This document sets out the obligations of Busythings Limited ("Busy Things") with regard to data protection and the rights of people with whom it works in respect of their personal data under applicable data protection legislation (including the Data Protection Act 1998 and when applicable the General Data Protection Regulations (the "GDPR")).
Busy Things is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We can be contacted by telephone on +44 (0)1332 364963, by email at firstname.lastname@example.org or by post at the registered office address 3 St. James Court, Derby, DE1 1BT. The data protection officer ("DPO") is Duncan Witham whose service address is 3 St. James Court, Derby, DE1 1BT and can be contacted on +44 (0)1332 364963.
This policy applies between any user of this website and Busy Things the owner and provider of this website. This Policy sets out procedures that Busy Things follows and where appropriate you must follow when dealing with personal data. The procedures set out herein are followed by Busy Things, its employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things.
Busy Things views the correct and lawful handling of personal data as key to its success and dealings with third parties. Busy Things ensures that it handles all personal data correctly and lawfully.
This policy applies only to the actions of Busy Things and users with respect to the Busy Things website. It does not extend to any websites that can be accessed from this website including, but not limited to, any links that may be provided to social media websites.
The Data Protection Principles
This Policy aims to ensure compliance with current UK data protection legislation and the GDPR. That legislation sets out principles with which any party handling personal data must comply. All personal data:
must be processed fairly, lawfully and in a transparent manner (and shall not be processed unless certain conditions are met);
must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
must be accurate and, where appropriate, kept up-to-date;
must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
must be processed in accordance with the rights of data subjects;
must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Rights of Data Subjects
Data subjects have the following rights:
the right to be informed that their personal data is being processed;
the right to access any of their personal data held by Busy Things within one month of making a request;
the right to rectification if their personal data is inaccurate or incomplete within one month of making a request (this can be extended by two months where the request for rectification is complex);
the right to erasure which enables data subjects to request the deletion or removal of personal data where there is no compelling reason for its continued processing;
the right to restrict processing personal data;
the right to data portability allows data subjects to obtain and reuse their personal data for their own purposes across different services;
the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics; and
rights in relation to automated decision making and profiling.
The rights listed in this clause 3 can be exercised by writing to Busythings Limited, 3 St. James Court, Derby, DE1 1BT or by email to email@example.com
Personal data is defined as information relating to an identifiable person who can be directly or indirectly identified in particular by reference to that data.
The GDPR also defines "sensitive personal data" as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
Busy Things only holds personal data which is directly relevant to its dealings with a given data subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by Busy Things from time to time:
Date of birth (parent/home subscriptions only);
Job title (school subscriptions only);
School Name (school subscriptions only);
School Address (school subscriptions only);
Personal or home address (parent/home subscriptions only); and
IP address (automatically collected);
web browser type and version (automatically collected);
operating system (automatically collected);
your activity on this website, including the referring site and the pages you visit
Processing Personal Data
Any and all personal data collected by Busy Things (including that detailed in Section 4 of this Policy) is collected in order to ensure that Busy Things can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by Busy Things in meeting any and all relevant obligations imposed by law.
Personal data may be required by us from time to time in order to provide users with the best possible service and experience when using the website. Specifically, personal data may be used by us for the following reasons:
internal record keeping;
improvement of our products/services;
transmission by email of promotional materials that may be of interest to you;
contact for market research purposes which may be done using email, telephone, or mail. Such information may be used to customise or update the website.
Personal data may be disclosed within Busy Things. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within Busy Things that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
Busy Things shall ensure that:
all personal data collected and processed for and on behalf of Busy Things by any party is collected and processed fairly and lawfully;
data subjects are made fully aware of the reasons for the collection of personal data and are given details of the purpose for which the data will be used;
personal data is only collected to the extent that is necessary to fulfil the stated purpose(s);
all personal data is accurate at the time of collection and kept accurate and up-to-date while it is being held and/or processed;
no personal data is held for any longer than necessary in light of the stated purpose(s);
all personal data is held in a safe and secure manner, taking all appropriate technical and organisational measures to protect the data;
all personal data is transferred using secure means, electronically or otherwise;
no personal data is transferred outside of the UK or EEA (as appropriate) without first ensuring that appropriate safeguards are in place in the destination country or territory; and
all data subjects can exercise their rights set out above in Section 3 and more fully in applicable legislation (including the GDPR).
