PRIVACY NOTICE

We are committed to respecting your privacy. This notice is to let you know how we promise to look after your personal information, what your privacy rights are and how the law protects you. We promise:

To keep your data safe and secure
Not to sell your data
To enable you to update/amend your marketing preferences.

Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us. This also includes the safe delivery of any activities you may attend or just managing our relationship with you.

As a group, TLG-PE Limited is a data processor. The following apply:

TLG-PE = Data Processor
Steps 2 Summit = Data Processor

We are committed to high standards of information security, privacy and transparency. When we hold or use your personal information as a data processor we will provide you with this privacy notice which sets out in detail:

what information we hold about you (such as your contact details, address, etc.)
how your personal information may be used and the reasons for these uses
details of your rights.

Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you. Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the earlier. If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us

We will only provide this privacy notice to you once, generally at the start of our relationship with you. However, if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly on our websites ("Sites") for updates atwww.tlg-pe.co.uk or www.steps2summit.co.uk

WHO WE ARE
References to we, our or us in this privacy notice are to the group of organisations below ("the Group"):

TLG-PE Limited incorporated and registered in England and Wales with company number 11843124, whose office is 4 Cross Street, Beeston, Nottingham, NG9 2NX. TLG-PE Limited is registered with the Information Commissioner's Office as a Data Controller - registration number ZA512535
Steps 2 Summit (wholly owned trading name of TLG-PE Limited as above.)

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Managing Director is our Data Protection Lead and has overall responsibility for data protection compliance across the group.

Contact details are set out in the "Contacting Us" section at the end of this privacy notice.

1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU

When you have an interaction with us you may provide us with or we may obtain personal information about you, such as information regarding your:

personal contact details that allow us to contact you directly, such as name, title, job role, address, email addresses and telephone numbers;
your organisation details, such as a school, company or other organisation type;
records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
financial details, such as any bank/payment details you provide so that we can receive payments from you or make payments to you, details of any financial transactions with you;
use of and movements through our online systems, passwords, IP addresses, user names and other IT system identifying information;
records of your attendance at any events (including training courses, workshops);
images in video and/or photographic form and voice recordings; and
your marketing preferences so that we know whether and how we should contact you.

Event Attendees

If you participate in one of our programmes in any capacity, you may also provide us with or we may obtain the following additional personal information from you:

professional details, such as qualifications, accreditations and experience;
contact details of others, such as parents/guardians, next of kin, family members, carers and emergency contacts;
specific details, such as gender, date of birth, kit size, preferences;
travel information.

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following "special categories" of more sensitive personal information regarding you if you are attending one of our meetings or training events:

information about your/their health, including any disabilities, medical conditions and history, injuries, allergies, medication, immunisations and health professional information; and
dietary and access requirements.

We may not collect all the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that:

the processing is necessary for reasons of substantial public interest, on a lawful basis;
the processing is necessary for the establishment, exercise or defence of legal claims;
the processing is necessary for the provision of health treatment; or
the processing is based on your explicit consent.

In the table below, we refer to these as the "special category reasons for processing of your personal data".

3. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information when you: create an account on our site(s) at www.tlg-pe.co.uk or www.steps2summit.co.uk, purchase any services or products we offer online; sign-up for/attend one of our programmes or events; undertake any work for us; make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

If you are a pupil at a school we also may collect personal information about you from a teacher at your school.

If you are providing us with details of colleagues, employees or other members of your school, they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the "Your rights in relation to personal information" section below.

If you are providing us with details of parents/guardians, next of kin, family members, carers or emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with them. They also have the same rights as set out in the "Your rights in relation to personal information" section below.

