Introduction

Your information is very important to us and we look after your information carefully in line with the latest data protection and privacy laws.

Below, we have set out more detail on those laws and on what information we collect about you and how we use that information.

Please do read this policy and our Cookie Policy so you know what we are doing with your information.

We may update this privacy policy and our cookie policy from time to time and will post any changes on our website at www.smbp.org.uk so it’s a good idea to come back and read through them again, from time to time. This privacy policy was last updated on 21 May 2018.

The rights of individuals are protected by the Data Protection Act 1998 (the “DPA”) up to and including 24 May 2018, and from 25 May 2018 by the General Data Protection Regulation (Regulation EU) 2016/679) (the “GDPR”). These impose restrictions and controls over the way that SMBP collects and uses personal data.

What is personal data?

“Personal data” is information relating to a living individual where the individual can be identified from the data, or the individual can be identified from that data combined with other information held by us (or likely to come into our possession).

This might include a name, address, telephone number, email address or photograph. It could also include identifiers such as an identification number.

What are special categories of personal data?

“special categories of personal data” is data which includes more sensitive/personal information about an individual.

This might include information relating to an individual’s racial or ethnic origin, physical or mental health, religion, or criminal offences.

What services does this policy cover?

Our services include (without limitation) virtual coaching services, provision of information about the Social Mobility Business Partnership, provision of the Social Mobility Business Partnership work experience and skills week, provision of audio visual content, text, photographs, advertising and other services which we may offer at or via the website at www.smbp.org.uk  (the “Services”). This policy covers all of the Services and any reference to “you” or “your”, means you as user of our Services. This policy applies to the collection and use of your information by us and parties that we authorise (such as our suppliers and sub-contractors).

What information does SMBP collect?

What information we collect about you depends which of our Services you are using. The information that we may collect includes:

  • your name, address, postcode, email address, date of birth, gender and/or ethnicity;
  • information about your use of our Services including details of the content you viewed on our website, how long you stayed and on which pages, and your navigation around the website;
  • your written conversations with virtual coaches via the virtual coaching facility on our website, for safeguarding and monitoring purposes; and
  • other data to ensure and check compliance with the Terms of Use and/or otherwise as required by law.

The DPA and the GDPR give you the right to access information held about you. Your right of access can be exercised in accordance with those acts. Any access request is free of charge.

When and how do SMBP collect information?

We (or our authorised third parties) may collect information about you:

  • when you register for Services, including (without limitation) when you complete a written form stating that you would like further information about our Services, when you register on our website and / or when you request support from a virtual coach via our website;
  • when you contact us with an enquiry or other feedback;
  • in monitoring your use of the Services including (without limitation) communications sent by you via the Services;
  • when we are checking compliance with the Terms of Use and/or otherwise as required by law;
  • through the use of “cookies” and/or other devices. For full details, see our cookie policy and the section entitled “Cookies and similar devices” below;
  • when you disclose your personal information to us or otherwise through the Services at any other point;
  • from third party suppliers who have confirmed to us that they are authorised to pass your information to us in accordance with your legal rights.

We may also combine information that you provide on one Service with information collected from other Services and/or with information that is publicly available or that we receive from other reputable sources. All information will be stored and used in accordance with this privacy policy.

How will SMBP use my information?

Your information may be used by us and our authorised third parties to:

  • assist in and administer the provision of Services to you;
  • accommodate you on a work experience and skills week;
  • monitor, develop and improve the Services and/or your experience;
  • process and deal with any complaints or enquiries made by or about you;
  • investigate any suspected breach of the Terms of Use or the breach of other terms and conditions otherwise relating to you;
  • contact you with further information about our Services (if you have requested to receive this).

What are SMBP’s legal grounds for processing my information?

We will only process your personal information where we have legal grounds to do so. Generally, we will only process it on the following grounds:

  • you have given consent for the processing. When we rely on consent to process your personal information, you will always have the right to withdraw this consent either by clicking the ‘unsubscribe’ button if there is one or by emailing us on info@smbp.org.uk;
  • the processing is necessary for the purposes of the legitimate interests pursued by SMBP or a third party. An example of this is when we prepare for your attendance on the work insight and skills weeks; we may use the information you have given us to accommodate any needs you may have and the participating businesses may use your information to issue office visitor passes, produce name badges or set the day up to accommodate any needs you may have.

Will I be sent marketing messages?

