Owner: 1-2-1 Mentors / in consultation with Data Privacy Advisory Ltd
Responsible for Delivery Across 1-2-1 Mentors: 1-2-1 Mentors
Reference and Version Number: V2.0 Date: April 2022
At 1-2-1 Mentor’s we’re committed to protecting, respecting your privacy and being transparent in everything we do.
This notice explains:
We may change this policy from time to time so please check this page to ensure that you’re happy with any changes.
Charmaine Dugdale
(Director):
1-2-1 Mentors, 149-151 Beacon Lane, Exeter, EX4 8LR
Tel: 07510 644343
Tel: 01392 426676
Email: charmainedugdale@1-2-1mentors.com
Questions for the DPO should be sent to dpo@dataprivacyadvisory.com
1-2-1 Mentors registration with the Information Commissioners Office as a Data Controller is number A8425561
Personal Data is processed as necessary by the 1-2-1 Mentors staff to ensure that the children/young adults placed with us get the maximum benefit from their time with us and are safeguarded effectively. We collect Personal Data that is submitted to us by the Commissioner, including the details of the Commissioner and their staff, and also during our teaching and mentoring assessment to ensure that we have a full understanding of the children/young adult’s need and aspirations. We use this Personal Data to help us choose the most suitable and design a bespoke programme to ensure that we give the children/young adults the best opportunities to achieve the goals set.
We collect information in the course of our business. The main prompts for our data collection are when:
The information we collect will change based on the reason we are processing your data. We will never collect more from you than we need.
We keep Personal Data relating to the referral or placement of a children/young adult in order to:
Children/young adults and their parents/carers personal data is never used for direct marketing purposes. Apart from day to day contact with children/young adults and their parents/carers during the course of a provision, the only other contact we may have will be to obtain feedback in connection with a provision.
Information and or Personal Data, that we hold on those who commission our services, is collected and held to ensure that we can fulfil any Contract, and for the legitimate business interests of 1-2-1 Mentors. Contact information may be used for direct marketing from time to time to keep commissioners and potential commissioners up to date with any changes to our services. Commissioners can choose to opt out from these communications if they wish.
When you contact us enquiring about our products and services, we will collect whatever information is necessary prior to taking steps to enter into a contract with you.
This information will typically include the name and place of work of key contacts in your organisation and their contact details. We will also process any information you submit via our online forms. We may also process any other information that we have legitimately collected about you in relation to our other services (such as whether your business has paid for our training courses in the past) where this other purpose was known to you at the point of data collection. This information would only be processed in relation to engaging in a contract at your request.
When we contact you at the request of someone else, we will always tell you who we are and where we got your information from. We will do this as soon as is reasonably possible and no later than 28 days after first receiving your contact details. Wherever possible, we will ask the person referring you to us to make the introduction or to check with you whether it is ok for us to call you first.
The information that we will have processed prior to that point will be likely minimal and will include your name, job title/ place of work and a contact point such as an email or telephone number.
The lawful basis we rely on when contacting you about our products or services at the request of someone else will be different depending on the context. For the most part, it will be in our legitimate interest to do so and you can request that we stop processing your data. Where you have agreed for us to get in touch, we will be doing so based on your consent and you can withdraw this at any time.
If we advertise a job posting or you are interested in working as a contractor for us, we may process some of your personal data so as to take steps to enter into a contract with you.
Typically, we will process your name, contact information and your CV and cover letter. Depending on the route you came into us, we may also look at your publicly available profiles in advance of an interview, such as a LinkedIn page or a professional Twitter account. We will also contact those you offered as a reference for you.
If you let us know about a disability or health condition (or provide us with any other special category data), we will do so under our legal obligations in relation to employment and equality laws.
If you are successful in your application and we want to offer you a job, we will process more information than this. To see our employee privacy notice, please contact Charmaine Dugdale.
Below is a list of the information we may hold:
Category of Personal Data
Names, addresses, date of birth, telephone numbers, email addresses, next of kin, emergency contact details, education history and plans, religion, disabilities, physical and mental health, medication, gender, sexual orientation, marital status, ethnicity, nationality, relatives' and or carers' contact details, social services contact details and role, Police and other official involvement, general educational and social history, court history and orders, financial information, social media
history and interactions.
Purpose of Processing
Future and current children/young adults: Fulfilment of our Contract with the referring Commissioner. Past children/young people; Safeguarding and Child Protection, educational, behavioural and engagement history and attainment.
Children/young adults may be contacted from time to time to provide feedback to assess the effectiveness of 1-2-1 Mentor’s service and as part of 1-2-1 Mentors continual improvement and Quality Assurance.
Legal Basis for Processing
Legitimate Business Interest, Legal Obligation, Public Interest, Vital Interest, Statistical Research and
Processing.
Category of Personal Data
Names, telephone numbers, email addresses and email letter and telephone correspondence and any information provided by the Commissioner.
Relevant background information on the family, other agency involvement/parental consent relating to the children/young adult is obtained.
Purpose of Processing
Fulfilment of the Contract with the Commissioner.
