|Publish date:||March 2021|
|Next review date:||March 2022|
|Policy owner:||Samad Miah (Data Protection Officer)|
We at BelievePerform are controllers of the personal data that we collect about you. As controllers of your personal data, we are responsible for how your data is processed. The word ‘process’ covers the collection, use, storage, sharing and erasure of that data. Believe Perform Ltd is an educational resource company that provides online resources to schools, teachers and individual students. We provide our services primarily via the believeperform.com platform.
We are committed to complying with current data protection legislation such as the General Data Protection Regulation (‘’GDPR’’) and the Data Protection Act 2018 (‘’DPA 2018’’) in our processing of your personal data.
Our privacy vision.
The vision of believeperform.com is to “make content accessible”. Believe Perform Ltd will use various ways to achieve our mission and to support our objectives: we believe that people who share our values would love to know how to support us. We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience.
2. Personal Data
Personal data is any information that relates to a certain individual (‘’Data Subject’’). This data can include basic personal identifiers such as name and contact details. It can also include more sensitive pieces of information including but not limited to a person’s race, ethnic origin or physical or mental health condition.
3. What information do we collect and why?
How do we collect your personal information?
Personal data is inputted directly into our website by the user, for a club or school the personal data is uploaded to the database by a school or club administrator or Head of Department within a particular school.
The following personal data about its users is collected:
- Forename and surname (compulsory)
- Email address (compulsory)
BelievePerform Ltd offers to support all school-based colleagues in this pursuit.
We are committed to protecting your personal data and we will only process this data if we have a legitimate business reason to do so or unless we have a lawful basis for doing so. There are various legal bases on which we rely to collect and process your data. These include but are not limited to:
Lawful basis for processing
Sometimes you may give us your consent to process your information, for example you give us consent to write to you regarding offers that may be of interest to you.
At times there will be a contractual reason why we process your information, this includes processing your renewal fee. Without this we would not be able to continue to provide our services to you.
We can rely on legitimate interest when processing is of a clear benefit to you or the business, there is a limited impact on your privacy and when we process your information in a way that you would expect.
We rely on legitimate interest for the majority of our processing, to enable us to do this we carry out due diligence (We may need to conduct investigations on supporters, potential customers, and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption) to ensure that we can adhere to this lawful basis.
So, what does this mean? When you provide your personal details to us, we use your information for our legitimate business interests to carry out our work of innovating and challenging the dominant classroom model in practice in the world today. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights. Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying, or improving our services, identifying usage trends, and determining the effectiveness of our campaigns and fundraising.
The following are some examples of when and why we would use this approach in our work helping woods and trees:
Direct Marketing: We will send postal marketing. We will also make sure our postal marketing is relevant for you, tailored to your interests.
Ordering online: In order for us to process an order, payment has to be taken and contact information collected, such as name, delivery address and telephone number, provided. The seller would also need to record the transaction.
Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
Personalisation: Where the processing enables us to enhance, modify, personalise, or otherwise improve our services/communications for the benefit of our supporters.
Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling, and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Why do we collect your personal data?
Believe Perform collect your personal data for two main purposes these include:
- To enable learners and teachers to effectively utilise believeperform.com.
- To provide information on new services to adults via our newsletters and marketing correspondence.
When do we collect personal data?
Believe Perform Ltd collects data at three times:
- On user registration to believeperform.com
- When a teacher updates user information on believeperform.com via the dashboard of either a School Administrator or Head of Department.
- When an adult positively opts into our marketing list by selecting this option when completing a registration process, completing a contact form or if they choose to amend their marketing preferences.
Believe Perform Ltd collects the following personal data about its users:
|Personal data||Reason for processing|
|Full name including title||
We collect basic information which allows us to recognise you, this allows us to manage your account and provide a high level of customer service.
|Email address||When creating an account with us it is compulsory that you provide us with an email address as you will use this information to log in and manage your account.
|Payment information||We may store some financial information about you. If you choose to purchase a subscription from us then we will store your card information to process the annual renewal.
|Information on website visits||We collect basic information that indicates usage for us to better provide services.
What third party extensions does believeperform.com use to process data?
|Paypal||Website payment instructions for those users paying by bank card.||Believeperform.com does not have access to users’ bank details.|
|Stripe||Website payment software which receives automated and manual payment.||Forename, surname, email address and postal address of bill payer.|
4. Data relating to Children
As children are able to use our platform, at times their personal information may be added to our database by a system administrator, teacher, or guardian. This information will usually be limited to names and email addresses. Children have the same rights as adults when it comes to their personal data.
5. How do we store your personal data?
Believe Perform Ltd do not hold physical copies of personal data. There may be exceptions to this rule which are assessed on a case-by-case basis, such as requests from a school or club administrators
Believe Perform Ltd guarantee to never:
- share any personal data with any third parties.
- sell personal data to any third parties.
- send marketing emails to its users unless they have positively opted in.
- communicate directly with a school aged student unless there is the presence of another adult.
- For example, Believe Perform Ltd will always ensure that when communicating with a student user there is always another member of the team or teacher/guardian of the student included.
Believe Perform Ltd guarantees to always maintain high levels of security relating to users’ personal data. Any processing of an individual’s personal data will be executed as per our Information Security Policy.
Believe Perform Ltd store personal data solely in the database of believeperform.com which is physically housed on two OVH SP-64 servers in London UK. The server uses TLS 1.2+ to serve content to users.
We retain personal information as long as is necessary or as long as it is needed to comply with our legal obligations. Where data is not needed for legal or statutory purposes we will remove this information from our database. See the section on how to contact us if you wish to request for your information to be removed.
7. Your rights to manage your personal data
You have rights when it comes to the processing of your personal information, the GDPR provides you with the below rights:
- We will always keep our data as accurate as possible but if you notice any inaccuracies then please contact us and we will do our best to get these rectified as soon as possible.
● Subject Access Request
- You are entitled to see the personal data that we store about you, this is called a Subject Access Request and you can request this at any time, this is free of charge and we will have 1 calendar month in most instances to respond and provide you with the requested information.
● Removing your data
- If we no longer need to store your personal information then we will remove it from our database, but you can request for your personal data to be removed with immediate effect at any time by contacting us. If we do not need to store this data for any legal or statutory reasons then we will process your removal request within 1 month.
● Restricting processing
- You can restrict or limit the processing that we do and you can request that we store your data but do not process it.
● Transferring data
- In some circumstances you can ask us to transfer your personal data to another organisation.
● Objection to processing
- In some circumstances you can object to certain types of processing such as marketing.
● Withdrawing consent
- If you provide us with your consent to market to you or contact you regarding offers and promotions, you are entitled to withdraw your consent at any time.
● Complaints about how we manage your data
- Please see the contact us section about how to contact us regarding complaints. You are also entitled to complain to the ICO details can be found at ico.org.uk
8. Changes to this policy
9. How to contact us
Data Protection Officer.
If you have any questions regarding this policy or any concerns about the way that your personal data is managed, then you can write to the Data Protection Officer using the below details.
DPO for Believe Perform is Samad Miah.
Samad is also a business Director who is responsible for all policies, procedures and training related to data protection.
Samad Miah’s details are as follows:
Name: Samad Miah
Title: Data protection officer
Address: 85 London Road, Cheltenham, GL52 6HL
Directors: Samad Miah, Adam Morris, Angela Martin-Castano