Privacy Policy

Ethically Led Ltd is registered with the ICO and compliant with the General Data Protection Regulations (GDPR) as a Data Controller. The company will liaise with the DPO of each education setting to ensure compliance with processes and procedures. 

Any data breaches will be reported to the client it relates to and to the ICO if applicable. Any breaches will be fully investigated by the company in liaison with the client, and security measures will be assessed and reviewed in relation to the investigation.  Ethically Led Ltd understands that failure to report a breach when required to do so may result in a fine, as well as for the breach itself. 

The Ethically Led website has security measures in place to protect the loss, misuse and alteration of the information under the company's control. All instances of unauthorised, attempted access to the site are logged and investigated. Where necessary, Ethically Led will inform law enforcement agencies or other relevant organisations regarding misconduct.

When a client makes an initial enquiry about using Ethically led Ltd, the company will request, and record, a contact name and some additional details. This could include:

• Name
• Job title
• Contact information (including email address and telephone number)
• Geographic information, such as postcode

Further information will be collected during meetings, telephone conversations, letters, emails and through the completion of agreement paperwork. Such information is only recorded and used to ensure effective and efficient communication with the education setting. 

The company will not collect any personal data that is not needed in order to provide the service agreed. This could include:

• To provide a service requested, for example, to respond to any enquiries submitted via email / telephone.
• To request and use client feedback for the purpose of monitoring, developing and improving the company's services.
• To maintain internal record keeping.
• To send personalised emails and information about services, offers and information clients may find interesting using email addresses provided (if a client doesn't want to be kept informed in this way by email, please let the company know this).

Any information / data from the client will only be processed when it is purposeful for the legitimate interests of Ethically led Ltd (the data controller), except when such interests are overridden by the interests, rights or freedoms of the client (data subject).

• Confidentiality will always be ensured when discussing information / data on the telephone or with other professionals present. Ethically Led Ltd will ensure to check confirmation of who is being spoken to at all times.
• No individual pupil level data will be requested by Ethically Led Ltd. During the lawful process of service delivery, group level data / information may be collected and processed. (Any emails sent containing group level information / data will be sent password protected / encrypted by the client.)

Ethically Led Ltd uses the details of the clients who have requested a service in order to provide it. However, these details are only used to provide the service required and for other closely related purposes. 

Ethically Led Ltd will not use or share client information with any other company for marketing purposes. If a client wishes to unsubscribe from receiving marketing material from Ethically Led Ltd at any time, please contact the company.

Under no circumstances does Ethically Led Ltd allow any unauthorised person to access confidential or personal information. The company stores as little information / data as possible. Methods for storage when necessary include:

• Electronically via a secure server.
• Manually in paper records kept in a locked filing cabinet.
• In Cloud based systems (Microsoft), securely backed up. 
• Electronically on lap-top computers with encryption. (All electronic devices are password protected to secure the information on the device in case of theft)
• Portable devices (such as mobile telephones or tablets) will not be used to hold personal information.

Non-sensitive details (email address etc) are transmitted normally over the internet which can never be guaranteed to be 100% secure. As a result, Ethically Led Ltd will strive to protect your personal information, but cannot guarantee the security of any information transmitted via email and the client does so at their own risk. Once the clients information is received, Ethically Led Ltd will make best efforts to ensure its security.

• Right of access - A client has a right to obtain a copy of the personal information Ethically Led Ltd holds about them, free of charge. If a client believes that any information held is incorrect / incomplete, please contact the company. Any information that is found to be incorrect / incomplete will be amended promptly. 
• Right to Erasure - A client has the right to request the deletion or removal of their personal data if they feel there is no compelling reason for its continued processing.
• Right to complain - A client has a right to  complain to the Information Commissioner's Office if they feel there is a problem with the way Ethically Led Ltd is handling their data. Please contact: https://ico.org.uk/concerns/handling/
• Right for data portability - A client has the right to request that their data is transmitted directly to another organisation which the company will undertake if this is technically feasible. Ethically Led Ltd will respond to such a request from a client within one month and if unable to do so will explain why.

When information /data is to be deleted this will be done securely / confidentially. Paper documents will be shredded and electronic memories scrubbed clean / destroyed, once it is no longer required or has fulfilled its purpose. 

Any information held in manual files / electronically will not be retained for longer than 7 years, unless the company is required to retain it longer for legal reasons. Information will never be retained for longer than is necessary. 

If any client / individual has a concern over their data held by Ethically Led Ltd, please contact:

• The Director - Claire Evans - on claire@ethicallyled.co.uk  or 07300 814564
• The Headteacher / Principal / Head of School or Data Protection Officer of the education setting.

Limited data sharing is necessary for Ethically Led Ltd to fulfil its obligations. The information / data collected by the company on behalf of the education setting the agreement is with, will only be collected for the specified, explicit and legitimate purposes as described above. It will not be further processed in a manner that is not compatible with the purposes of the service delivery. It will not be shared with any third parties for marketing purposes and it will not be shared or referred to in social media. 

Ethically Led Ltd reserves the right to change this Privacy Policy. The company will provide notification of any such changes through the website at the time they take effect. 

By using this website / entering into an agreement with Ethically Led Ltd, a client signifies their acceptance with this policy. (This includes following the posting of any changes to this Privacy Policy.)

If you require any further information, or need to make contact, please write, telephone or email the company at:

Ethically Led Ltd

71-75 Shelton Street 

Covent Garden

London

WC2H 9JQ

Tel: 07300 814564

Email: claire@ethicallyled.co.uk

This document was last updated June 2023