. Sexual harassment of men and women can be found to constitute sex discrimination.

Example: Asking a woman during an interview if she is planning to have any (more) children constitutes discrimination on the ground of gender.

Age

It is not permissible to treat a person less favourably on account of age. This applies to people of all ages.  This does not currently apply to the calculation of redundancy payments.

Disability

It is not permissible to treat a disabled person less favourably than a non-disabled person.  Reasonable adjustments must be made to give the disabled person as much access to any services and ability to be employed, trained, or promoted as a non-disabled person.

Race

It is not permissible to treat a person less favourably on account of race, skin-colour, nationality or ethnic origin.

Sexual Orientation

It is not permissible to treat a person less favourably on account of sexual orientation. For example, an employer cannot refuse to employ a person because s/he is homosexual, heterosexual or bisexual.

Religion or Belief

It is not permissible to treat a person less favourably on account of religious beliefs or religion or lack of any religion or belief.

Positive Action in Recruitment

Under the Equality Act 2010, positive action in recruitment and promotion applies as of 6 April 2011. ‘Positive action’ means the steps that BSS-S can take to encourage people from groups with different needs or with a past record of disadvantage or low participation, to apply for positions within BSS-S.

If BSS-S chooses to utilise positive action in recruitment, this will not be used to treat people with a protected characteristic more favourably, it will be used only in tie-break situations, when there are two candidates of equal merit applying for the same position.

Reasonable Adjustments

BSS-S has a duty to make reasonable adjustments to facilitate the employment of a disabled person.  These may include:

  • Making adjustments to premises;
  • Re-allocating some or all of a disabled employee’s duties;
  • Transferring a disabled employee to a role better suited to their disability;
  • Relocating a disabled employee to a more suitable office;
  • Giving a disabled employee time off work for medical treatment or rehabilitation;
  • Providing training or mentoring for a disabled employee;
  • Supplying or modifying equipment, instruction and training manuals for disabled employees; or
  • Any other adjustments that BSS-S considers reasonable and necessary provided such adjustments are within the financial means of BSS-S.

Employees with a disability who feel that any such adjustments could be made by BSS-S should contact a BSS-S director.

Responsibility for the Implementation of this Policy

All employees, subcontractors and agents of BSS-S are required to act in a way that does not subject any other employees or clients to direct or indirect discrimination, harassment or victimisation on the grounds of race, sex, pregnancy or maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

The co-operation of all employees is essential for the success of this Policy. Senior employees are expected to follow this Policy and to take steps to ensure that all employees, subcontractors and agents do the same.

Employees may be held independently and individually liable by BSS-S for their discriminatory acts and in some circumstances an Employment Tribunal may order them to pay compensation to the person who has suffered as a result of discriminatory acts.

BSS-S takes responsibility for achieving the objectives of this Policy, and endeavours to ensure compliance with relevant Legislation and Codes of Practice.

Acting on Discriminatory Behaviour

A person who is the subject of, or perpetrator of, or witness to, discriminatory behaviour, should contact a BSS-S director.

Advice and Support on Discrimination

Contacts include:

Equality and Human Rights Commission

Fleetbank House, 2-6 Salisbury Square, London, EC4Y 8JX

Helpline Telephone Number:

Phone: 0808 800 0082

Textphone: 0808 800 0084

Website: www.equalityhumanrights.com

Citizens Advice Bureau

3rd Floor North, 200 Aldersgate Street, London, EC1A 4HD

Website: www.citizensadvice.org.uk

Community Legal Services Direct

Telephone: 0845 345 4 345

Website: www.clsdirect.uk

The Extent of the Policy

  • BSS-S seeks to apply this Policy in the recruitment, selection, training, appraisal, development and promotion of any employee. BSS-S offers goods and services in a fashion that complies with the spirit of this Policy.
  • This Policy does not form a part of any employment contract with any employee and its contents are not to be regarded by any person as implied, collateral or express terms to any contract made with BSS-S.
  • BSS-S reserves the right to amend and update this Policy at any time.