Switch The Play is a ‘data controller’. This means that we are responsible for deciding how we hold and use personal information. We are required under data protection laws to notify you of the information contained in this policy.
For the purposes of this policy:
• ‘Clients’and ‘Potential Clients’ includes natural persons who have engaged us for the potential of us providing support and advice to them. This includes Switched On members;
•‘Subscribers’ includes natural persons that have signed up to one of our newsletters or bulletins, have attended or registered to attend one of our events or follow us on social media.
This policy applies to the personal information of past, present and potential clients, and subscribers. Please note that you may fall into more than one of these categories so we may hold your personal information in a number of capacities. If you are a past or present employee, member or consultant of the firm, we will hold further personal information about you. For further details please contact firstname.lastname@example.org.
Data Protection Contact
We have appointed a Data Protection Officer (DPO) to oversee compliance with this policy. If you have any questions about this policy or how we handle personal information, please contact the DPO in writing using the details below.
Email address: email@example.com
1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
Switch The Play may obtain personal information about you, such as:
- personal contact details that allow us to contact you directly such as name, title, email addresses and telephone numbers;
- date of birth;
- gender; membership details including start and end date;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
- images in video and/or photographic from and voice recordings;
- marketing information: name, title, job title, address, telephone number, email address, company, engagement details (click-throughs, open rates, bounce rates, return to sender notifications) event attendance history, dietary preferences, payment details and marketing preferences.
- social media information: username, company details and engagement details (likes, retweets, shares, reactions, comments).an do your marketing preferences so that we know whether and how we should contact you.
In some cases, we may collect non-personal information such as the type of internet browser you are using, the type of computer operating system application software and peripherals you are using and the domain name of the website from which you linked to our website. We use your information on an aggregated basis to do such things as operate our site and improve our site for your and others benefit.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following ‘special categories’ of more sensitive personal information about you arising out of communications with us (whether in-person, via email, social media, telephone or other communication methods), your attendance at Switch The Play or third party events, in the course of providing services or support to you or for the purposes of referring you (where applicable and with your express consent) to third parties for the purposes of providing services or support to you:
- Relationship information (sensitive): special access requirements, allergies.
- Matter information (sensitive): The categories of personal information that we hold about you for the purposes of specific matters that we are providing advice and support on will vary according to the type of matter. By way of example this category may include, amongst other things: race or ethnicity, philosophical or religious beliefs, psychometric data, information about your financial circumstances, educational information, information about your health, including any medical condition, health and sickness records, medical records and health professional information, disabilities and sexual orientation.
3. WHERE WE COLLECT YOUR INFORMATION
We typically collect any personal information about ‘subscribers’ when you sign up to one of our newsletters or bulletins or when you register to attend one of our events or third party events at which a Switch The Play representative is present.
We collect personal information from clients and potential clients as part of our initial engagement process with you, and over the course of our relationship.
We collect personal information from social media either from you directly or from social media platforms when you engage with our social media accounts.
Our website site uses some unobtrusive cookies to store information on your computer. Some cookies on this site are essential, and the site won’t work as expected without them. These cookies are set when you submit a form or interact with the site by doing something that goes beyond clicking on simple links.
This website doesn’t store any information that would, on its own, allow Switch The Play to identify individual users of this site without their explicit permission. Any cookies that may be used by this website are used on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.
Switch The Play uses Google Analytics to monitor visits to its website. Google Analytics stores IP address anonymously on its servers in the US, and neither Switch The Play or Google associate your IP address with any personally identifiable information. These cookies enable Google to determine whether you are a returning visitor to the site and to track the pages that you visit during your session.
The following are Google Analytics cookies:
The following are WordPress cookies:
5. HOW WE USE YOUR INFORMATION
We will only use your personal information where the law allows us to. The law says that we must identify a lawful basis for each use of personal data. We rely on a number of lawful bases, including:
1. Where we have obtained freely given, specific, informed and unambiguous consent from you to use your personal information in certain ways.
2. Where we need to perform a contract that we have entered into.
3. Where we need to comply with a legal obligation.
4. Where it is necessary for us to use personal information to pursue our legitimate interests (or those of a third party) and we believe that using personal information in that way is not overridden by the interests or fundamental rights of the person to whom the information relates.
If you fail to provide personal information
For some of your personal information, you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a member or we may not be able to properly perform our contract with you. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example, we may no longer be able to provide certain member benefits to you.
Change of Purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
6. DIRECT MARKETING
Email or post marketing: from time to time, we may contact you by email or post with information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by emailing us at firstname.lastname@example.org. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.
7. DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not sell your information to third parties.
We may share your information with third parties including associates and third party service providers for the purposes of providing services and/or support to you or us.
Third-party service providers require access to your personal data in the course of providing their services to us. We engage third parties to provide the following services: one-to-one mentoring, mental health support and services, psychometric profiling, recruitment services, public relations and marketing, IT support, document management systems, event hosting services, event delivery services, email marketing management systems, press releases and news articles or blogs, and survey and polling services.
All third parties are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow third parties to use your personal data for their own purposes. We only permit them to access your personal data for specific purposes and in accordance with our instructions.
We do not disclose personal information to anyone else except as set out above.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal accounting, or reporting requirements. The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you.
Where you have chosen to unsubscribe from marketing communications, we will retain your contact details to ensure that you are not sent any further communications.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example, if you change your phone number or email address. You can contact us using by using the details set out in the “Contacting us” section below.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information;
- the right to request that we transfer elements of your data either to you or another service provider;
- the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example, the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.
If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
10. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice, we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
11. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please email email@example.com.
If you are not satisfied that we have addressed your concerns adequately, you have the right to lodge a complaint with the ICO. Their contact details are below:
Information Commissioner’s Office
Tel: 0303 123 1113
Version dated 10th May 2018