Upward Mobility Privacy Policy

Introduction
Upward Mobility as an organisation has a responsibility to protect and respect your privacy and to look after data provided to us.

This privacy notice explains what data we collect, how we use that data, where we store the information, how long we store that data for and how we store your details securely. If you have any questions about this privacy notice/policy or how we handle your personal information, please contact Upward Mobility at the address below.

Upward Mobility as a data controller are responsible for deciding how we hold and use personal information about you. This notice explains to you what decisions we have taken in relation to that information.

Upward Mobility may change this policy from time to time by updating this page. The last updated date will be displayed at the bottom of this page.

General data protection principles
In collecting and processing your personal information we will comply with the data protection law in force at the time. This requires that the personal information we hold about you must be:

  • used lawfully, fairly and in a transparent way,
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes,
  • relevant to the purpose we have told you about and limited only to those purposes,
  • accurate and kept up-to-date,
  • kept only if necessary for the purposes we have told you about, and
  • kept securely.

What information is being collected?
If you give us consent, we may collect and store the following information while you access our service online, by phone or in writing.

  • We collect information on our students from themselves, their families, educational, social work and health care professionals and other outside agencies. Also, through our ongoing contact with our students, we will update information required to support them to a high standard.
  • We collect information about our employees throughout the period that an employee is working for us (eg, recruitment & selection processes, ongoing appraisals, training and absence management)
  • We collect information from other sources, such as HMRC, DWP, PVG, and publicly available information (for example social media, internet, news articles, etc) when assessing employees or partner organisations.
  • We collect information when you visit our website, through the use of ‘cookies’ and other tracking technology, to understand how you found our website, the pages you viewed and the length of time you viewed them, the type of device you use, your IP (internet protocol) address, and browser type. This allows us to continue to improve our website content and the online experience for users.
  • Information relating to any transactions carried out between you and us on or in relation to this website, including:
    • information related to any membership application,
    • training course bookings,
    • grant applications,
    • organisational development referrals,
    • newsletter subscriptions such as email address and name,
    • noticeboard notices, and/or
    • contact forms.
    • Any other information that you choose to send to us.

Only Upward Mobility staff, authorised contractors and approved volunteers can collect information on Upward Mobility’s behalf.

We may request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

How will the information be used?
We use information submitted in the following ways depending on what reason you provided information to us.

  • To provide you with services and information.
  • To fulfil our legal and regulatory obligations.
  • To manage our relationship with you.
  • To process registrations and invoices for training courses.
  • To provide organisational development and support services.
  • To respond to your requests from contact forms.
  • To publish noticeboards on the website.
  • For the purposes of recruitment.
  • To enable us to review, develop and improve our website and the services we offer.
  • To process donations to Upward Mobility.
  • For other legitimate business purposes.

We will only use personal information when the law allows us to.

Who will information be shared with?
Upward Mobility may share personal information with other companies who support us to deliver our service (eg, IT maintenance supplier, HR service supplier). We will only provide these companies with the information they need to deliver the relevant service and we ensure that your information is treated with the same standards as if we were handling it ourselves. We do not allow our third-party contacts to use your data for their own purposes and require them to take appropriate security measures in respect of your personal information.

We may also need to disclose your personal information to regulatory or government bodies (eg, Care Commission, HMRC), the police or our legal advisors.

Please note Upward Mobility will NOT sell your information to other third parties.

Do we need your consent to use particularly sensitive information?
We don’t require your consent if we use your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive information. If we do so, we will provide you with full details of the information that we would like and the reason that we need it, so that you can carefully consider whether you wish to consent.

If you fail to provide us with personal information
We may be unable to provide the best service if you do not provide certain information when requested. It may also prevent us from complying with our legal obligations.

Change of purpose
We will only use your personal information for which we collected it, unless we reasonably consider that we need to us it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the reasons for this so that you can carefully consider whether you wish to consent.

How we store your personal data
Upward Mobility will take all reasonable steps to protect your data in accordance with this privacy policy. We have put in place appropriate measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Electronic data is stored on secure computer systems and we control who has access to them. Our staff only have access to the data necessary for them to carry out their responsibilities.

All the information that you provide to us is stored on encrypted servers within the European Economic Area (EEA). However, some of our suppliers may run their operations outside the EEA or your information may be transferred outside of the EEA e.g. in relation to the provision of a services such as newsletter subscriptions. Although they may not be subject to the same data protection laws as companies based in the EEA we ensure they provide an adequate level of protection in accordance with UK data protection laws.

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

How long we store the data
Upward Mobility will only store the information you provide for as long as is needed for the purpose it was originally obtained. This is dictated by legal and financial obligations as well as business requirements.

We’ll hold your personal information:

  • for as long as we have reasonable business needs, such as managing our relationship with you and managing our operations,
  • for as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us, and/or
  • for retention periods in line with legal and regulatory requirements or guidance.

IP addresses and cookies
Upward Mobility may collect information about your computer, including where available your IP address, operating system and browser type, for system administration purposes. This is statistical data about users’ browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your Internet usage by using a cookie file that is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us improve the website and deliver a better and more personalised service.