Data Protection Procedures
Busy Things shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things comply with the following when processing and / or transmitting personal data:
all emails containing personal data must be encrypted;
personal data may be transmitted over secure networks only - transmission over unsecured networks is not permitted in any circumstances;
personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient. Using an intermediary is not permitted;
all hardcopies of personal data should be stored securely in a locked box, drawer, cabinet or similar;
all electronic copies of personal data should be stored securely using passwords and suitable data encryption, where possible on a drive or server which cannot be accessed via the internet; and
all passwords used to protect personal data should be changed regularly and should not use words or phrases which can be easily guessed or otherwise compromised.
Any personal data you submit will be retained by Busy Things for a period of up to three years after a subscription or free trial has expired.
Unless we are obliged or permitted by law to do so, and subject to Section 10, your personal data will not be disclosed to third parties.
All saved files are deleted 18 months after file creation.
All London Grid for Learning and Trustnet user account details will be deleted if the account is inactive for the current academic year plus 1 year.
Busy Things shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
the Data Protection Officer (the "DPO") within Busy Things shall be appointed with the specific responsibility of overseeing data protection and ensuring compliance with the GDPR;
all employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things are made fully aware of both their individual responsibilities and Busy Things' responsibilities under the GDPR and shall be furnished with a copy of this Policy;
all employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things handling personal data will be appropriately trained to do so;
all employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things handling personal data will be appropriately supervised;
methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
the Performance of those employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things handling personal data shall be regularly evaluated and reviewed;
all employees, contractors, agents, consultants, partners or other parties working on behalf of Busy Things handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence under the GDPR;
all contractors, agents, consultants, partners or other parties working on behalf of Busy Things handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of Busy Things arising out of this Policy and the GDPR;
where any contractor, agent, consultant, partner or other party working on behalf of Busy Things handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless Busy Things against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
Access by Data Subjects
A data subject may make a subject access request ("SAR") at any time to see the information which Busy Things holds about them:
SARs must be made in writing, and if applicable, accompanied by the correct fee;
Busy Things shall provide a copy of the information free of charge, unless the request is manifestly unfounded or excessive, particularly if it is repetitive, in which case Busy Things shall charge a reasonable fee based on the administrative cost of providing the information.
Upon receipt of an SAR Busy Things shall have a maximum period of 30 days within which to respond. The following information will be provided to the data subject:
whether or not Busy Things holds any personal data on the data subject;
a description of any personal data held on the data subject;
details of what that personal data is used for;
details of any third-party organisations that personal data is passed to; and
details of any technical terminology or codes
Notification to the Information Commissioner's Office
As a data controller, Busy Things is required to notify the Information Commissioner's Office that it is processing personal data. Busy Things is registered in the register of data controllers.
Data controllers must renew their notification with the Information Commissioner's Office on an annual basis. Failure to notify constitutes a criminal offence.
Any changes to the register must be notified to the Information Commissioner's Office within 28 days of taking place.
The DPO shall be responsible for notifying and updating the Information Commissioner's Office.
Third Party Websites and Services
Busy Things may, from time to time, employ the services of other parties for dealing with payment processing and delivery of purchased items. The providers of such services do have access to certain personal data provided by users of the website.
Any personal data used by such parties is used only to the extent required by them to perform the service that Busy Things requests. Any use for other purposes is strictly prohibited. Furthermore, any personal data that is processed by third parties shall be processed within the terms of this policy and in accordance with the GDPR.
Links to Other Websites
Changes of Business Ownership and Control
Busy Things may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Busy Things. Personal data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this policy, be permitted to use the personal data for the purposes for which it was originally supplied to us.
Your Right to Withhold Information
You may access certain areas of the website without providing any personal data at all. However, to use all features and functions available on the website you may be required to submit certain personal data.
Implementation of Policy
This Policy shall be deemed effective as of 12th March 2018 No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
Last updated 12th March 2018
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Busy Things reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.