privacy notice

Mark Brown Programmes Ltd takes your data privacy seriously. We are education and behaviour management consultants focussed on delivering specially developed programmes. In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for and committed to complying with Data Protection Laws including the UK General Data Protection Regulations (UK GDPR) and Data Protection Act 2018 and any subsequent laws.

In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.

Our Contact Details:

Mark Brown Programmes Ltd
Email: Mark@mbprogrammes.co.uk
Tel: 07514406980

If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact using the above details.

Who’s Personal data do we collect and process?

We process information about appointing parties such as education establishment, programme candidates, suppliers, professional advisors or individuals making an enquiry about our services.

What personal data do we collect and process?

In the course of working with you, we can collect the following types of data:

• General contact details such as, Name, Address, email address, Telephone number

• Details of your organisations activities and your role

• General Correspondence and discussions between you and us in relation to our services

• Details of the Services provided to you

• Contact details of nominated contacts at organisations or programme candidates

• Financial Details including government grant entitlement and details for payment

• Information obtained through our use of cookies (please see our Cookie Policy)

• Marketing preferences

Special Categories of Personal Data that we collect:

We can also collect the following special categories of data in the course of our correspondence or consultations:

• Medical Conditions and History, ethnicity, Sexual orientation, behavioural information, criminal convictions

Where we collect such special category information we do so with the consent of the individual and under significant public interests in delivering our service. Such information is not retained and is destroyed immediately at the end of any consultancy.

How we collect your information

In most cases we collect your data directly from you. We collect data and process it when you:

• Complete an online ‘contact us’ form

• Provide information during a meeting or consultation

• Speak to us on the telephone to discuss or use our services

• Email or write to us to enquire about or use our services or provide feedback

We also receive your data indirectly from the following sources:

• Social Media Sites including LinkedIn

• Schools, Local Authorities such as social work and prison services where you have been nominated as a programme candidate.

• Public sources – demographic data, Market Research

• Credit Agencies and publicly available company data

• Or if you are an individual who has been nominated as a candidate, schools, social work departments or prison services may provide your contact details to discuss our programmes or arrange contact.

Please Remember: Where you provide any of this information relating to or on behalf of another individual such as a nominated programme candidate, you must remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.

Why do we collect your information?

Where we collect and process personal data, we are required to identify both the purpose and our legal basis for doing so. There are 6 possible legal bases which are:

Consent – where we have your consent for processing your personal data for one or more specific purpose

Contract – where the processing is necessary for the performance of a contract or potential contract with you.

Legal Obligation – The processing is necessary for our compliance with a legal obligation

Vital Interests – Where our processing is necessary in order to protect the vital interests of the data subject or another natural person

Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Legitimate Interests - Where the processing is necessary for the purposes of our legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms.

Our various purposes and legal basis for the information we collect, are detailed below:

Where we rely on your consent you have the right to withdraw this consent at any time by contacting us.

Legitimate Interests - Where the processing of personal data is based on our Legitimate Interests, it is to deliver and improve on our service and security and maintain accurate records. It is also in an aim to prevent fraud or illegal activity in favour of the wellbeing of our customers, shareholders and employees.

Direct Marketing
We may send you details of similar services or programmes to those you have enquired about or contracted with us previously. You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.

We will never share or sell your information to any other party for marketing purposes.

Who we share your information with?

From time to time and in the general course of our business, we may share your personal information with some of the following:

• Our Accountant or Payment Service Providers

• Regulators and Governing bodies, Lawyers

• School contacts, social workers or prison services where they have identified candidates

• Auditors, Professional Consultants

• Software and Cloud storage providers

• Telecoms providers and call software solutions (for call recording)

• Fraud detection Agencies and Credit Reference Agencies

• Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime

• Selected Third Parties in connection with any future sale, transfer or disposal of our business

International data transfers
Although we don’t transfer your information outside of the UK, with today’s modern technology including Cloud Storage and software, some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. Where this is the case, we make sure that additional safeguards are in place such as ensuring that those countries have a decision of adequacy under the UK GDPR or have included standard contract clauses in their terms to support the protection of your data.

Automated decision-making or Profiling
We do not process personal data for automated decision making or profiling

How Long do we keep personal data for?
We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy. We maintain and review a detailed retention policy which documents how long we will hold different types of data. The time period will depend on the purpose for which we collected the information and is never on an indefinite basis. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).

The following details the criteria used to establish the retention period set out within our
policy.

Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of
7 years after the end of any contract with a view to maintaining and improving the
performance of our products, keeping our systems secure, and maintaining appropriate
business and financial records. Most of our retention periods are determined on the basis of
this general rule. We do not however retain special category data.

Where required by Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may
also be necessary to store personal data regarding pending or future legal disputes. Personal
data contained in contracts, notifications and business letters may be subject to statutory
storage obligations depending on national law.

Your Rights as a data subject
As a data subject, you have rights in relation to your personal data. These are:

Access – You have the right to request details of personal information held or processed and
to copies of this data. We do not usually charge for this service.

Rectification – You have the right to request that any information be corrected that you
believe is inaccurate or to complete any information that you believe is incomplete.

Erasure – You have the right to request that we erase your personal information with some
exceptions.

Restrict Processing – You have the right to request that we restrict the processing of your
personal data under certain circumstances

Object to Processing – You have the right to object to our processing of your data, under
certain conditions.

Data Portability – In some circumstances, you have the right to request that we transfer the
data that we have collected to another organisation or directly to you.

You also always have the Right to Withdraw Consent where you have previously provided
this.

To exercise any of these rights, or if you have a complaint please contact us.

If after contacting us you remain unhappy with the outcome, you also have the right to complain to the Supervisory Authority. Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:

Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Online: https://ico.org.uk/global/contact-us/
Helpline: 0303 123 1113

Contractual Obligations and Consequences
In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, employment and legal obligations) or can also result from contractual provisions. This means that sometimes we cannot complete our agreed service without that information and so if you aren’t able to provide it or ask that we delete it, there is a possible consequence that our contract would need to be cancelled.

Cookies & similar technologies
When you visit our Website, we use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalised advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you visit or use the Website. For full information on our use of cookies and how to manage them, please see our Cookie Policy.

To learn more about how to manage your browser cookie settings in general please see www.allaboutcookies.org.

Remember: When clicking on external links via our website, or finding us via social media platforms, you are visiting or redirected to the domain of those websites. We have no control over the privacy settings on these websites and the cookies they set, so please bear in mind that you should set your preferences in line with their own policies and cookie controls separately.

Data security
We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.

We store customer records in cloud-based services and data centres which have controlled and restricted access. We operate records management and Information security policies which detail physical security, cloud storage security monitoring, access control and password security measures. We also maintain and use anti-virus and malware software
and firewalls.

Changes to our Privacy Notice
Mark Brown Programmes Ltd keep our Privacy Notice under regular review. This Privacy Notice was last updated on 30th March 2021.