You may refuse to accept cookies when you first visit our website, or by activating the setting on your browser that allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the website.

  • _utma, _utmb, _utmc, _utmz
    These cookies are used by Google Analytics to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
  • Squarespace
    Our website runs on the Squarespace website platform. Squarespace uses cookies to track a user session, when they last visited or did something on the site. No personal information is stored in these cookies; only timestamps related to that browser session.
  • Third party cookies
    The code provided by Twitter, Facebook and Instagram to include additional functionality on our website may, by default, set cookies. For information about these third party cookies, go to http://twitter.com/privacy, www.facebook.com/about/privacy or https://help.instagram.com/519522125107875.
  • External web links
    Our website may contain links to other websites and resources that you may find of interest. Once you leave our website, you should note that we do not have any control over the external website. We are not liable for your protection and privacy on these external websites. You should exercise caution and look at the privacy policies applicable to the website in question

Your rights
The General Data Protection Regulations (EU Regulation 2016/679) provide a set of standardised data protection laws that aim to make it easier for people to understand how their data is being used and strengthens your rights.

  • The right to be informed about the processing of your personal information.
  • The right of access to your personal information.
  • The right to rectification – have any incomplete or inaccurate information we hold about you corrected.
  • The right to request erasure of your personal information.
  • The right to request the restriction of processing your personal information.
  • The right to data portability – the right to move, copy or transfer your personal information.
  • The right to object to processing of your personal information.
  • Rights in relation to automated decision making and profiling.

We have outlined more details on each of these rights below. If you would like to exercise any of these rights or have any general queries about your personal information then please contact us (contact details below).

We will deal with these requests without undue delay and at the latest within one month of receiving the request. Where requests are complex and numerous we may need to extend the time limit for responding by two months.

If requests are excessive or repetitive we reserve the right to charge a fee to cover the administrative costs involved.

If a request is manifestly unfounded or excessive we may refuse to comply with the request and will provide you with a justification for our decision.

The right to access your personal information
You have the right to request a copy of the personal information we hold about you. We will aim to provide the information you have requested without undue delay and at the latest within one month of receiving the request.

The right to rectification – the right to edit and correct your personal information
It is important to us that we hold accurate information and we endeavour to ensure that this is the case.
You have the right to request that inaccurate personal information is rectified or completed (if incomplete).

The right to request erasure of your personal information
You can request the deletion or removal of your personal information when there is no compelling reason for its continued processing. You do not have an automatic right to have your personal information deleted and each request will be dealt with on an individual basis. If we are unable to comply with your request we will provide you with a justification for our decision.

The right to request the restriction of processing your personal information
You have the right to request that we suspend processing of your personal information. In this case we may continue to hold your information but will not process it any further. There may be circumstances where we have an obligation to process the data and we would inform you if that is the case before we lift the restriction. Where possible we will endeavour to comply with your request but if that is not possible we will provide you with a justification for our decision.

The right to data portability – the right to move, copy or transfer your personal information
You have the right to receive a copy of your personal information or to ask us to share your personal information with another organisation or individual. We will endeavour to facilitate these requests although they will be considered on an individual basis as we may need to seek agreement from all parties involved and assess technical feasibility.

If we provide information directly to an individual or another organisation, then we will take appropriate measures to ensure it is transmitted securely and to the right destination. We are not responsible for the security or subsequent processing that may be carried out by these parties after we share your personal information.

The right to object to processing of your personal information
You have the right to object to the processing of your personal information in particular to data processed for direct marketing purposes. For example, if you no longer want to receive our newsletter you may choose to unsubscribe. In these circumstances we may continue to hold personal information to ensure that we suppress further communications to you.

If you object to processing of your personal information so that we can provide you with a service, then we will consider your request on an individual basis. There may be circumstances where we have an obligation to process the data and we would inform you if that is the case before we lift the restriction. Where possible we will endeavour to comply with your request but if that is not possible we will provide you with a justification for our decision.
Rights in relation to automated decision making and profiling
Some organisations may make decisions about you using only technology without their employees being involved (eg, applications for online loans or insurance policies). Upward Mobility does not currently use any automated decision-making or profiling technology.

How to contact us
Data Protection
Upward Mobility
151 London Road
Edinburgh EH7 6AE

Telephone: 0131 661 4411
Email: info@upmo.org
ICO Registration Reference: Z5984382

Your right to make a complaint
You can raise a concern about how we handle your personal information to Upward Mobility (contact details above).

You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are not happy with how we process your personal information or how we have handled your request.
The ICO is the UK supervisory authority for data protection issues.

www.ico.org.uk/concerns
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Changes to the privacy notice
We reserve the right to update this privacy notice at any time. The latest version of this policy will be available on our website. If there is a major change to our privacy policy we will add a notice to our website and may contact you by email (where appropriate). We may also notify you in other ways from time to time about the processing of your personal information

This privacy policy was last updated in July 2018.