Introduction
Welcome to The PSHE Association's privacy policy.
We respect your privacy and are committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data when you visit our website (regardlessof where you visit it from), or interact and communicate with us, and tell you about your privacy
rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy
policy.
1.

Important information and who we are
Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal
data through your use of this website, including any data you may provide through this websitewhen you sign up to a newsletter, create an account, use our services, contact us through thewebsite or by any other means or in any other scenario where you may provide us with data.
This website is not intended for children and we do not knowingly collect data relating tochildren.
It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended tooverride them.
Controller
The PSHE Association is the controller and responsible for your personal data (collectively
referred to as "PSHE Association", "we", "us" or "our" in this privacy policy). We are a registeredcharity (with charity number 1127056) as well as a company limited by guarantee (withcompany number 6551975).
We have appointed a data privacy manager who is responsible for overseeing questions inrelation to this privacy policy. If you have any questions about this privacy policy, including any
requests to exercise your legal rights, please contact the data privacy manager using the details
set out below.
Contact details

If you have any questions about this privacy policy or our privacy practices, please contact ourdata privacy manager in the following ways:
Email address: info@pshe-association.org.uk
Postal address: PSHE Association, Coram Campus, 41 Brunswick Square, London, WC1N 1AZ.
Telephone number: 020 4538 1509
You have the right to make a complaint at any time to the Information Commissioner's Office(ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however,appreciate the chance to deal with your concerns before you approach the ICO so please contact
us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 10 December
2021. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data aboutyou. We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the privacy policy of every
website you visit.
2.

The data we collect about you

Personal data, or personal information, means any information about an individual from whichthat person can be identified. It does not include data where the identity has been removed(anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which wehave grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar
identifier, marital status, employer/ school names, job title/ role, date of birth andgender.

Contact Data includes billing address, delivery address, email address and telephone
numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other detailsof products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser typeand version, time zone setting and location, browser plug-in types and versions,operating system and platform, and other technology on the devices you use to accessthis website.

Profile Data includes your username and password, key stage level, experienceteaching PSHE, purchases or orders made by you, your interests, preferences, feedback
and survey responses.



Usage Data includes information about how you use our website, products and services
and membership category.

Marketing and Communications Data includes your preferences in receiving marketingfrom us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing a specificwebsite feature. However, if we combine or connect Aggregated Data with your personal dataso that it can directly or indirectly identify you, we treat the combined data as personal data
which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health, and genetic andbiometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have withyou, and you fail to provide that data when requested, we may not be able to perform thecontract we have or are trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service you have with us but wewill notify you if this is the case at the time.
3.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data byfilling in forms or by corresponding with us by post, phone, email or otherwise. This
includes personal data you provide when you:

apply for membership or to receive products/ services;

create an account on our website;

subscribe to our service or publications;request marketing to be sent to you;enter a competition, promotion or survey; orgive us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we willautomatically collect Technical Data about your equipment, browsing actions andpatterns. We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other websites
employing our cookies. We work with Hotjar and Google Analytics who may also,
through cookies, track your experience with our website including where you camefrom, what you did whilst using our website and where you went after our webpage.



Third parties or publicly available sources. We may receive personal data about you
from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google based outside the UK;
help desk providers such as Zendesk based inside the EEA;
online form platforms such as Paperform outside of the EEA;
advertising networks; andsearch information providers.



Contact, Financial and Transaction Data from providers of technical, payment anddelivery services such as Stripe based outside the UK.



Identity and Contact Data from publicly available sources such as Companies Houseand the Electoral Register based inside the UK.

4.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have enteredinto with you.



Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although
we will get your consent before sending third party direct marketing communications to you
via email or text message. You have the right to withdraw consent to marketing at any time bycontacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use yourpersonal data, and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your personal data where morethan one ground has been set out in the table below.
Purpose/Activity

Type of data

Lawfulbasis
forincluding basis ofinterest

processing
legitimate

To register you as a new (a) Identity
customer/ member(b) Contact

Performance of a contract with you

To process and deliver your (a) Identity
order including:(b) Contact(a) Manage payments, fees(c) Financial
and charges(a) Performance of a contract withyou(b) Necessary for our legitimate
interests (to recover debts due to us)(b) Collect and recover money (d) Transaction
owed to us(e) Usage Data(f) Marketing andCommunications
To manage our relationship (a) Identitywith you which will include:(b) Contact(a) Notifying you aboutchanges to our terms or (c) Profile
privacy policy(a) Performance of a contract withyou(b) Necessary to comply with a legal
obligation(c) Necessary for our legitimate
interests (to keep our records

(b) Asking you to leave a (d) Marketing and updated and to study how customers
review or take a survey
Communications
use our products/services)
To enable you to partake in a (a) Identity
prize draw, competition or(b) Contact
complete a survey(c) Profile(d) Usage(a) Performance of a contract withyou(b) Necessary for our legitimate
interests (to study how customers
use our products/services, todevelop them and grow our business)(e) Marketing andCommunications
To administer and protect our (a) Identity
business and this website(including
troubleshooting, (b) Contact
data analysis, testing, system
maintenance,
support, (c) Technicalreporting and hosting of data)(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, toprevent fraud and in the context ofa business reorganisation or group
restructuring exercise)(b) Necessary to comply with a legal
obligation

