Privacy Notice

REVISED: 25 May 2021

Welcome! Keystone Knowledge Ltd. (“Keystone Knowledge”, “we”, “us”, “our”) is a company that provides schools (maintained and single academy) and multi academy trusts with operational consultancy and services. We take our responsibility to protect your personal information very seriously and the privacy of every user matters to us. If you have any questions around our policies, please don’t hesitate to ask using the contact details below.

Contact details

Keystone Knowledge Ltd, is a private limited company registered in England and Wales under company number 12092122 and with ICO registered number ZA713985

Data Protection Compliance Manager:

Email address:          data@keystoneknowledge.com

Postal address:         Keystone Knowledge Limited, Nightingale Way, Etwall, DE65 6RT

Telephone number:   +44 7591672393

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Some words with capital letters are defined in the glossary at the end of this notice or within the text but  others, as listed here have the meanings given in the EULA and you are referred to the EULA for such meanings: Customer Data, User, Third Party Accounts, Order Form, Services

1.    Who and what does this Privacy Notice apply to?

Customers: By accessing our Services you are accepting the terms of this Privacy Notice. Additionally, use of our website indicates acceptance of our terms and conditions.

Suppliers: If you supply products and services to us this Privacy Notice also applies to any of your personal data that we collect and process.

Website users: By accessing our Website https://www.keystoneknowledge.com you are accepting the terms of this Privacy Notice.

SchoolMark respects your personal data and is committed to protecting all personal data collected.

“Personal data” means any information relating to an identified or identifiable natural person.

This Privacy Notice applies to all personal data:

• we may collect and process in the course of providing our Services;
• provided when you visit the Website;
• provided when you contact us via email by completing the online enquiry form or ‘contact us’ links on the Website;
• you provide when you use any instant messaging function we may make available on the Website;
• which you as a Customer provide to us when you register on our website (“Site”) for the managing and reporting of user data captured on behalf of our Customers; and
• which you as a supplier provide to us when we work with you for the supply of your products or services to our business outside of web-based services (together the “personal information”).

Our Website is not geared towards individuals under the age of thirteen (13) and is not meant to be used or accessed by individuals under the age of 13. We do not knowingly collect personally identifiable information from children under 13 through our Website.

What does this Privacy Notice Cover?

This Privacy Notice provides information about:

• how we use the personal information collected;
• what personal information we collect;
• how we ensure that privacy of the personal information is maintained; and
• your Legal Rights relating to the personal information.

What is outside the scope of this Privacy Notice?

This Privacy Notice applies to our processing of personal data where we are a data controller.

This Privacy Notice does not apply to (i) our processing of Customer Data which you may input when using the Services. In this action we are the data controller; or (ii) your use of Third Party Accounts when accessing Services or (iii) other links to third party websites or services which we may direct you to from time to time but for which linking to them is at your discretion. Because we do not control or manage these third- party companies, we are not responsible for the privacy practices and policies of those companies. We encourage you to check the applicable third party’s privacy policies and terms of use before submitting any information through those links and websites.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated May 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The personal information we collect about you

You may supply Keystone Knowledge with different kinds of personal information which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes addresses, email address and telephone numbers.
• Financial Data includes bank account details
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, geographical location, length of visit on a website, page views and navigation paths, as well as information about the timing, frequency and pattern of your use.
• Profile Data includes all username and passwords to the Site.
• Usage Data includes information obtained through login data, keyword searches, how you use our Site, products and services.
• Marketing Data includes any preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal information: Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is the personal information collected?

We use different methods to collect personal information from you including:

• Direct interactions. You will give us Identity, Contact and Financial Data by uploading documents, populating information on the Website and Site or by corresponding with us by post, phone, email or otherwise request marketing to be sent to you.
• Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. However, this data is restricted to the minimum necessary for the site to work and the data collected is not analysed nor your information used to monetize your interactions with us.

4. How we use the personal Information

We will only use the personal information when the law allows us to. Most commonly, we will use the personal information in the following circumstances:

• to streamline networks and improve efficiency for our Customers;
• to ensure that content that appears on our Site is as up to date as possible and that it is presented in a manner which allows the Site to be accessible;
• to carry out our obligations arising from the performance of the contract we entered into when you registered to become a Customer;
• to carry out our obligations arising from the performance of the contract we entered into with you as a supplier; and
• where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to direct marketing at any time by contacting us

Purposes for which we will use the personal information

We have set out below, in a table format, a description of all the ways we may use the personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please see the glossary for further information about each lawful basis of use.

Note that we may process the personal information on more than one lawful ground depending on the specific purpose for which we are using the personal information. Please contact us if you need details about the specific legal ground we are relying on to process the personal information where more than one ground has been set out in the table below.

Cookies

Please see the cookie notices provided to you when you use the Website. These give you information about the cookies that we use, why we use them and how you can choose which can be used. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Change of purpose

We will only use the personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use the personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process the personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We share your personal information with the parties set out below. The lawful basis for processing each is based on performance of a contract with you or necessary for our legitimate interests (for running our business, archiving data, provision of administration and IT services, network security, to prevent fraud and data breach.

Other External Third Parties

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of the personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use the personal information for their own purposes and only permit them to process personal information for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA)

7. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal information for?

We will only retain personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, operational, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

No fee usually required

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out in section 9. There will not be a charge to access the personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Your legal rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. Please see section 8 for details on how you request or action these legal rights.

You have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables any incomplete or inaccurate data we hold to be corrected, though we may need to verify the accuracy of the new data provided.

Request erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal information where you have successfully exercised the right to object to processing (see below), where we may have processed the personal information unlawfully or where we are required to erase personal information to comply with local law. Note, however, that we may not always be able to comply with requests for the erasure as a result of specific legal reasons which will be notified to you, if applicable, at the time of the request.

Object to processing of personal information where we are relying on a legitimate interest (or those of a third party) and there is something about the particular situation which makes you object to processing on the ground it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing such Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process the Personal Information which override your rights and freedoms.

Request restriction of processing of the personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you need us to establish the personal information’s accuracy; (b) where our use of the personal information is unlawful but you do not want us to erase it; (c) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of the personal information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal Information to you or to a third party. This does not apply to the personal information we collect and process for you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

GLOSSARY

Lawful Basis:

Legitimate Interest means the interest of Keystone Knowledge in conducting and managing its business to enable it to give you the best service and the best and most secure experience. For example we have an interest in making sure our marketing is relevant for you, so we may send you marketing that is tailored to your interests in our business and the Site. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing personal information where it is necessary for the performance of the contract with the Customer or supplier.

Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.