HUB Privacy & Cookies Policy
West Country Business Systems (Holdings) Limited of Landmark House, Wirral Park Road, Glastonbury, Somerset BA6 9FR (“we”, “us”) are committed to protecting and respecting your privacy. We operate the website and HUB services for the benefit of schools, Local Education Authority (LEAs) or similar organisations, their staff, students and parents (collectively, Users).
For the purpose of the Data Protection Act 2018 (and any replacement legislation) and the General Data Protection Regulation (UK) (together the Data Protection Legislation), West Country Business Systems (Holdings) Limited is the data controller.
INFORMATION ABOUT USERS
We may collect and process the following data:
- Information Users give us when using HUB. Users may give us information when registering for or logging into HUB, using the services available via HUB, or by corresponding with us by phone, e-mail or otherwise to assist with administration and support of a User’s account. Such information about a User may include name, address, e-mail address and phone number.
- Information we collect about Users. With regard to each visit to HUB, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect a User’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about a User’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from HUB (including date and time); pages viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our support number.
HOW WE USE THIS INFORMATION
We use information held about Users in the following ways:
- to provide HUB and related services available via HUB to Users;
- to carry out our obligations arising from any contracts entered into between schools, LEAs or similar organisations and us and to provide Users with the information, products and services requested from us;
- to provide Users with information about other goods and services we offer that are similar to those that a school has already purchased or enquired about;
- to notify Users about changes to our service;
- to ensure that content from HUB is presented in the most effective manner for Users and the computers being used to access HUB;
- for internal record-keeping and reporting purposes;
- for the purposes of supporting the provision of HUB and dealing with any support requests or customer queries;
- for analytical, research, reporting and product development purposes;
- to administer HUB and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve HUB to ensure that content is presented in the most effective manner for Users and for Users’ devices;
- to allow Users to participate in interactive features of our service, when Users choose to do so;
- as part of our efforts to keep HUB safe and secure;
- to measure or understand the effectiveness of any advertising we serve to Users and others, and to deliver relevant advertising to Users;
- to make suggestions and recommendations to Users of HUB about goods or services that may interest Users.
WHAT ARE COOKIES AND HOW DO WE USE THEM?
A cookie is a small file of letters and numbers that we store on your browser, computer, or device. We may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of HUB. They include, for example, cookies that enable Users to log into secure accounts, use interactive features and services.
- Analytical/performance cookies. These allow us to recognise and count the number of visitors and Users and see how they use HUB. This helps us to improve the way HUB works, for example, by ensuring that Users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise Users when they return to HUB. This enables us to personalise our content for Users, greet you by name and remember your preferences.
- Targeting cookies. These cookies record your visit to HUB, the pages you have visited and the links you have followed. We will use this information to make HUB and the information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please see HUB Cookies Policy which details the cookies we use.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of HUB.
INFORMATION WE RECEIVE FROM OTHER SOURCES
We may receive information about a User from third parties we work with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
HOW WE USE THIS INFORMATION
We may combine this information with information Users give to us and information we collect about Users. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We may use information relating to Users and schools in anonymised format to carry out research and produce reports that we publish and share with third parties. No User or school would be identifiable in such research reports.
DISCLOSURE OF INFORMATION
We may share User personal data with any member of our Group, which means our subsidiaries, our ultimate Holding Company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share User personal data with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or a school.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- The school, LEA, or other similar organisation on whose behalf or under whose direction Users access and use HUB.
We may disclose personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose User personal data to the prospective seller or buyer of such business or assets.
- If West Country Business Systems (Holdings) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about Users will be one of the transferred assets.
WHERE WE STORE USER PERSONAL DATA
The data that we collect from Users will not be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). All information Users provide to us is stored on our secure servers. Where we have given Users (or where you have chosen) a password which enables access to certain parts of HUB, Users are responsible for keeping this password confidential. We ask Users not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect User personal data, we cannot guarantee the security of User data transmitted to HUB; any transmission is at Users’ own risk. Once we have received User information, we will use strict procedures and security features to try to prevent unauthorised access.
Personal data that we process about Users for any purpose shall not be kept for longer than is necessary for that specific purpose.
Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
YOUR RIGHTS & ACCESS TO YOUR DATA
You may request from us, details of the personal data we hold about you and how we are processing it, although this should be clear from HUB itself and the permissions/consents you have set.
Where notified, we will amend your data, including where you provide us with additional information to complete your record.
Where you have previously consented to us using your data, you may withdraw this consent at any time.
You may request that we restrict the use of your data, where you believe:
- the data we hold about you is inaccurate;
- the processing of your data is not lawful;
- your data no longer needs to be used for the purpose that it was originally provided; and
- where you object to the use of your data for specific purposes.
Should you no longer wish to engage with HUB, you have the right to request erasure of your details from our systems. To complete these requests, please submit in writing to DPO@wcbs.co.uk.
Please note that in some circumstances, where we act as a data processor on behalf of a third party, your relationship with the data controller (i.e. the school or LEA), for example, a contract of employment, may result in your not being able to stop engaging with HUB, and/or to have your data erased.