We will only send you information about our Services if you indicate that you wish to receive such messages (e.g. by “opting-in” by ticking a tick box). Where we have your consent or are otherwise permitted to do so, we may send you information by email, telephone (including SMS and MMS), mail or other methods of communication.

To stop receiving marketing communications from us, you can use the ‘unsubscribe’, ‘stop’ or similar facility contained in any such communication or you can email us at info@smbp.org.uk, stating that you do not wish to receive further communications from us.

We do not pass or sell your personal information to third parties for any other purpose than as set out in this privacy policy. Unless you have given us your consent to pass your details to a third party, any marketing referred to in this section is conducted by us on our own behalf or on behalf of third parties to whom we have not given any access to your data.

How long will SMBP keep my information for?

Unless you request that we delete your information:

  • In relation to the work experience and skills week; we will keep your information for only as long as we need it to accommodate you on the work experience and skills week;
  • For the virtual coaching service; if you have registered for virtual coaching, we will keep your information until you no longer require access to the service. We will retain a copy of your conversations via the service for a period of 6 years, for the purposes of safeguarding; and
  • If you have consented to SMBP sending you direct marketing communications, we will retain your information for a period of 5 years, to cover the period we expect that you may be in higher education, after which we will delete it.

Does SMBP share my information?

We may pass information about you to other parties as follows:

  • to third parties authorised by us and acting on our behalf such as our employees, contractors, suppliers and/or agents including without limitation our customer care teams to administer the Services provided to you by us now or in the future;
  • to our participating businesses for the purposes of running our work insight and skills training weeks;
  • where we have your consent to do so, for marketing communications (see section on “Marketing Communications” above);
  • as part of general, statistical information about the Services’ user base, traffic volumes and related matters. These details will not include information personally identifying you;
  • as part of general, statistical information about the ethnic diversity and living situation of the students that access our Services. These details will not include information personally identifying you; and
  • to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms of Use and or the breach of other terms and conditions or otherwise where required by law or where we suspect harm or potential harm to others. We will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders. We shall not be obliged to give you any further notice of this.

Please note this policy does not cover companies, services or applications that we do not own or control, or people that we do not employ or manage, including (without limitation) third party websites or applications/widgets (e.g. from “social media” platforms such as Facebook or Twitter) which we link to or offer via our Services.

Cookies and similar devices

In addition, in common with many other online services, we and our authorised third parties may use “cookies” and/or other tools to store and sometimes track information about you. For more details about what cookies are, the cookies that we use and how to disable them, please see our cookie policy.

Are my details safe?

We endeavour to take all reasonable steps to protect your personal information. We are careful to choose storage facilities that we have had assessed and we are confident are suitably secure to store your information.

Please always think carefully before disclosing information to other users or otherwise making your information publicly available. It is important that you are aware that any information you disclose to another user may then be disclosed by that user. We have no responsibility or control over the contents of communications made between users of our Services.

What are my rights?

Any personal information you supply will be treated in accordance with the DPA or GDPR, as applicable.

We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:

  • the right to request a copy of the personal information we hold about you. To do this, please contact us at info@smbp.org.uk, making clear that you are requesting a copy of your personal data and including full details of what you require. You may also be required to submit a proof of your identity;
  • the right to object to your personal information being used for direct marketing. We will give you the ability to object to this, and where required we will ensure we obtain your consent before undertaking marketing;
  • the right to object to your personal data being processed where the legal basis for the processing is our own legitimate interests as a business (see the ‘legal basis for processing’ section above). We will comply with such a request unless there is a lawful reason for not doing so, such as, when we need to continue to process your data to defend a legal claim;
  • the right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal data;
  • the right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal data is essential;
  • the right of erasure. You may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations;
  • the right to data portability. In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible; and
  • the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

How can I change my details?

Where you register your details for certain Services and open a user account with us, you can then use that to access and log on to use those Services. You may change or update some of your details at any time via your account. If you are not registered for these Services but wish to update your details then please contact us (see “Contact SMBP” section below). You should please make sure that you update your details as soon as possible with all relevant changes.

Data Controller

Social Mobility Business Partnership, a charity incorporated in England, registered number 1174309 and with its registered office at ITV Broadcasting Limited, Upper Ground, London, SE1 9LT.

Contact SMBP

You can email us with any questions, queries or complaints at info@smbp.org.uk.

Our Funding Partners