Privacy Policy
At Big Hearted Living, we process personal data for 5 main reasons:
1. To provide adults and children with training programmes, courses and events;
2. As employers;
3. In the performance of a supplier contract;
4. When you purchase an item from our online shop;
5. If we have permission from the user, or where otherwise allowed by law, to market to them.
Who we share information with:
We will not share your information with any third parties UNLESS
1. it is necessary in the performance of our contractual obligation to you;
2. they are a third party data processor acting on our instruction.
Children and their parents/guardians
When you make an enquiry about our Sessions for children, we will complete an initial enquiry form. This information will include contact data for the parent or guardian of the prospective attendee and may include, but is not limited to, some data about the child’s education history. Once you enter into a relationship with Big Hearted Living, we may process some special category data such as health and medical data to ensure the safety of Children while they are in our care.
We will also process your bank details for the payment of our fees, if paying by direct debit. Where card payments are taken we do not retain any of that data.
Big Hearted Living is the data controller for the information you provide for the duration of our contractual relationship unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us.
Lawful Basis
Our lawful basis for processing your personal information is set down in the GDPR under Article 6(1):
(b) Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
Children
For the data we process in relation to the students we coach, it is in our legitimate interests to process that data (under Article 6(1)(f)). Where a parent or guardian has signed our mutually agreed contract it will be necessary to process their data alongside this (as above). We will not send marketing information to children but to their parent or guardian.
In relation to the special category data we hold about our Attendees and Children, we will process this in accordance with Article 9(2)(c) of the GDPR, i.e. that processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
With whom we share your data
From time to time we may share your data (including your special category data) with third parties who assist us in our duties to you. When we do this we ensure we have a contract in place with those parties to protect your data.
Where we store your personal data
The majority of your data is stored electronically on a centralised computer system managed by a data processor. Everyone has access to their own (and/or their child’s) data and can update it at any time. Certain members of staff have access to this system to enable them to act on your behalf.
Data is kept in hard copy with our Session Leaders when they are working with you or your Child. Where there is special category data then access to that data is shared only where it is necessary and (when at a Venue) kept in a secure place where access is restricted.
Employees and Freelancers
Big Hearted Living is the data controller for the information you provide during the employment and application process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us.
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
Advertised positions
We ask you to send us a current CV and a covering letter which will include your personal details including name and contact details. As well as your previous experience, education, referees and any other information relevant to the role you have applied for.
Speculative Applications
We will sometimes receive speculative applications. When these are received, if there is no suitable vacancy at that time we will retain the data in our system for 24 months.
Shortlisting
We will shortlist applications for interview. They will receive all information supplied at that time.
You may be required to provide:
· Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
· Proof of your qualifications – you may be asked to attend our office with original documents, we will take copies.
· We may contact your referees, using the details you provide in your application, directly to obtain references.
· If we make a final offer, we may also ask you for the following:
· Bank details – to process salary payments.
· We will always require an enhanced DBS check.
· We may ask you to complete a questionnaire about your health. This is to establish your fitness to work as well as for your well-being whilst on our premises.
· Emergency contact details – so we know who to contact in case you have an emergency at work.
· Information for your inclusion in our pension scheme. We use a data processor for this scheme.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of 24 months. If you say yes, we would proactively contact you should any further suitable vacancies arise.
Freelancers
The nature of Big Hearted Living’s business means that we may employ freelance trainers on a contract basis. We process the employment information supplied for the performance of that contract in the same secure way as we do for our permanent staff. We retain their data for the duration of that contract and for such period thereafter as is necessary in line with our retention policy. We will always require that our educators are DBS checked and that information is kept in a separate place that only senior members of staff can access.
Big Hearted Living is the data controller for the information you provide for the duration of our contractual relationship unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us.
We will process this data because the processing is necessary for the performance of our mutually agreed contract.
In relation to the special category data we hold about you we will process this in accordance with Article 9(2)(b) of the GDPR, i.e. that the processing is necessary for the purposes of carrying out the obligations and exercising specific rights of Big Hearted Living or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
Where employment information is kept
HR data is kept in electronic and hard copy files securely and accessed only by members of the senior management team.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your DBS check, fitness to work, records of any security checks and references.
Online Shopping
When you set up an account with Big Hearted Living you are able to access our online shop. We will not capture any additional personal data unless you purchase something. If you make a purchase you can pay by PayPal or credit card and we will not retain any of your payment data.
Use of data processors
Data processors are third parties who necessarily provide elements of our internal practices. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Use of other third parties
Some third parties with whom we share your data are data controllers in their own right in which case they will have their own retention periods.
We have contracts with all third parties to ensure the security of your data that we share with them.
Visitors to our website
We use a third party processor to administer our website.
We use Google Analytics which collects IP addresses from visitors interacting with our site but these do not identify the visitor.
Check your cookies
You can see which cookies are active in your browser’s settings. For help, visit your browser’s documentation:
· Chrome
· Firefox
Others
There may be other individuals with whom we do business and for whom we hold personal data, such as those who work for supplier companies. We process this information in accordance with our contracts with those organisations.
Updating your personal information
You can update your personal information at any time, and change your marketing preferences. To do this please email us at hello@bemoregiraffe.com.
Marketing
If you have chosen to receive our marketing messages and news about our services we will process sufficient contact data to enable us to send you those. We use a third party processor and you can unsubscribe at any time.
Your Rights
Under current UK data protection legislation, you have rights as an individual which you can exercise in relation to the information we hold about you.
Individuals have the right to see the personal data held by Big Hearted Living (a subject access request). Once the person requesting the information has been identified the request will be carried out within one calendar month in a clear and easy to read way. There are numerous and various exemptions to this right and each request will be dealt with on a case by case basis.
Individuals have the right to have their data rectified where it is incorrect or out of date. Where a request for data rectification is made it will be dealt with in a similar way to a subject access request (SAR), i.e. within a strict time frame.
You also have the rights to (i) erasure and (ii) restriction and you can request that we remove your data or restrict the processing of it.
Your right to object to the processing of your data is an absolute right which will be dealt with immediately unless there are compelling grounds for us to continue the processing where appropriate.
You can read more about these rights here: https://ico.org.uk/your-data-matters/
This privacy policy was updated on 24th March 2022. We reserve the right to update and alter this policy.