4. USES MADE OF THE INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our reason for being able to do this.

Purpose	Personal information used	Lawful basis for processing the information.
To administer any subscription, contract or account(s) you have with us. To manage our relationship with you and process any payments required. To be able to support you with any of our services or product enquiries made by you.	All contract, organisation and subscription details. Financial details, records or your interactions with us and your marketing preferences.	To allow us to manage your contract, subscription and/or account(s) with us.
To arrange and manage any contracts and/or subscriptions for any products and/or services provided by us.	All contract, organisation and subscription details. Financial details and records or your interactions	To allow us to administer and perform any contract and/or subscription for the provision of products and/or services to you.
To send you information which is included in your subscription or purchase, including display materials and resources.	All contract, organisation and subscription details.	To allow us to provide you with the documents included in your purchase/subscription.
To provide accurate reporting data to users about pupil performance, attainment and participation. (TLG-PE)	Pupil name, gender, date of birth. Pupil status for SEN, EAL, looked after, disadvantaged, most able.	This information is provided directly by the school to allow us to properly provide accurate data as part of your subscription with us.
To provide accurate reporting data to users about pupil participation. (Steps 2 Summit)	Pupil name, gender, date of birth.	This information is provided directly by the school to allow us to properly provide accurate data as part of your subscription with us.
To conduct monitoring and evaluation of our work.	Contact, organisation and subscription details. Records of attendance and participation.	To allow us to ensure that we can monitor our impact and inform decisions about our future programs, provisions and services.
To answer queries and complaints	Contact and organisation details. Records of your interactions with us.	To allow us to handle queries and complaints in line with our service agreement.
For the purpose of promoting our work	Video Photography	When we have been given explicit consent to do so.
The security of our IT systems	Your online usage of both the TLG-PE system and the Steps 2 Summit system	To allow us to ensure that our IT systems are secure at all times.
To send you marketing information we think you may find useful, or which you have requested from us, including our newsletter, updates, products, services and cross-business opportunities.	Marketing preferences
Retention of records	All the personal information we collect.	We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage our relationship with you and in some cases, we may have a legal or regulatory obligation to retain records.

We will use your personal information as described in this privacy notice, but, for example, we may use your personal information to administer any account(s) you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes.

For some of your personal information you will have a legal, contractual or other requirement or obligation to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly discharge our contractual obligations or comply with legal obligations. 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 deliver our products or services to 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.

5. DIRECT MARKETING

Email and post marketing: from time to time, we may contact you by email or post information about products, services, programmes and opportunities 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 sending an email to dpl@tlg-pe.co.uk. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.

6. DISCLOSURE OF YOUR PERSONAL INFORMATION

Details of how we disclose your personal information are set out below, but generally it is where we need to do so in order to run our organisation or to deliver our goods, services, programmes and events to you. In such circumstances, we will put in place arrangements to protect your personal information. Outside of that we do not disclose your personal information unless we are required to do so by law.

We do not sell, trade or rent your personal information to others. We may share personal information with the following parties:

Any party approved by you
Within the Group: TLG-PE and Steps 2 Summit
IT system providers: including CRM, websites, video and teleconference services
The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives
Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security

We do not disclose personal information to anyone else except as set out above.

7. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

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, however, we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier. In some cases, personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of up to seven years after your last contact with us. Exceptions to this rule are:

All special category data will be deleted or irreversibly anonymised within three months of the date of the event or programme/intervention for which it was collected.
Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after your interaction with us.

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, by contacting us using the details set out in the "Contacting Us" section below.

School data held through the TLG-PE and Steps 2 Summit system (including pupil information) is deleted when a subscription is terminated or expires.

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 to you or another service provider; and
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 your 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 15 below. You can also unsubscribe from any direct marketing (section 5) by clicking on the unsubscribe link in the marketing messages we send to you.

If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner's Office or your local data protection regulator. Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner's website at https://ico.org.uk/for-the-public/. However, we are here to help and would encourage you to contact us to resolve your complaint first.

10. LINKING WITH THIRD PARTY SITES

Our Site may, from time to time, contain links to and from other websites associated with our work or the work of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

In addition, if you linked to our Sites from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

11. SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information. All system data is stored on a Microsoft SQL Server database on a Microsoft Azure platform in the UK. The SQL uses SSL/TLS encryption and the whole site runs on a https encryption.

All TLG-PE Limited staff are subject to an enhanced DBS Check every three (3) years. Additionally, all staff activity is reviewed and monitored weekly to ensure compliance.

12. COOKIES

Certain parts of our Sites use "cookies" to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer's hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.

We use cookies on our Sites to give us an idea of which parts of the Sites you are visiting and to recognise you when you return to the Sites. Reading cookies does not give us access to other information on your computer's hard-drive and our Sites will not read cookies created by other websites that you have visited.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Sites. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Sites.

In common with most websites, our sites log various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.

We may use this information to analyse trends, administer the Site, track your movement around the sites and gather broad demographic information.

13. LOG FILES

In common with most websites, our sites and systems log various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring/exit pages and date/time stamp.

We may use this information to analyse trends, administer the system, track your movement around the sites/systems and gather broad demographic information.

14. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. Any changes we may make to this privacy notice in the future will be posted on our Sites and, where appropriate, notified to you by e-mail. When we change this privacy notice in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes and should you object to any alteration, please contact us as set out in the "Contacting Us" section below.

15. CONTACTING US
In the event of any query or complaint about the information we hold about you, please email

dpl@tlg-pe.com or write to us at:

The Managing Director
4 Cross Street
Beeston
Nottingham
NG9 2NX

Version 2:
Dated 11th May 2018