Safeguarding and Child Protection.
Parents/Carers may be contacted from time to time to provide feedback on the effectiveness of 1-2-1 Mentors service and as part of 1-2-1 Mentors continual improvement and Quality Assurance.
Legal Basis for Processing
Legitimate Business Interest,Legal Obligation, Public Interest, and Vital interest.
Category of Personal Data
Names, telephone number, email addresses, office address, job title, employer, email, letter and telephone correspondence, contract(s), tenders, tender submissions, preferences and interests, general financial information relating to the commissioning body, payment terms and efficiency, usage of the
1-2-1mentors.Ltd’s website.
Purpose of Processing
Fulfilment of Contract with the Commissioner. Safeguarding, Child Protection, Behaviour Management, Reporting, Statistical Analysis and Review, and Quality Assurance.
Legal Basis for Processing
Legitimate Business Interest, Legal Obligation, Public Interest, Vital Interest, Research and Statistical Purposes.
We use personal information about you in connection with the following purposes:
Fulfilling your requests:
We use your Personal Data to:
We use your Personal Data to contact you about the children/young adults in order to fulfil our legal and regulatory obligations. This Personal Data will be used to:
Information on those who commission our services or who may commission our services is used to:
Before getting in touch by telephone, we will always check against the Telephone Preference Service (TPS) and/or the Corporate Telephone Preference Service (CTPS), whichever is appropriate.
If you no longer wish to be contacted for marketing purposes, please email:
1-2-1mentors@1-2-1mentors.com
We do not use profiling or automated decision-making tools.
We will hold your data for no longer than we need it for. This will be context dependant on our relationship with you and why we are processing your data. We may have legal (i.e. financial obligation) reasons to keep your data beyond its immediate use, but this will never be for longer than industry standard. For further information about our retention periods, please contact us directly.
If we have a business relationship with you, we may pass some information to our third-party service providers, agents, subcontractor and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we will always have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond our network for them to use for their own direct marketing purposes, unless you have consented to this.
These third parties may include: N/A
We may share your information with credit reference agencies and other companies for use in credit decisions, for fraud prevention.
We may share your information with third party contractors or organisations working with 1-2-1 Mentors to fulfil supplier contracts. We will only share information that is relevant to fulfilling your request.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our staff and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
We are appointed by a Commissioner for our services to work with you through a bespoke teaching/mentoring programme. We will share information about your progress to inform them about how you are doing. This information may include some or all of the following:
We will only disclose information about you to our staff and the commissioning body in connection with the engagement, education and safety of the children/young adults and others associated with them, and in order to perform the Contract, unless required otherwise by law.
Information about Commissioners is shared with staff and member companies within the group only, unless otherwise instructed in order to perform a Contract, with prior agreement, or as required by law.
You have a choice about whether or not you wish to receive marketing information from us.
You have the absolute right to object to us processing your personal information for marketing purposes and to withdraw your consent when that is the basis we rely on.
You can exercise these rights and change your marketing preferences at any time by contacting us by email: 1-2-1mentors@1-2-1mentors.com
Where we have your business contact details (e.g. Information@example-corporation.com) and no personally identifiable information, we may send your business marketing information by email where we think you may be interested in our products or services.
Where we have a corporate email address for you which also contains identifiable information (eg: Joe.Bloggs@example-corporation.com) we may send you business marketing information by email if we think that our products and services may be of interest to you. However, as stated above, you have the right to object and if you do, we will respect your wishes and we will not send you any further marketing material by email.
The accuracy of your information is important to us and, if the personal data we hold about you is incorrect, you have a right to have it rectified. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold about you is inaccurate or out of date, please email us at: 1-2-1mentors@1-2-1mentors.com
You have the right to ask for access to a copy of the personal information 1-2-1 Mentors holds about you. This is known as a Subject Access Request and there is no charge for this, providing the requests are not manifestly unfounded or excessive. We may ask you to provide ID before processing the request. Once in receipt of this, we will process the request without undue delay and within one month. You also have rights in relation to erasure, restriction, data portability and objections. We do not use automated decision-making tools. If you would like to exercise your rights, please contact us 1-2-1mentors@1-2-1mentors.com
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
Our Data Protection Officer is Nigel Gooding and you can contact him at: dpo@dataprivacyadvisory.com
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). Information about how to complain to the ICO can be found here: https://ico.org.uk/make-a-complaint/
Non-sensitive details and emails (your email address etc.) are transmitted normally over the Internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
We take your privacy and protection of your Personal Data very seriously. If you have any questions or comments about the way we collect or use your Personal Data please contact us either in writing:
The Data Protection Officer
10 Oaktree Place,
Manaton Close,
Exeter,
Devon.
EX2 8WA.
or by email: dpo@dataprivacyadvisoryc.com
Our Data Protection Policy is available upon request.
Next Review Date
All policies should be reviewed at least annually or when significant change occurs to the policy subject matter.
The next review date for this policy is 01.09.2023
149/151 Beacon Lane, Exeter, Devon, Ex4 8LR
01392 426676