Data and Privacy Policy

Data and Privacy Policy 2019

1. Who are we?

The Full English (Education) Ltd maintains and develops the Poetry By Heart website and runs the Poetry By Heart school poetry recitation in association with The Poetry Archive, The English Association and The Poetry Society. Founded by Andrew Motion and Julie Blake in 2012, Poetry by Heart is an inspiring competition for pupils in schools and colleges to learn and to recite poems by heart. Their performances are the outward and audible manifestation of an inwardly-understood and enjoyed poem. In the process, pupils foster deep personal connections with the poems chosen and bring poetry alive for their friends, families and communities.

We encourage pupils, teachers, school librarians and other interested audiences to begin a journey of personal discovery of the pleasures of poetry by offering collections of poems free-of-charge at our website www.poetrybyheart.org.uk/. Each poem in our collection is presented with resources to support independent learning and to encourage exploration of poems and poets across time.

The Full English (Education) Ltd is a registered company. Our Company registration number is 08484860. Our registered office address is 2nd Floor, 53 High Street, Keynsham, Bristol, BS31 1DS. Our postal address is 13-14 Orchard Street, Bristol, BS1 5EH.

We are committed to keeping the personal details of our school competition organisers and supporters safe. This Notice explains how and why we use your personal data, to ensure that you remain informed and in control of your information.

2. Our Commitment to your Privacy

The Full English (Education) Ltd holds and processes data, including personal data, so that we can deliver the Poetry By Heart competition. We aim to grow and sustain the visitors to our website, and through engagement with our audiences, build a valuable community and vital networks.

We collect, hold and process personal data to build and maintain relationships; to secure the resources we need to deliver the competition; to provide a strong evidence base for our work; to keep our staff, volunteers, supporters and competition participants safe and to meet our legal and contractual obligations.

We are committed to gathering and processing personal data with full regard for the General Data Protection Regulations (GDPR), the Privacy and Electronic Communications Regulations (PECR) and to the principles of personal choice and control. We always collect and process data on lawful grounds to meet the genuine needs of our organisation, but we do so with the highest regard for an individual’s rights and freedoms.

We will never sell personal data to third parties, and will never share your information unless it is absolutely necessary to meet our organisational needs and legal obligations. We apply strict controls with data sharing and processing agreements in place.

3. Key terms

We use the following key definitions, which are used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)

  • ‘Data subject’: this is you, one of our valued school competition organisers and supporters. As the data subject, we respect your right to control your data.
  • ‘Data controller’: this is us, the Full English (Education) Ltd. With your permission, we determine why and how your personal data is used (as outlined in this document).
  • ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. All data processing is done by our own in-house staff. Sometimes we use third party software, such as MailChimp, to send our newsletters. The third parties we work with at no point ‘own’ your data, so you will never hear from them unless you have separately signed up to their newsletters or other communications, and they will always delete your data from their systems when they have completed the task in hand. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.

4. What kind of personal data do we collect? How do we collect it?

Basic information

a) For e-Newsletter subscribers, we will usually collect your name, email address and information about your interest in Poetry By Heart. For our occasional surveys we collect a wider range of information directly from you and only with your permission. We collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where you have given permission for such information to be shared).

b) For school competition organisers entering pupils for the national Poetry By Heart competition, we will usually collect your name, job title, email address (preferably your school email address), school address and school telephone number. We collect this data from you directly via our website competition registration system.

c) For pupils participating in the Poetry By Heart competition, we will only collect information about you if you win your school key stage competition and if you wish to progress in the national competition. We will usually collect only the minimum information necessary to judge your competition entry. This information is your name, key stage, school and links to your poems. We will collect this information from your school competition organiser. Your school competition organiser will make sure you and your parents give permission for them to do this. We store this data during the competition and then we delete it.

Getting to know you better

We also collect information about you that helps us to get to know you better. This may include:

  • information about your poetry interests, which you tell us through our occasional surveys
  • records of Poetry By Heart events you’ve attended, Poetry By Heart competitions or activities that you’ve been involved in

We also use ‘cookies’ on our website to collect information that helps us to give you the best experience we can when using the site and its resources.

Cookies are small text files that are placed on your computer or mobile phone when you browse websites, so the Full English (Education) Ltd does not store this information.

