Privacy notice

How we use your information

This privacy notice tells you what to expect when Develop collects personal information. It applies to information we collect about:

• visitors to our websites
• complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry
• people who use our services, eg who subscribe to our newsletter or request a publication from us
• people who sign up for our programs
• job applicants and our current and former employees.

Visitors to our websites

When someone visits www.developebp.co.uk and we want to collect personally identifiable information through our website, we will be:

• up front about it
• make it clear when we collect personal information
• explain what we intend to do with it

We use Google Analytics to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.

Use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

Cookie	Name	Purpose
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Read Google’s overview of privacy and safeguarding data
Contact  Form Driven by Google Forms	_ga _gat	This cookie is essential for the submission of the Contact us form to Develop. The form uses Google forms. Read Google’s overview of privacy and safeguarding data
YouTube cookies		We may embed videos from YouTube using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. Read more at YouTube’s embedding videos information page.
Google web fonts	fonts.googleapis.com	Web based fonts that can be deployed in websites from Google. See https://developers.google.com/fonts/

 

Security and performance

We use a third party service to help maintain the security and performance of our website.(1&1) In completing this service they DO NOT process the IP addresses of visitors to the website.

WordPress

We use a third party service, WordPress.com, to publish for example our blog, and some of our networking microsites. These sites are hosted at WordPress.com, which is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see Automattic’s privacy notice.

People who call us

When you call Develop, our call handling system may collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.

People who email us

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy.  Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

People who make a complaint to us

When we receive a complaint from a person we may need to make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

Marketing Develop’s services

Develop offers various services to engage targeted areas of the public, those still in education or people that require employability support as highlighted by government policy, local demand or SEMLEP priorities. We use a third party to deal with some publication and marketing requests, but they are only allowed to use the information to send out specific publications and marketing activities.

We have to hold the details of the people who have requested service information in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

People who register on our programs

When a person registers on one of our programs we will hold details on file to be able to deliver that program service. The details will be kept on a ‘needs to know’ basis and retained for a period set out by the program key stakeholder, for example retention for some ESF funded projects is 15 years. Once this period has expired the data is secure shredded and un-recoverable.

Personal details vary depending upon each program and may include sensitive data, ethnicity data and any specific learning or support needs.

Where we act as a Data Controller, we keep the data secure and only share it, through a data sharing agreement, with an appointed data processor who processes the data on our behalf. In this case we retain overall responsibility for the security and fair processing of the data.

Where details are sent to us from a local authority or other public body, we enter into a data sharing agreement with that entity and act as a data processor.

Contracted providers reporting a breach

Where Develop engage the services of another entity to deliver a program in partnership, any breach as defined in the GDPR, is reportable to Develop. Develop will collect details of the breach that may include details of individuals. These details will be used to ascertain if the rights of individuals concerned have been damaged and the appropriate remedial steps will be taken, including obligated reporting to the ICO and to the individuals concerned.

Job applicants, current and former employees

When individuals apply to work at Develop, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure Barring Service, or for the Prevention of Crime and Fraud, we will not do so without informing them beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We may retain anonymised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.

Once a person has taken up employment with the Develop, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Develop has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Complaints or queries

Develop tries to meet the requirements of the GDPR when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

Access to personal information

Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998, and the GDPR. If we do hold information about you we will:

• give you a description of it
• tell you why we are holding it
• tell you who it could be disclosed to
• let you have a copy of the information in an easy to read form.

To make a request for any personal information we may hold you need to put the request in writing addressing it to our Data protection Officer at the address provided below or by filling in this form.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by contacting our Data Protection Officer.

Disclosure of personal information

In most circumstances we will not disclose personal data without your consent. However, in some circumstances there will be a need to disclose information without consent. Typically this will be for the prevention of crime, fraud, terrorist activity and safeguarding young and vulnerable people.

We take into consideration if the information could be sourced from other places first before we disclose, and if needed will only respond to a court order.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice

We keep our policies updated at least once per year or on significant legal changes.

How to contact us

If you want to request information, submit a written subject action request or suggest improvements to our privacy arrangements you can email dp@developedp.co.uk or write to the;

Data Protection Officer, Develop, 15 Doolittle mill, Ampthill, Beds. MK452ND

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