Leafhopper Enterprise Support Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who uses SOLAR and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and data subjects’ rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via SOLAR which may include personal data [and special categories of data] relating to pupils and teachers. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).
2. Information About Us
- 2.1 SOLAR is owned and operated by Leafhopper Enterprise Support Ltd, a limited company registered in England under company number 5490621, whose registered address is 56 Boughton Lane, Maidstone, ME15 9QS and whose main trading address is 56 Boughton Lane, Maidstone, ME15 9QS (“We/Us/Our”).
- 2.2 Our VAT number is 150 8332 31.
- 2.3 Our Data Protection Officer is Peter Ananicz, and can be contacted by email at email@example.com, by telephone on 0800 019 0661, or by post at 56 Boughton Lane Maidstone, ME15 9QS.
3. What Does This Policy Cover?
4. Data subjects’ Rights
- 4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- 4.1.1 the right to be informed about Our collection and use of personal data;
- 4.1.2 the right of access to the personal data We hold about you (see section 12);
- 4.1.3 the right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
- 4.1.4 the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
- 4.1.5 the right to restrict (i.e. prevent) the processing of your personal data;
- 4.1.6 the right to data portability (obtaining a copy of your personal data to reuse with another service or organisation);
- 4.1.7 the right to object to Us using your personal data for particular purposes; and
- 4.1.8 rights with respect to automated decision making and profiling.
- 4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. You also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- 4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of SOLAR, We may collect some or all of the following personal and non-personal data:
- 5.1 pupil name;
- 5.2 pupil date of birth;
- 5.3 pupil gender;
- 5.4 pupil year group;
- 5.5 pupil key stage;
- 5.6 pupil class;
- 5.7 pupil ethnicity;
- 5.8 pupil UPN;
- 5.9 if a pupil is looked after;
- 5.10 if a pupil has free school meals;
- 5.11 any additional fields added by the school using custom fields;
- 5.12 teacher name; and
- 5.13 teacher email address.
6. How Do We Use Personal Data?
- 6.1 All personal data is processed and stored securely.
- 6.2 We do not keep personal data for any longer than is necessary considering the reason(s) for which it was first collected. Data will therefore be retained for 2 months after a contract with SOLAR is cancelled/revoked to allow for customer requests for copies of their data.
- 6.3 We will comply with Our obligations and safeguard data subject’s rights under the GDPR at all times. For more details on security see section 7 below.
- 6.4 Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because the data subject has consented to Our use of personal data, because it is in Our legitimate interests or it is necessary to comply with a legal obligation. Specifically, We may use personal data for the following purposes:
- 6.4.1 supplying SOLAR to you in accordance with our contract (please note that We require personal data in order to enter into a contract with you);
- 6.4.2 personalising and tailoring SOLAR for you in accordance with our contract;
- 6.4.3 replying to emails from you which is necessary in the performance of our contract or for the taking of steps at your request with a view to entering into a contract;
- 6.4.4 supplying you with emails and newsletters that you have opted into (you may unsubscribe or opt-out at any time by emailing us using the details provided in section 13 or using the unsubscribe option on newsletters).
- 6.5 We do not use personal data for marketing purposes. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect data subjects’ rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended).
- 6.6 Data subjects have the right to withdraw consent to Us using their personal data at any time, and to request that We delete it but this may mean that you may not be able to access certain features of SOLAR.
7. How and Where Do We Store Personal Data?
- 7.1 We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or where applicable, for as long as We have permission to keep it.
- 7.2 Personal data will only be stored in the UK.
- 7.3 Steps We take to secure and protect personal data include:
- 7.3.1 daily backups;
- 7.3.2 use secure access to our physical servers; and
- 7.3.3 all stored passwords are encrypted and cannot be read by any Leafhopper staff.
8. Do We Share Personal Data?
- 8.1 We will not share any personal data with any third parties for any purposes.
- 8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
- 9.2 In the event that any personal data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have personal data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
- 10.1 In addition to data subjects’ rights under the GDPR set out in section 4, when you submit personal data via SOLAR, you may be given options to restrict Our use of such personal data. In particular, We aim to give you strong controls on Our use of personal data for information purposes e.g. newsletters (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails/Newsletters or by contacting us using the details provided in section 13.
- 10.2 We do not use any data on SOLAR for marketing purposes.
11. Your Right to Withhold Information
You may access certain areas of SOLAR without providing any data at all. However, to use all features and functions available on SOLAR you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 13.
13. Contacting Us
email at email@example.com, by telephone on 0800 019 0661, or by post at 56, Boughton Lane, Maidstone, Kent, ME159QS. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
- 14.2 It is important that the personal data we hold is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This policy has been approved and authorised by :-
Name: Peter Ananicz
Date: 4th August 2020
Date for Review: 3rd August 2021