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Early Years Solutions:
- 'Earlyyearssolutions.com'
Privacy Policy
Our
contact details
Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
Phone Number: 01872 330030
E-mail: support@earlyyearssolution.com
The type of personal information we collect
We currently collect and process the following
information:
·
Name
·
Email address
·
Mobile number
·
Profession
·
Registration number
·
‘Online
identifiers’ includes IP addresses and cookie identifiers which may be personal
data
How
do we get personal information, and why do we have it?
All the personal information we process is provided to us
directly by you for one of the following reasons:
·
To register on the earlyyearssolution.com for
completing e-learning and training
·
To attend updates on the topic
·
To participate in live classes
·
To participate in discussions
·
To provide your feedback
We use the information that you have given us to
1)
Send link to live classes
2)
Send updates on the relevant topics
3)
Answer any queries you might have
We follow the following seven key
principles in processing personal data.
“(a) processed
lawfully, fairly and in a transparent manner in relation to individuals
(‘lawfulness, fairness and transparency’);
(b) collected for
specified, explicit and legitimate purposes and not further processed in a
manner that is incompatible with those purposes; further processing for
archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes shall not be considered to be incompatible
with the initial purposes (‘purpose limitation’);
(c) adequate,
relevant and limited to what is necessary in relation to the purposes for which
they are processed (‘data minimisation’);
(d) accurate and,
where necessary, kept up to date; every reasonable step must be taken to ensure
that personal data that are inaccurate, having regard to the purposes for which
they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form
which permits identification of data subjects for no longer than is necessary
for the purposes for which the personal data are processed; personal data may
be stored for longer periods insofar as the personal data will be processed
solely for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes subject to implementation of the
appropriate technical and organisational measures required by the GDPR in order
to safeguard the rights and freedoms of individuals (‘storage limitation’);
(f) processed in a
manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental
loss, destruction or damage, using appropriate technical or organisational
measures (‘integrity and confidentiality’).”
Lawful basis for processing
☐ We have reviewed the purposes of our
processing activities and selected the most appropriate lawful basis (or bases)
for each activity.
☐ We have checked that the processing
is necessary for the relevant purpose and are satisfied that there is no other
reasonable and less-intrusive way to achieve that purpose.
☐ We have documented our decision on
which lawful basis applies to help us demonstrate compliance.
☐ We have included information about
both the purposes of the processing and the lawful basis for the processing in
our privacy notice.
☐ Where we process special category
data, we have also identified a condition for processing special category data
and have documented this.
Under the General Data Protection Regulation (GDPR), the
lawful bases we rely on for processing this information are:
(a)
Your consent.
You can
remove your consent at any time. You can do this by contacting us at support@earlyyearssolution.com or using the contact us page on the
website: earlyyearssolution.com
(a)
Legitimate interest:
☐ We have checked that legitimate
interests is the most appropriate basis.
☐ We understand our responsibility to
protect the individual’s interests.
☐ We have conducted a legitimate interests assessment (LIA) and kept a record of it, to
ensure that we can justify our decision.
☐ We have identified the relevant
legitimate interests.
☐ We have checked that the processing
is necessary and there is no less intrusive way to achieve the same result.
☐ We have done a balancing test, and are confident that the individual’s interests do not override those
legitimate interests.
☐ We only use individuals’ data in ways they would reasonably
expect, unless we have a very good reason.
☐ We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a
very good reason.
☐ We do not process children’s data, special category data or
criminal offence data.
☐ We have considered safeguards to
reduce the impact where possible.
☐ We have considered whether we can
offer an opt out.
☐ If our LIA identifies a significant
privacy impact, we have considered whether we also need to conduct a DPIA.
☐ We keep our LIA under review and
repeat it if circumstances change.
☐ We include information about our
legitimate interests in our privacy information.
YOUR CHOICES
1.Limit the information You
provide: You always have an option to choose the information You provide to us,
including the option to update or delete Your information. However, please note
that lack of certain information may not allow You access to the Platform or
any of its features, in part or in full. For example: information required for
Your registration on the Platform.
2.Limit the communications You
receive from us: Further, You will also have the
option to choose what kind of communication You would like to receive from us.
However, there may be certain communications that are required for legal or
security purposes, including changes to various legal agreements, that you may
not be able to limit.
3) Reject Cookies and other similar
technologies: You may reject or remove cookies from Your web browser; You will
always have the option to change the default settings on Your web browser if
the same is set to ‘accept cookies’. However, please note that some of the
Services offered on the Platform may not function or be available to You, when
the cookies are rejected, removed, or disabled
Your data protection rights (if you are
a UK customer)
Under data
protection law, you have rights including:
Your right of access
- You have the right to ask us for copies of your personal information.
Your right to
rectification - You have the right to ask us to rectify personal information
you think is inaccurate. You also have the right to ask us to complete information
you think is incomplete.
Your right to
erasure - You have the right to ask us to erase your personal information in
certain circumstances.
Your right to
restriction of processing - You have the right to ask us to restrict the
processing of your personal information in certain circumstances.
Your right to object
to processing - You have the right to object to processing your personal
information in certain circumstances.
Your right to data
portability - You have the right to ask that we transfer the personal
information you gave us to another organization or you in certain
circumstances.
You are not required
to pay any charge for exercising your rights. However, if you make a request,
we have one month to respond to you.
Please contact us at
support@earlyyearssolution.com or Early Years Solutions, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ if you wish to
make a request.
