LEAP Equine Assisted Programmes Limited (‘we’ or ‘us’ or ‘our’), hereafter known as ‘LEAP’, gather and process your personal information in accordance with this privacy notice and in compliance with the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR) which comes into force on 25th May 2018 and relevant laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
This Policy explains how we use any personal information we may receive about you when you use our website, request information or when you attend our training courses or use our services.
LEAP’s registered office is at Unit 1c, Crucible Close, Coleford, Gloucestershire, GL16 8RE and we are a company registered in England and Wales under company number 07852416. We are registered on the Information Commissioner's Office Register registration number ZA222726, and act as the Data Controller and Data Processor in relation to data supplied to us. Our Data Protection Officer can be contacted at email@example.com.
2. DEFINITIONS OF DATA
A. PERSONAL DATA
“Any information relating to an identified or identifiable natural person (‘data subject’).”
“An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
B. SPECIAL CATEGORY DATA
“Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.”
3. WHEN WE COLLECT INFORMATION
LEAP may collect personal information about you when you:
· Contact us via our website by completing the ‘Contact Us’ form.
· Contact us via email.
· Request information.
· Register for training.
· Attend training courses.
· Register as a LEAP Practitioner.
· Receive any of our services.
· Apply for jobs with LEAP.
We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
LEAP takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice.
4. WHAT TYPE OF DATA WE COLLECT
The type and extent of data collected will be limited to the purpose of the collection and may include:
· Email address
· Landline Telephone Number
· Mobile Telephone Number
· Training Course Application Information which includes:
- Biometric Information
- Health Information
- Qualification Records
- Training Course Assessment Information which includes:
- Registered Practitioner Information which includes:
- Company Name and contact details
- Insurance Details
- Employee Data
5. WHY WE COLLECT THIS INFORMATION
The purposes and reasons for processing your personal information include:
· To respond to requests for course information.
· To advise you of new courses that become available.
· To follow up on Workshops to offer full course information.
· To answer queries.
· To offer CPD opportunities to LEAP Practitioners.
· To update LEAP Practitioners with membership information.
· To register students with Crossfields Institute.
· To improve courses by requesting feedback.
· To process recruitment applications.
· To process employee payroll information.
6. HOW WE COLLECT THIS INFORMATION
LEAP collects personal information:
· Directly from recipients. e.g. If you submit an enquiry through our website or contact us via email or telephone.
· From our ticketing partners - e.g. when you register for a course via a third party, they will pass your information to LEAP for processing.
· When our services are provided with a business partner – the information is collected by the business partner in order for us to provide you with the product or service.
· When you apply for a Training Course and submit Course application documents.
· Directly from job applicants e.g. if you submit a job application.
7. SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement.
LEAP uses selected third parties to provide our services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us.
Your personal information may be provided to:
• Our Senior Therapeutic and Training Team for reviewing course applications. Details of the Team can be found on our website.
· Selected third parties – such as Crossfields Institute, Paysubs membership site, Eventbrite ticketing site, Xero accounting and payroll system - a listing of our third parties can be supplied on request.
At no time will any personal data held by LEAP be passed to organisations for marketing or sales purposes.
9. SECURITY MEASURES
10. TIMESCALES FOR HOLDING PERSONAL DATA
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes
LEAP retains personal information for only as long as is necessary for the purpose for which it was provided, and we have retention policies in place to meet these obligations.
For example, Crossfields Institute Quality Assurance documents are required to be retained for a minimum of 3 years.
11. LEGAL GROUNDS FOR PROCESSING DATA
LEAP uses the following grounds for processing personal data:
The individual (you, the data subject) has given clear consent for LEAP to process your data for a specific purpose. Eg, sending out course literature following a request.
The processing is necessary for a contract with you or there are specific steps required before entering into a contract. Eg. processing registration data for Crossfields Institute.
C. LEGAL OBLIGATION
The processing is necessary for LEAP to comply with the law. Eg, processing tax information to HMRC.
12. YOUR RIGHTS
You have the right to access any personal information that LEAP processes about you and to request information about:
· What personal data we hold about you
· The purposes of the processing
· The categories of personal data concerned
· The recipients to whom the personal data has/will be disclosed
· How long we intend to store your personal data for
· If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws, to exercise your data portability rights, and to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
13. EXTERNAL LINKS
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
LEAP is not responsible for the content of any of these sites, and the content of these sites does not represent the views of LEAP nor does this imply our endorsement of the linked websites or any association with their operators.
15. CONTACTING LEAP
LEAP only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If you wish to exercise your rights as specified in this notice, raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact us at:
Data Protection Officer
Leap Equine Assisted Programmes Ltd
16. COMPLAINING TO THE ICO
You also have the right to lodge a complaint with the supervisory authority:
Information Commissioner's Office
Telephone: 0203 123 1113