Digital Engagement and Safeguarding Policy

Inspire by Sbarduno is aware of its obligations under the General Data Protection Regulation (GDPR) and current data protection legislation, and is committed to processing your data securely and transparently. This privacy notice sets out, in line with data protection obligations, the types of data that we hold on you. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

Data controller details

The Proprietor is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Inspire by Sbarduno, M-Sparc, Menai Science Park, Gaerwen, Anglesey. LL60 6AR

Data protection principles

In relation to your personal data, we will:

• process it fairly, lawfully and in a clear, transparent way
• collect your data only for reasons that we find proper for the course of your engagement in ways that have been explained to you
• only use it in the way that we have told you about
• ensure it is correct and up to date
• keep your data for only as long as we need it
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.

Why we process your data

The law on data protection allows us to process your data for certain reasons only:
• in order to perform the contract that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• to protect your interests
• where something is done in the public interest and
• where we have obtained your consent.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. For example, we need to collect your personal data in order to:
• carry out the contract that we have entered into with you

We also collect data so that we can carry out activities which are in the legitimate interests of the proprietor. We have set these out below:
• making decisions about who to enter into a contract with
• dealing with legal claims made against us
• preventing fraud

Sharing your data

Your data will be shared with employees within the business where it is necessary for them to undertake their duties. For example, the administrator when payment is made.

We may also share your data with third parties as part of a business sale or restructure, or for other reasons to comply with a legal obligation upon us.

We do not share your data with bodies outside of the European Economic Area.

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with current data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after your engagement has ended. Retention periods can vary depending on why we need your data.

Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• the right to portability. You may transfer the data that we hold on you for your own purposes
• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• the right to regulate any automated decision-making and profiling of personal data.
You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact Inspire by Sbarduno.

Defining Roles

During the online workshop, Inspire by Sbarduno will be responsible for the following:
• presenting and delivering the virtual, hands-on one hour Science Workshop
• will not take any photos or videos during the virtual Science Workshop
• will not keep any digital record of the session
• will share the participating link (Microsoft Teams or Google Meet) via email, and not directly to any pupils
• does not need to receive any personal details of any pupils who participate in the session.

During the online workshop, the school will be responsible for the following:

• contacting parents / guardians for permission to participate in the online Science Workshop, with an opportunity to ask questions and interact with Inspire by Sbarduno, using the two-way camera. If a parent(s) / guardian(s) does not give permission, the pupil (s) should be able to participate but not in view of the camera, or the school should choose not to turn on the camera
• not sharing the participating link with anyone else
• ensuring that the Science Workshop is not filmed to be shared with anyone else
• turn off the camera if you don’t wish the session to be a two-way workshop
• check with parents / guardians for any food related allergies that a child might have to any of the ingredients used in any of the Food Workshop experiments. Also have parental / guardian permission for the child to eat the produce of the experiments at the end (e.g., home-made ice cream; chocolate rocks)

The school has permission to take any photos of the session which would include images of Awen Ashworth (Proprietor), pupils participating in the experiments and also to tag @InspirebySbarduno on social media. It will be the schools’ responsibility to ensure permission to take any photos.

Making a complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

Data Protection Officer

The Company’s Data Protection Officer is Awen Ashworth. She can be contacted on awen@sbarduno.com

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