To deliver relevant website (a) Identity
content and advertisements
to you and measure or (b) Contact
understand the effectivenessof the marketing we serve to (c) Profile
you(d) Usage

Necessaryfor
ourlegitimate
interests (to study how customers
use our products/services, todevelop them, to grow our businessand to inform our marketingstrategy)(e) Marketing andCommunications(f) Technical
To use data analytics to (a) Technicalimproveourwebsite,(b) Usage
products/services,marketing,customer
relationships and experiences

Necessaryfor
ourlegitimate
interests (to define types ofcustomers for our products andservices, to keep our website
updated and relevant, to develop
our business and to inform ourmarketing strategy)

To make suggestions
recommendations to

Necessaryinterestsand (a) Identityyou(b) Contact

for
(to

our
legitimate
developourabout goods or services that (c) Technicalmay be of interest to you(d) Usage

products/services
business)

and

grow

our

(e) Profile(f) Marketing andCommunications
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising. We have established the following personal data control
mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what
we think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us
or purchased membership, goods or services from us and you have not opted out of receivingthat marketing.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of thiswebsite may become inaccessible or not function properly.


A cookie is a small file of letters and numbers that we store on your browser or the hard
drive of your computer if you agree. Cookies contain information that is transferred to yourcomputer's hard drive.



We use the following cookies:



Strictly necessary cookies. These are cookies that are required for the operation of our
website. They include, for example, cookies that enable you to log into secure areas of our
website, use a shopping cart or make use of e-billing services.



Analytical or performance cookies. These allow us to recognise and count the number ofvisitors and to see how visitors move around our website when they are using it. This helps
us to improve the way our website works, for example, by ensuring that users are finding
what they are looking for easily.



Functionality cookies. These are used to recognise you when you return to our website. This
enables us to personalise our content for you, greet you by name and remember yourpreferences (for example, your choice of language or region).



Targeting cookies. These cookies record your visit to our website, the pages you have visitedand the links you have followed. We will use this information to make our website more
relevant to your interests.

Found here: https://knowledge.hubspot.com/reports/what-cookies-does-hubspot-set-in-avisitor-s-browserYou can block cookies by activating the setting on your browser that allows
you to refuse the setting of all or some cookies. However, if you use your browser settingsto block all cookies (including essential cookies) you may not be able to access all or partsof our website.



Except for essential cookies, all cookies will expire after one year. Essential cookies will
expire once you stop using our website.
Change of purpose

We will only use your personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.
5.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in thetable above.
Internal Third Parties as set out below.

External Third Parties as set out below.

Specific third parties as set out below.



Third parties to whom we may choose to sell, transfer or merge parts of our businessor our assets. Alternatively, we may seek to acquire other businesses or merge withthem. If a change happens to our business, then the new owners may use your personal
data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.

6.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal
data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the following safeguards is implemented:


We will only transfer your personal data to countries that have been deemed to provide
an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved foruse in the UK which give personal data the same protection it has in the UK.

Where, from time to time, there are alternative appropriate safeguards in place andas approved by law.

Please contact us if you want further information on the specific mechanism used by us whentransferring your personal data out of the UK.
7.

Data security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.
8.

Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements. We may retain your personal data for a longer period in
the event of a complaint or if we reasonably believe there is a prospect of litigation in respect
to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount,nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data andwhether we can achieve those purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we will anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may use thisinformation indefinitely without further notice to you.
9.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to yourpersonal data. Please click on the links below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you tohave any incomplete or inaccurate data we hold about you corrected, though we mayneed to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data where you havesuccessfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not always beable to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In somecases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us tosuspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.



Where our use of the data is unlawful but you do not want us to erase it.



Where you need us to hold the data even if we no longer require it as you need it toestablish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we haveoverriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we used theinformation to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processing carriedout before you withdraw your consent. If you withdraw your consent, we may not beable to provide certain products or services to you. We will advise you if this is thecase at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we could refuse to comply with your request in thesecircumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity andensure your right to access your personal data (or to exercise any of your other rights). This isa security measure to ensure that personal data is not disclosed to any person who has no rightto receive it. We may also contact you to ask you for further information in relation to yourrequest to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us
longer than a month if your request is particularly complex or you have made a number ofrequests. In this case, we will notify you and keep you updated.
10.

Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our businessto enable us to give you the best service/product and the best and most secure experience. We
make sure we consider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimate interests. We do 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). You can obtainfurther information about how we assess our legitimate interests against any potential impact
on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performanceof a contract to which you are a party or to take steps at your request before entering into sucha contract.
Comply with a legal obligation means processing your personal data where it is necessary forcompliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties

Service providers acting as processors based within the UK who provide IT and systemadministration services.



Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers who provide consultancy, banking, legal, insurance andaccounting services.



HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities
in certain circumstances.



Marketing automation platforms, acting as a processor, such as The Rocket Science
Group LLC t/a MailChimp based in the US who provide email marketing automation
services.

CRM platforms, acting as a processor, such as Hubspot who provide CRM services.



Our online help desk service provider, acting as processors, such as Zendesk, who arebased in the US.

Online video conference service providers, such as Zoom based in the US.

Merchant services, acting as a processor, such as Stripe, who provide secure payment
processing services.