Privacy & Cookies Policy

Definitions:

You are referred to as ‘the Customer’ or ‘Client’.

The term “DCL Early Years services Ltd” or “us/we/our” refers to the Director of DCL Early Years services Ltd.

1. Introduction and Purpose of Policy:

DCL Early Years services Ltd maintains a strict policy of Client confidentiality. DCL Early Years services Ltd respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data and tell you your privacy rights and how the law protects you. This policy is GDPR compliant.

DCL Early Years services Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information then you can be assured that it will only be used in accordance with this privacy statement.

This policy should be read in conjunction with our Terms and Conditions. This policy should be read together with any other data processing notice that we may provide to you on specific occasions, for example when you sign-up for one of our services.

2. Controller:

DCL Early Years services Ltd is the controller and is responsible for your personal data. The Director is responsible for overseeing questions in relation to this privacy policy.

Contact Details:

DCL Early Years services Ltd
71-75 Shelton Street,

Covent Garden,

London,

England,

WC2H 9JQ
dcleyservices@gmail.com

Individuals have a right to make a complaint to the ICO (Information Commissioner’s Office) if they think there is a problem with the way we are handling their data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Changes to this policy and your duty to inform us of changes:

This policy version was updated on the 7th May 2020. It may be changed or amended at our absolute discretion, so you should review it from time-to-time so you are aware of any changes. Any changes will be posted on the website. It is important that the personal data that we hold about you is accurate and current. Please keep is informed if your personal data changes during your relationship with us.

4. What do we collect?

Personal data, or personal information, means any kind of information about an individual from which that person can be identified. We may collect, use, store and transfer different types of personal data about you which we have grouped together as follows:

Identity Data: includes first name, last name, your child’s name, your child’s date of birth, your child’s school year and sometimes your child’s educational background. We collect most of this information from you at the start of our service or when changes have been made.

Contact Data: includes email address, telephone numbers.

Financial Data: includes bank details and payment card details.

Transaction Data: includes details and payments to and from you.

Technical Data: includes login data and IP address.

Profile Data: includes purchases or orders made by you, your preferences, feedback and survey responses.

Usage Data: includes how you use our website, products and services.

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

5. If you fail to provide personal data

Where we need to collect specific personal data from you and you fail to provide that data when requested, we may not be able to perform our work successfully. In this case, we may have to cancel a product or service that you have with us, but we will notify you if this is the case at the time.

6. How is your personal data collected:

We use different methods to collect data from you including:

Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your browsing actions and patterns. We collect this data by using cookies and other similar technology.
Third parties:We may receive personal data from you from other parents or companies.

7. How we use your personal data:

We will only use your personal data when the law allows us to. Your personal data may be used for the following purposes:

to contact you regarding your child and service;
to improve DCL Early Years Services Ltd;
to ensure we deliver a good service to Clients, Students and tutors;
we may periodically send promotional newsletters or emails about our work, events, workshops or other information which we think you may find interesting using the email address which you have provided;
to notify you of any changes to DCL Early Years services Ltd’s service.
where we need to comply with a legal or regulatory obligation.

8. Data that is collected automatically:

To the extent that you access the Website, we will collect your Data automatically, for example:

we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

9. What is our lawful basis for processing personal data?

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 require more information.

We require our Clients to sign ‘Consent’ for the usage and storage of their personal information. This consent is asked for in the initial sign-up document sent to the client at the start of our services. Consent may also be sent via email.
When starting our services, we request Identity and Contact information in order for the successful performance of a ‘Contract/Agreement’ with you.
If you purchase something through us, we may need to process Identity, Financial and Transaction information for our ‘Legitimate Interests’ (to collect payment).
To manage our relationship with you, we may require Identity, Contact, Profile and Marketing and Communications data from you for the successful performance of a ‘Contract/Agreement’ with you. We may also use it for ‘Legitimate Interests’ (e.g. to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and website, we may need Technical data for the ‘Legitimate Interests’ for running our business
To use data analytics to improve our website, products, services, marketing and customer relationships, we may use Technical or Usage data for the ‘Legitimate Interests’ for running our business, business growth, and monitoring customer satisfaction.

10. Sharing information with third parties:

Clients: After clients have begun working with us, we may share general information with our staff in order to improve our service to you. We will keep your personal information confidential and will not pass it on to any 3rd parties unless we are required to do so by law.

Staff or applicants: The information that you provide to DCL Early Years Services Ltd forms the basis of a staff profile. This may include the following information: a photograph, your qualifications, experience, personal biography, and any testimonials. Once you have given us permission, this profile will be published on the DCL Early Years Services Ltd website. We will pass on your contact details to Clients for jobs that you have expressed an interest in. Other than sharing information with our clients we will keep your personal information confidential and will not pass it on to any 3rd parties unless we are required to do so by law.

11. What happens to your payment details?

These go direct to our payment partners. We do not receive such information except as stated above. To ensure your details are not being used without consent, our payment partners may send your personal information to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.