Our cookies help us:

  • Make our website work as you’d expect
  • Remember your settings during and between visits
  • Improve the speed/security of the site
  • Allow you to share pages with social networks like Facebook
  • Continuously improve our website for you

For more information on our Cookies Policy, please contact us.

Sensitive personal data

We do not normally collect or store sensitive personal data (such as information relating to health) about school competition organisers, supporters and competition participants. However, if a pupil is selected to compete in the Poetry By Heart national finals event we will collect information necessary for their safety and well-being and we will collect information necessary for their chaperone’s safety and well-being. The chaperone is usually the competition organiser but may sometimes be the parent or guardian. When we collect this information, we will be very clear as to why we are collecting it, and we will only do so with your specific consent and permission, or the specific consent and permission of the pupil’s parent or guardian. In this situation, we collect the data from the competition organiser or parent or guardian directly. Generally, we anonymise sensitive personal data wherever possible. We always destroy sensitive personal data after the finals competition using a certified confidential data shredding company.

4. Why do we collect your personal data?

We use your personal data to keep in touch with you. We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’. Further information about why we collect your personal data is outlined below.

a) To deliver services that you have asked for.

This may involve:

  • Sending school competition organizers and supporters our e-newsletters and information about Poetry By Heart competitions, events and activities which may be of interest
  • Processing school competition entries and communicating about the progress of pupils in the national competition rounds
  • Keeping personal and professional details up to date for school competition organisers and supporters

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

b) To send school competition organisers and supporters information about our work and ask for your opinion.

We also collect school competition organisers’ and supporters’ personal data so that we can send you information about our work that we feel will be of interest to you. This includes your e-newsletter, events, volunteering opportunities, our projects, products, newsletter requests, feedback, competitions and other activities. From time to time, we may also use your personal data to ask for your opinion about the Poetry By Heart competition.

This information is in addition to that outlined in section a) and is defined as ‘direct marketing’ by the ICO.

Your personal data also helps us to get to know you better and to develop our work in a timely and relevant way. As defined by the ICO, we use two different lawful bases for processing your data for ‘direct marketing’ purposes:

i) Legitimate interest

This is where we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests.

ii) Opt-in consent

This is where you have given us express permission to contact you by particular communication channels.

We respect your right to update the way we get in touch with you about our work at any time.

As defined by the ICO, the lawful basis for processing your data for these purposes is ‘contractual’ (where processing your competition registration) and ‘legitimate interest’ (when sending you information about our work).

6. How do we store your data?

All of the personal data we process is processed by our staff in the UK and our IT hosting and maintenance is done in accordance with guidance issued by the Information Commissioner’s Office.
We use MailChimp e-mail marketing. A copy of their policy regarding data security in terms of operational security, physical security and application security can be found here.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a clear Data Protection Policy and associated guidance which staff are required to follow when handling personal data.

We cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

We will only use and store information for as long as it required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required.

7. Your rights

We respect your right to control your data. Your rights include:

a) The right to be informed
This privacy notice outlines how we capture, store and use your data.

b) The right of access
If you wish to obtain a record of the personal data we hold about you, we will respond within one month. We may charge up to £10 for responding to a request. To make a data access request please contact us on info@thefullenglish.org.uk.

c) The right to rectification

If we have captured information about you that is inaccurate or incomplete, we will update it.

d) The right to erase

You can ask us to remove or anonymise your personal details from our records.

e) The right to restrict processing

You can ask us to stop using your personal data. If we do stop processing your personal data it may result in us being unable to continue to provide you with the services we offer.

f) The right to data portability

You can ask to obtain your personal data from us for your own purposes.

g) The right to object

You can ask to be excluded from marketing activity.

h) Rights in relation to automated decision making and profiling

We respect your right not to be subject to a decision that is based on automated processing.

For more information on your individual rights, please see the Information Commissioner’s Office.

Responsibility

Overall responsibility for this notice and the implementation of our Data Protection Policy lies with the Director.

Information Commissioner’s Office

For further assistance with questions regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk

8. Leaving our website

We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from this website to another website be aware that you may be supplying information to a third party.

9. Get in touch

Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:

Director at info@thefullenglish.org.uk

Our office hours are Monday – Friday, 9am – 5pm.