☐ We take responsibility for complying
with the UK GDPR, at the highest management level and throughout our
organisation.
☐ We keep evidence of the steps we take
to comply with the UK GDPR. We put in place appropriate technical and
organisational measures, such as:
☐ adopting and implementing data
protection policies (where proportionate);
☐ taking a ‘data protection by design
and default’ approach - putting
appropriate data protection measures in place throughout the entire lifecycle
of our processing operations.
☐ putting written contracts in place
with organisations that process personal data on our behalf.
☐ maintaining documentation of our
processing activities.
☐ implementing appropriate security measures.
☐ recording and, where necessary,
reporting personal data breaches
☐ carrying out data protection impact
assessments/ Legitimate interest assessment for uses of personal data that are
likely to result in high risk to individuals’ interests.
Contracts
Early Years Solutions, UK is using the
platform by Graphy INC, Vistra
(Delaware) Ltd, 3500 South Dupont HWY, Dover, Kent, DE 19901, Email: privacy@graphy.com is the data processor.
When a Learner
purchases any Creator's Content, Graphy will provide
the Creator access to a limited set of Personal Information about such Learner
to enable the Creator to provide their services to the Learner. We clarify that
in respect of the Learners' Personal Information, Graphy
shall remain the controller of the Personal Information collected, processed and stored on the Platform as stated hereunder.
However, any
Personal Information processed and stored by the Creator outside the purview of
the Platform shall be the responsibility of the ‘Early years solution.’
Contracts is in
place to include specific terms or clauses regarding:
a)
processing only on the controller’s documented
instructions.
b)
the duty of confidence.
c)
appropriate security measures.
d)
using sub-processors.
e)
data subjects’ rights.
f)
assisting the controller.
g)
end-of-contract provisions; and
h)
audits and inspections.
☐ We consider data protection issues as
part of the design and implementation of systems, services, products, and
business practices.
☐ We make data protection an essential
component of the core functionality of our processing systems and services.
☐ We anticipate risks and
privacy-invasive events before they occur and take steps to prevent harm to
individuals.
☐ We only process the personal data
that we need for our purposes(s), and that we only use the data for those
purposes.
☐ We ensure that personal data is
automatically protected in any IT system, service, product, and/or business
practice, so that individuals should not have to take any specific action to
protect their privacy.
☐ We provide the identity and contact
information of those responsible for data protection both within our
organisation and to individuals.
☐ We adopt a ‘plain language’ policy for any public
documents so that individuals easily understand what we are doing with their
personal data.
☐ We provide individuals with tools so
they can determine how we are using their personal data, and whether our
policies are being properly enforced.
☐ We offer strong privacy defaults,
user-friendly options and controls, and respect user preferences.
☐ We only use data processors that
provide sufficient guarantees of their technical and organisational measures
for data protection by design.
☐ When we use other systems, services or products in our processing activities, we make
sure that we only use those whose designers and manufacturers take data protection
issues into account.
☐ We use privacy-enhancing technologies
(PETs) to assist us in complying with our data protection by design
obligations.
☐ We have assessed the nature and scope
of our processing activities and have implemented encryption solution(s) to
protect the personal data we store and/or transmit.
☐ We understand the residual risks that
remain, even after we have implemented our encryption solution(s).
☐ We ensure that we keep our encryption
solution(s) under review in the light of technological developments.
☐ We have considered the types of
processing we undertake, and whether encryption can be used in this processing.
Personal data breaches
Preparing for a personal data breach
☐ We know how to recognise a personal data breach.
☐ We understand that a personal data breach isn’t
only about loss or theft of personal data.
☐ We have prepared a response plan for addressing any
personal data breaches that occur.
☐ We have allocated responsibility for managing
breaches to a dedicated person.
☐ Our staff know how to escalate a security incident
to the appropriate person or team in our organisation to determine whether a
breach has occurred.
Responding to a personal
data breach
☐ We have in place a process to assess the likely
risk to individuals as a result of a breach.
☐ We have a process to inform affected individuals
about a breach when their rights and freedoms are at high risk.
☐ We know we must inform affected individuals without
undue delay.
☐ We know who the relevant supervisory authority for
our processing activities is.
☐ We have a process to notify the ICO of a breach
within 72 hours of becoming aware of it, even if we do not have all the details
yet.
☐ We know what information we must give the ICO about
a breach.
☐ We know what information about a breach we must
provide to individuals, and that we should provide advice to help them protect
themselves from its effects.
☐ We document all breaches, even if they don’t all
need to be reported.
International
transfers
Any Personal Information
that we transfer will be protected in accordance with this Policy as well as
with adequate protections in place in compliance with applicable laws and
regulations.
Please note that these
countries may have differing (and potentially less stringent) privacy laws and
that Personal Information can become subject to the laws and disclosure
requirements of such countries, including disclosure to governmental bodies,
regulatory agencies, and private persons, as a result of
applicable governmental or regulatory inquiry, court order or other similar
process.
Please note that the
Personal Information we hold about You may have to be transferred to other
countries outside Your residential country. Same shall be done in accordance
with the purposes described in this Privacy Policy. https://graphy.com/dpa
How to complain
If you have any concerns about our use of your personal
information, you can make a complaint to us at support@earlyyearssolution.com or postal address Early Years Solutions, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
You can also complain to the ICO if you are unhappy with
how we have used your data.
The ICO's address:
Information
Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk