Introduction and Purpose
Sedbergh School is a company limited by guarantee registered in England No: 3946280, we are committed to protecting and respecting the privacy and security of personal information. This policy describes how we collect and use personal information about you.
Sedbergh School is registered with the Information Commissioners Office as a “data controller”. We are responsible for deciding how we hold and use personal information. We are required under The General Data Protection Regulations (EU) 2016/679 and the United Kingdom Data Protection Act 2018 to notify you of the information contained in this policy.
This policy also applies to our subsidiary and trading companies:
Casterton Sedbergh Preparatory School
Sedbergh School Developments Limited
Sedbergh School International Limited
This notice applies to current and former pupils, parents, customers, subscribers, third parties intending to become pupils, visitors to our websites, and those who have used or registered for any of our products or services.
By registering, applying for or by visiting any of our websites, including:
sedberghschool.org
mulberrybushnursery.sedbperghprep.com
iss.sedberghschool.org
summercourses.sedberghschool.org
sedberghprep.org
Or any of our site landing pages, you are accepting and consenting to the practices described in this policy. You may also be asked to accept the terms of this privacy policy before applying for any of our products or services, completing an online booking or submitting an online query on our Site. This policy does not form part of any contract that you may have with Sedbergh School. It is for information purposes only.
With regard to each of your visits to our websites, we will automatically collect the following information:
1. Technical information, which may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform.
2. Information about your visit, including the full Uniform Resource Locators (URL), click stream to, through and from our websites (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our help team number.
3. If you contact us using the telephone numbers listed on our websites, we may record calls for training and monitoring purposes as well as ensuring our marketing is delivered and attributed effectively.
Cookies
Our websites may use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our websites and also allows us to improve our them. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or other device if you agree. Cookies contain information that is transferred to your device’s hard drive.
We may use the following cookies:
Strictly necessary cookies
These are cookies that are required for the operation of our websites and include, for example, cookies that enable you to log into secure areas.
Analytical/performance cookies
These allow us to recognise and count the number of users of our websites and to see how users move around our websites. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily. We use a suite of analytical software such as Google Analytics and heat tracking technology such as Hotjar, to see what areas of the website are clicked/interacted with.
Functionality cookies
These are used to recognise you when you return to our websites, to personalise our content for you, and remember your preferences.
Remarketing Cookies
We may use these cookies to tailor specific advertisements to you after you leave our websites that will be shown on third party websites to enable us to provide you the latest offers and information.
We used AdRoll to serve ads for retargeting and advertising. To view more information about how your personal data is used, click the following link: https://www.adrollgroup.com/privacy
Custom Audience Pixel
A custom audience pixel is a small piece of JavaScript code that we have incorporated into each of our webpages. This code provides a series of functions from transmitting application-specific events and user-defined data to third-parties. We use custom audience pixels to record information about the way visitors use our websites. For this reason, each of our webpages contains a custom audience pixel.
This pixel records information about the user’s browser session, which it sends to third-parties, along with a hashed version of the third-party ID and the URL viewed. The user information will be deleted after 180 days, until the user visits our websites again. No personal information of visitors to the website will be disclosed, and Sedbergh School can only advertise to website customer target groups in a targeted way once the customer target group has reached a critical mass. This makes it impossible for Sedbergh School to discover the identity of individual users.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites or access the services we may provide to you through it.
Google Analytics cookies will expire after the following time frames: new visitor information (2 years), average length of time on website (30 minutes) and referral information (6 months).
Uses made of the information
We will only use personal information where current regulations permit us to. We must identify a lawful basis for each use of personal data. We rely on a number of these, including:
1. Where we have obtained freely given, specific, informed and unambiguous consent from you to use your personal information in certain ways, for example in marketing communications.
2. Where we need to perform a contract that we have entered into.
3. Where we need to comply with a legal obligation.
4. Where we need to use personal information to pursue our legitimate interests (or those of a third party) and we believe that using personal information in that way is not overridden by the interests or fundamental rights of the person to whom the information relates.
We use information held about you in the following ways:
Information you give to us.
We will use this information:
• To analyse the information, we collect so that we can administer, support and improve and develop our business and the services we offer.
• To contact you in order to send you details of any changes to our services or supplies which affect you.
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know when you submit the relevant data which could be on our online booking form, comment/query form or any other form on which you submit information to us on our websites.
• To ensure that content from our websites are presented in the most effective manner for you and for your device.
• To provide relevant marketing communications to you via email, text, post, online or telephone.
• To make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them.
• To communicate with you on third party social media platforms.
• To monitor the effectiveness of our marketing communications and your responses to it.
• If you contact us via a phone number listed on our site, to record these for training and monitoring purposes and to identify the digital source for attribution and improvements in our digital marketing delivery.
• For all other purposes consistent with the proper performance of our operations and business.
Information we collect about you
We will use this information:
• To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our websites to ensure that content is presented in the most effective manner for you and for your device.
• To allow you to participate in interactive features of our service (when these are available from time to time), when you choose to do so.
• As part of our efforts to keep our site safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• To make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Communication & marketing
If you are an existing contact, joined our mailing list or submitted an enquiry we may occasionally update you on our latest services, news and special offers via e-mail and telephone. You have the right to withdraw this consent or amend your marketing preferences at any time by contacting the Deputy Bursar (Compliance) [email protected]
Disclosure of your information
You agree that we have the right to share your personal information with:
• Sedbergh School and any of its subsidiaries or any of our associated companies.
• Selected third parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Sedbergh School or any of its associated companies, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our online booking terms and other agreements; or to protect the rights, property, or safety of Sedbergh School, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• All third parties are required to take appropriate security measures to protect your personal information in line with our policies.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). Where information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice.
For information processed through any of our sites (include online bookings), this may be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of any of our services online booking, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
If we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How we keep your data secure
We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those people who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
Any data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information) or as set out in any relevant contract we have with you.
For failed applications, we will hold your data for up to one year.
For enquiries, we will hold your data for up to two years from the date on which the enquiry is sent.
For call recordings, we will hold these for up to three months from the date of the recording.
Changes to your data
It is important that the personal information is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us. If your personal information changes, please let us know by emailing the Deputy Bursar (Compliance) [email protected]
Your rights
You have the right at any time to:
• Ask for a copy of the information about you held by us in our records
• Require us to correct any in accuracies in your information
• Make a request to us to delete what personal data of yours we hold
• Ask us not to process your personal data for marketing purposes.
We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected] If you wish to unsubscribe from any of our emails, please let us know.
Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The General Data Protection Regulations gives you the right to access information held about you. Your right of access can be exercised in accordance with the regulations.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be reflected in this policy and, where appropriate, notified to you by e-mail.
Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to:
The Deputy Bursar (Compliance)
Sedbergh School
Malim Lodge, Loftus Hill
Sedbergh
LA10 5RY
Email: [email protected]
If you have any concerns about the use of your information, we would ask that you contact us to resolve the matter in the first instance at [email protected]
If you think your data rights have been breach, you also have the right to complain to the Information Commissioner’s Office (ICO). You can contact the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
Our main privacy notices are available here:
https://www.sedberghschool.org/senior/information/privacy-policy
Sedbergh School is a company limited by guarantee registered in England No: 3946280
Registered Office: Malim Lodge, Sedbergh LA10 5RY 01539 620303
Registered Charity No: 1080672