About this policy
This policy describes how we use your personal data when you use our website (https://www.norfolksennetwork.org/), subscribe to our newsletter, or when we provide services to you or your child. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
Who we are and how you can contact us
We are Norfolk SEN Network, a registered charity whose aim is to help children and young people with special educational needs to find the right educational placement or provision to meet their needs. Where the child is aged 16 or under, we will work with their parents or guardians of the child to meet this aim. Where they are aged 16 to 25, we may deal with the young person directly. Our registered charity number 1044353 and our registered address is 2A Eastern Crescent, Norwich, NR7 0UE.
You can contact us in writing at the address given above, by emailing no***************@ho*****.uk or by using the contact form on our website. If you would like to speak to us please call us on 0330 043 0225.
What personal data we collect about you
We collect:
- personal data that you provide to us. There are several ways in which you might share your personal data with us, for example, you might make contact with us via our website, or by telephone, post, or social media, or you might provide your details to us at an event so that we can provide you with further information about our services (either because you would like us to provide you or your child with assistance, or because you would like to hear more about our work or are interested in supporting us).
The personal information that you provide to us will usually include your name, telephone number, address and email address. If we are providing our services to you, then we will need to ask you to provide some further information:
If you are a young person who we are assisting directly, then we will ask you to provide us with your name, date of birth, details of where you are currently attending school, sixth form, or college, details of your special educational needs, copies of any reports (obtained either by you, or shared with you) commenting on your special educational needs, and any correspondence between you and the school/sixth form/college and/or Local Authority relating to this.
- personal data that we receive from third parties.
If we are providing assistance to your parents or guardians on your behalf to ensure that you are placed in the best school or given appropriate assistance for your needs then we will be provided with information about you by your parents, which will include your name, date of birth, details of your current school, details of your special educational needs, copies of any reports commenting on your special educational needs, and any correspondence between your parent’s and the school and/or Local Authority relating to this.
Alongside personal data which we receive from parents and young people directly regarding their needs, we may receive further information from the child or young person’s school and from the Local Authority.
- personal data about your use of our website. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages you viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouse-overs).
What we use your personal data for
We use your personal data in the following ways:
- personal data that you provide to us is used to:
- provide you with the information and services that you request from us
- provide you with our newsletter and keep you up to date regarding our events, in accordance with your marketing preferences
- manage and administer our charity
- review and improve our service
- personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
- personal data about your use of our website is used to:
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- as part of our efforts to keep our site safe and secure
Cookies
Our website does not collect any identifiable data about you using cookies.
Consent and other legal grounds for processing personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you
- we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Where we process special category personal data (which would include details relating to your or your child’s special educational needs), we are required to have an additional ground for processing that information. The additional ground we rely on is that of ‘explicit consent’, we will therefore only collect and process this information from you where we have your explicit consent to do so.
To help you better understand the legal grounds we rely on for different types of processing, we have set out an overview of the main processing activities we carry out and the relevant legal grounds below.
| Categories of personal data used | Purpose | Legal basis | Additional legal ground for processing special category personal data |
| Name and contact details | To respond to your queries regarding our services | Legitimate interest (in growing our charity and developing new relationships). | N/A |
| Name, contact details, and your marketing preferences | To send you appropriate marketing communications in accordance with your marketing preferences | Consent and/or legitimate interests (to grow and develop our business) | N/A |
| Name, contact details, and details relating to your schooling and special educational needs (or your child’s schooling and special educational needs). | To correspond with you regarding the assistance you require and how we are able to assist. | Legitimate interest (to grow and develop our business) or contract (where you have instructed us to provide services and paid your annual fee). | Explicit consent |
| Name, contact details, and details relating to your schooling and special educational needs (or your child’s schooling and special educational needs). | To work with you regarding the steps to be taken to help with getting the needs of you/your child met. | Contract | Explicit consent |
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.
Your rights to know what personal data we hold and to control how we use it
You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the Who we are and how you can contact us section.
You also have rights to:
- prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
- have inaccurate personal data corrected, blocked or erased
- object to decisions being made about you by automated means or to your personal data being used for profiling purposes
- object to our using your personal data in ways that are likely to cause you damage or distress
- restrict our use of your personal data
- require that we delete your personal data
- require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file
You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
Automated decision making and profiling
We do not make use of automated decision making or profiling.
You are entitled to ask that we do not make automated decisions about you or use your personal data for profiling purposes. Please refer to the section on Your rights to know what personal data we hold and to control how we use it for details on how to exercise your rights.
When we will share your personal data with others
We share your data with the following people in the day to day running our business:
- the Local Authority
- The Special Educational Needs and Disability Tribunal.
- Your child’s school
- We may also share your personal information with third parties on a one-off basis, for example, if:
- we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
- 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 website terms of use www.norfolksennetwork.org and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- ensuring that our staff receive regular data security awareness training
- only storing your personal data on our secure servers
- ensuring that paper records are stored in locked filing cabinets on our office premises
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
- enforcing a strict policy on the use of mobile devices and out of office working
- using reCAPTCHA technology on our website
Unfortunately, sending 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 personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if.
- you register as a Member of Norfolk SEN Network.
- we provide support to you and you ask us to add you to our mailing list.
The marketing communications we send are contained within a bi – monthly newsletter which we send either by post or by email, depending on the preference you have indicated.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not post), or you may ask us not to send you any marketing communications at all.
You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.
We never share your personal data with third parties for marketing purposes.
When we will send your personal data to other countries
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
How long we keep your personal data
We only keep your personal data for as long as we actually need it. In practice this means that:
- if you have signed up to receive our newsletter, we will retain your name and email address or postal address (depending on how you have said you would like to receive the newsletter) until you unsubscribe.
- if we provide services to you, then we will retain a complete copy of your file for either 7 years from the date we last hear from you, or until the child who we assisted turns 19 years old (whichever is later).
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website (https://www.norfolksennetwork.org/) or you can contact us (see Who we are and how you can contact us) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number at the end of the policy and the date on which that version of the policy came into force.
This is policy version 1 which came into effect on 10th July 2019.
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