PRIVACY POLICY
Privacy Law means the Data Protection Act 1998 (as amended by the Data Protection Act 2018), the EU Data Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice)(Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011, the General Data Protection Regulation (from 25 May 2018) and all other applicable laws and regulations relating to processing of personal data and privacy in any applicable jurisdiction as amended and replaced, including where applicable the guidance and codes of practice issued by the UK Information Commissioner or such other relevant data protection authority.
Who we are
SPARK Opportunity operates as a social enterprise whose aims are to find pathways for learners into employment.
Our website address is: https://www.spark-opportunity.co.uk
Changes to our Privacy Notice
The Privacy Notice is reviewed regularly as part of our internal processes or as our services change. It is subject to change at any time, but the most up to date version is published on our website: www.spark-opportunity.co.uk
This notice is dated: 24 September 2004
Contacting us
If you'd like to request further information about our privacy policy or exercise any of your rights, you can contact us:
By email at: hello@spark-opportunity.co.uk
Through our website: www.spark-opportunity.co.uk
Information we collect from you and what we do with it
We only collect data that is necessary so we can provide our service to you. We use your information to administer, support, improve and develop our business generally, to provide statistical information to meet our lawful requirements and to enforce our legal rights. If we intend to use your information for a different purpose, we will do so in ways consistent with Privacy Law or, wherever possible, by notifying you in advance.
We will only use your information for the specific purpose(s) for which it has been provided to or collected.
We collect and process a variety of information from you and about you. In most cases, the information we collect about you is provided by you directly. This helps us to confirm the information we collect is accurate and as up to date as possible. We will usually do this when you first contact us, though we may ask you to confirm your details on subsequent contacts from time to time.
The type of information collected from you and obtained about you will vary depending on your relationship with us. We are likely to ask you to provide name, address and contact details, including phone number and email address to contact you about your enquiry and provide our service to you and keep you up to date about the services you have requested or receive from us, inform you about any service interruptions, or contact you with other information related to our business; financial information (including method of payment and bank account details) and manage your payment arrangements.
To ensure you receive the best possible service, we will ask you personal information about your lifestyle and personal preferences. We will only collect sensitive personal information about you or your family, such as medical information, with your explicit consent, and for a specified purpose which will be explained to you at the time. This information will be kept for as long as necessary and only passed on to third parties when necessary.
Who we share your data with
We use trusted partners to help us process your personal information and provide services to you, such as:
• Financial companies to help us process payments including card payments and to process cheques;
• Legal services, insurance companies or other professional advisors to obtain advice or make a claim.
• Estate agencies or other property professionals to ensure we find the perfect home for you
• School and educational settings to ensure we abide by their safeguarding policies and best practices.
• Other trusted partners that you consent to sharing data with to ensure you relocation is a smooth process
We process personal data for certain legitimate business purposes, which includes undertaking research to understand:
• views on the possible future direction of the business
• how people interact with our website
• how people choose and/or use our and services
• Information we share with others
In most circumstances we will not disclose your personal information without your consent. However, there are circumstances where we need to share some of your information to meet our compliance obligations or where we are permitted to under Privacy Law. We have legal obligations to share data with some third parties identified in law. We may disclose your personal information to third parties if we are under a duty to disclose or share your personal information to comply with any legal obligation. We do not require your consent to process your information in this way.
Information we collect or obtain from others about you
We prefer to collect information about you directly. This helps us to confirm the information we collect is accurate and as up to date as possible.
When necessary, we will receive information collected by our trusted partners or other parties working directly with you, relating to services they are delivering to you, or to respond to a complaint you have made.
Comments
When visitors leave comments on our website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
Contact forms
We only keep your information for as long as necessary and we you do not use the information submitted through contact forms for marketing purposes.
Cookies
We use cookies to make our services and websites work more effectively as well as to collect to information. We may obtain information about your general internet usage by using a cookie file which is stored on your browser, your mobile device or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. Some of the cookies we use are essential for the services site to operate. If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
Analytics
We may use data analytics to improve our website, services, marketing, customer relationships and experiences. Google Analytics is a third-party website monitoring tool that allows users to see volumes of website visitors, their source, and to analyse how the content of their website is viewed and navigated. Google Analytics does not store any personal information about website visitors, but does use persistent cookies to identify repeat visitors. You may universally opt-out of all Google Analytics tracking used by all websites by visiting https://tools.google.com/dlpage/gaoptout Google's privacy policy is available at: https://www.google.com/policies/privacy/.