12. Marketing and Email tracking:

Our newsletters employ tracking so that we can monitor at an individual level whether a recipient has opened the email and what content they have clicked on. We only send our newsletter to recipients who have shown an interest in our company, subscribed via our website or who are past or current clients. Recipients are able to easily unsubscribe from the newsletter if they wish.

We would like to send you information by post, email, telephone, text message (SMS) or automated call about our services which may be of interest to you.

We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you complete our online enquiry form for the first time.

If you have consented to such receive marketing from us and our group companies you can opt out at any time.

Uses of the Information given to us

We collect information about you so that we can:

Identify you and manage any accounts you hold with us
process your application
conduct research, statistical analysis and behavioural analysis
carry out customer profiling and analyse your preferences
if you agree, let you know about other products or services that may be of interest to you—see ‘Marketing’ section below
detect and prevent fraud
customise our website and its content to your preferences
notify you of any changes to our website or to our services that may affect you;
carry out security vetting and improve our services

13. Change of Purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

14. International Transfers:

We do not transfer your personal data outside the European Economic Area (EEA)

15. Access to your data/Your legal rights:

You may request details of personal information which we hold about you under the General Data Protection Regulation (2018). If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible using our Contact page. We will try to respond to all legitimate requests within a month. You will not have to pay a fee to access your personal data.

You have the following rights in relation to our use of your personal information:

The right to access your personal information
You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
The right to rectification
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
The right to erasure
In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restriction of processing
In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information.
Right to data portability
In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing
You can ask us to stop sending you marketing messages at any time.
The right to withdraw consent
For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to process your insurance if you withdraw your consent.
The right to lodge a complaint
You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/

16. Data Security:

We are committed to ensuring that your information is secure. This information that you provide will be stored physically at your tutor’s home in a locked cupboard. It will also be shared online via our secure file hosting service. This online service can only be accessed by the Director of DCL Early Years Services Ltd.

17. How long do we keep your personal data for? How can personal data be deleted?

We will retain your personal data for as long as necessary to fulfil the purposes we collected it. To consider the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. However, should you want your personal data to be deleted, contact the Director of DCL Early Years Services Ltd and this can be arranged promptly.

18. Technology and E-Safety:

DCL Early Years Services Ltd are registered with the Information Commissioner’s Office - ICO - as a data handler.

If tutoring or teaching online, staff must make it clear to the Client how their online service is delivered, and the nature of the technology used. Videos should be switched on so that both Client and staff member can be seen during the lesson. Clients are not permitted to record lessons, if the staff member requires recorded footage of the session, permission from the client must be obtained first.

The use of technology is growing and children are exposed to technology from a very young age. We recognise the benefit of using electronic devices to support children’s learning and to help us comply with the record keeping and learning and development aspects of the Early Years Foundation Stage (EYFS, 2017).

E-safety covers all electronic devices including cameras, computers, videos and DVD recorders, mobile phones and other devices capable of taking photographs or linking to the internet. It also includes the use of social media, software, emails, chat rooms, blogs, laptops, games consoles and new technology as we are aware that internet and technology is constantly evolving.

How the internet is used:

The Early Years Foundation Stage (EYFS, 2017) requires providers to teach children about technology which is generally accepted to include learning about the internet. We aim to take a common sense approach to how long children spend using ICT and the suitability of ICT resources for various ages of children. Parents are consulted about time spent on the internet and their wishes are followed.
Staff use the internet to input learning and development information about children; share learning and development information with children’s parents; store personal data about children and their families
The Director uses the internet to complete payroll; send messages including email to parents and children; share information with families and staff.

The risks of using the internet

We are aware of the risks of allowing staff and children to go online on computers, tablets, mobile phones, watches, gaming etc and:

aim to supervise use to protect children and staff when using the internet;
share safe internet messages with parents so they can support their children’s internet use and keep them safer at home;
teach children about how to use the internet safely and monitor their use;
train staff to keep online information secure and to raise awareness of the risks of radicalisation and extremism on the internet and online bullying;
Staff including volunteers and students are only given access to children’s online data when training has been provided and a Data Sharing Agreement signed;
Staff and children are made aware of the risks of being online and know how to report any concerns.

Keeping data safe

We understand that while technology is useful for learning it can also present safety problems when misused and this policy has been written to clarify appropriate technology use by us and by parents of children who use our services and:

The broadband is secured by a password which is changed regularly;
Virus protection software is automatically updated;
Online learning journey systems are secured with a password which is changed regularly;
Passwords are used for all online systems – passwords are changed regularly and the password is stored in a password protected document on the main computer and shared via Dropbox;
Note – Dropbox is cloud storage owned by a US company and not covered by GDPR.
Laptops, tablets and other ICT equipment which contain sensitive data about children, families and staff are secure;
Tablets and laptops ‘time out’ to a password protected page when unused;
Memory sticks, when used, are encrypted and locked away.
The password to any secure documents is shared with my partner to ensure it remains secure should I be injured or fall ill.

Online communications

All internet enabled devices are monitored to ensure safe internet use. Any technology used by children has internet safety controls in place so children cannot access inappropriate sites. Every effort will be made to keep internet security updated and online usage by children will be monitored. Any uploading of personal information onto websites must be carried out in compliance with the Data Protection Act 1998 and will not be done without prior written permission from the parent involved.