Embedded content from other websites and third party websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Our website may also contain links to and from other websites including our partner networks and affiliates. If you follow a link to any of these websites, please note that we do not have control over these websites or their content. These websites have their own privacy policies and we will not accept any responsibility or liability for you visiting these. We recommend that you review the website terms and conditions that are applicable to the third-party website.
How long we retain your data
We will retain certain information (i.e. contact information and bank details) for as long as you have a relationship with us.
Generally, we keep:
• correspondence, complaints, financial details and contact histories - we will retain this data whilst you continue to engage with us for our services and thereafter for up to five years;
• data subject requests (i.e. subject access requests and objections) for up to five years;
• web chats and social media posts (in third party systems) for up to twelve months, unless related to a complaint;
After which time your personal information will be either deleted or anonymised.
These retention periods may be extended in certain limited cases as prescribed or permitted by law.
What rights you have over your data
You can request a copy of information we hold about you at any time.
Privacy law requires us to respond to your request within 30 calendar days of verifying your identity (or within 3 months for more complex cases). You'll receive a full response as soon as we can reasonably provide one and we aim to resolve all subject access requests within 30 calendar days. In more complex cases where we cannot provide a full substantive response within that time frame, we will write to you within 30 calendar days to explain why an extension is needed. We don't charge for subject access requests.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If you believe information we hold about you to be inaccurate or incomplete, you can ask us to correct it or complete it at any time, through any of our contact channels. Wherever possible, we will correct inaccurate or incomplete information immediately.
You have the right to ask us to restrict the use of your personal information
In some instances, you have the right to ask us to restrict the use of your personal information (for example if you have challenged the accuracy of the information we hold or have objected to our processing). We will restrict our use of your information whilst we investigate your objection or request to correct your information.
We will respond to your request as soon as we can, and we will act on any requests within one month of your request.
You have the right to data portability
Where we process your personal information with your consent or for the performance of a contract, and our processing is automated, you have the right to move, transfer or copy that data to another system for your own purposes. If we do in future, you can make a request and this data can be exported from our systems for you.
You have the right to ask us not to process your personal information
We process most of the information we collect about you under the lawful basis of 'legitimate interest'. You have the right to object to our processing your personal information under this lawful basis, or for marketing purposes (including profiling).
We will respond to your objection as soon as we can, detailing any actions we can reasonably make. If we believe there is an overriding compelling reason to continue the processing, we will explain why we think this is.
We will action any requests to stop direct marketing as soon as we receive your objection.
You can object to us using your data at any time through any of our contact channels.
Lawful basis for processing
Privacy Law states we must have a lawful basis for processing your information. We may do this in the following instances:
• the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests;
• you have given consent for us to process the information i.e. in relation to certain marketing activities;
• the processing is necessary for a contract we have, or because we have been asked to take specific steps before entering into a contract;
• the processing is necessary for compliance with a legal obligation to which we are subject i.e. we are required to provide certain information to HMRC;
• the processing is necessary for us to comply with the law.
Contacting us
When you contact us by telephone, your telephone number may be added to our records so that we can contact you in future to provide further services or information. We may keep notes about the conversation held to ensure you are receiving the best service possible.
If you contact us by post or email we will keep a record of the contact. We will respond to you using the email address you gave us. We may add your email address to our account and it may be used for future communications. Please note that email isn't considered to be a secure communication method. If you have any concerns over the security of your information in transit, please raise this with us so that we can suggest alternative methods of contact. Emails sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with our own policies. Emails are stored, archived and deleted in line with our information security and data retention policies. If you use our website to contact us we will keep a record of the contact.
We strongly advise not to post your personal contact or other sensitive information on a public social media site. If you contact us using social media to report an issue, we will ask you to private message us.
Complaints
Complaints concerning your privacy are taken very seriously. If you think our use of your personal information is inappropriate please let us know and we will provide additional information needed. We also welcome suggestions for improving our procedures.
We may need to share details about your complaint internally to fully investigate. If you escalate your complaint to the Information Commissioners Office, we may share information with them in order to resolve your complaint.
If the complaint relates to a service provided by a third party, we will share information with them to resolve your complaint. If a complainant doesn't want information identifying them to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We will only use the personal information we collect to process the complaint and to examine the level of service we provide.
We will keep complaints in line with our data retention policy. This means that information relating to a complaint will be retained for two years from closure.
You can contact the Information Commissioner's Office at www.ico.org.uk for information, advice or to make a complaint. Here you can also access information relating to the right you have regarding your personal information.
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