The website, Facebook group - blog … does contain photos of children and staff.
Note – if photos of children or staff are used online consent (parent or staff member permission) must be sought in writing in advance and can be withdrawn at any time.
When emails are sent to parents, BCC is used to protect private email addresses;
Staff are trained to recognise the importance of ensuring all communications between staff, parents and children are professional respectful. If concerning comments are made by other staff members or parents etc on social media, staff will not respond: they will report the comment to the Direcor.
Staff are trained to understand that information about children and families will not be shared online, including on social media – this is a disciplinary offence.

If there is a concern about e-safety, we will act on the concern to comply with the requirements of the EYFS, Childcare Registers, Ofsted and the ICO.

19. Children's Personal Data:

We will collect, store, and use the following categories of personal information about Children:

Name
Date of birth
Home address
Dietary requirements
Attendance information
Emergency contact should Parents/Carers be unavailable and the emergency contact’s contact details.
Accidents and pre-existing injuries forms
Records of any reportable death, injury, disease or dangerous occurrence .
Observation, planning and assessment records of Children We may also collect, store and use the following “special categories” of more sensitive personal information:
Information about a Child’s race or ethnicity, religion, spoken language, nationality.
Information about a Child’s health, including any medical condition, health and sickness records.
Information about a Child’s accident or incident reports including reports of pre-existing injuries.
Information about a Child’s incident forms / child protection referral forms / child protection case details / reports.

We need all the categories of information in the list above primarily to allow us to perform our obligations (including our legal obligations to Children. The situations in which we will process personal information of Children are listed below.

Personal information of Children will be shared with local authorities without the consent of Parents/Carers where there is a situation where child protection is necessary.
Ofsted will be allowed access to the systems to review child protection records.
To ensure we meet the needs of the Children
To check safeguarding records
To check complaint records

20. Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.

The following kinds of cookies may be used on this website:

a) Session cookies: These are essential for our service and enable us to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. They allow you to proceed through many pages of the site quickly and easily without having to authenticate or reprocess each new area you visit. For example, a session cookie remembers your shopping cart selection so you will have the items you selected when you are ready to check out.

b) Mobile app session IDs: Similarly, these are used to authenticate you while you are using our mobile app.

c) Facebook cookies: Facebook places third party persistent cookies (up to a year) to authenticate you if you log in via Facebook. Click here for more information. If you register or log into our service via Facebook, you will be automatically logged into our service as long as you remain logged in to Facebook. If you specifically log out of our service, we place a persistent cookie to prevent the automatic login happening on future visits.

d) Referral cookies: Persistent cookies (up to 30 days) are placed to track referrals from websites affiliated with us so we can pay affiliates and assess the effectiveness of the affiliate links.

e) Google cookies: Persistent cookies (up to four years we believe) are set in connection with the following Google services on our site and these cookies may involve certain information (such as your IP address and web address of the page you’re visiting) being sent to Google:

i) Google Analytics (“GA”): We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. You can specifically opt out of GA here. See below for other opt out routes.

ii) GA Advertising Features: We may use the following GA Advertising Features: Remarketing with GA / Google Display Network Impression Reporting / GA Demographics and Interest Reporting / Integrated services that require GA to collect data via advertising cookies and anonymous identifiers. These features involve GA collecting data via Google or other advertising cookies including for display of ads which may be of interest based on your visits to this and other sites. You can specifically opt out of GA here. You can opt of GA Advertising Features at www.networkadvertising.org/choices. See below for other opt out routes.

iii) Google advertising cookies (AdSense, Doubleclick): Google uses cookies in connection with Google advertising on our website to serve ads to you based on your visits to this and other websites, to avoid showing you repeat ads and for various other purposes. You can opt out at www.networkadvertising.org/choices. See below for other opt out routes

More information and opt out: Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. Click here for information about how Google uses data from its partners’ sites or apps as well as different ways to opt out of Google cookies.

f) Gosquared cookies: Cookies are used on our site to enable Gosquared analytics services. See here for more details including opt out information.

g) Social media cookies: We may use various social media sharing and other features including: Facebook and Twitter. These features may involve the relevant companies using cookies or linking your visit with cookies previously placed by them on your computer in order for them to collect information relating to your visit to our website or your interaction with their services or otherwise. Click the links shown above for further information including how to opt out where this is possible.

h) Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This persistent cookie will remember your preference for up to 90 days.

21. Third-party sites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. This also applies to the buttons that you will see on our website for Facebook.

22. General Website Information

The use of our website is subject to the following terms of use:

The content of the pages of the website is for your general information and use only. It is subject to change without notice. Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.

This website contains material which is owned by or licensed to DCL Early Years Services Ltd. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions. All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website. Unauthorised use of this website may give to a claim for damages and/or be a criminal offence. From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s). You may not create a link to this website from another website or document without DCL Early Years Services Ltd’s prior written consent.

Contact:
If you have any questions, please contact:

The Director of DCL Early Years Services Ltd at dcleyservices@gmail.com.

Reviewed/Updated: 9th May 2020