1.0              Welcome to SSAI privacy policy

·         We appreciate you taking the time to read all our notices carefully.

·         SSAI (“School Safety Assurance International”) is committed to protecting your privacy by ensuring that any personal data is collected and used lawfully and transparently.

·         When delivering our professional services such as employment law advice, health and safety services and legal representation, we are the Data Controller of the personal data that you supply to us under your contract with us.

·         This privacy policy explains how personal data is collected and used when you use our website.

·         It also explains how we process any data that you supply to us on this website, for instance to request a quote or to use our online services.

·         This Privacy Notice explains:

Ø  Who we are

Ø  Personal data we collect

Ø  Our legal basis for processing

Ø  Who we may share information with and why

Ø  Where we may transfer data to

Ø  How we keep information secure and deal with security incidents

Ø  How long we may keep your data for

Ø  Your data privacy rights

Ø  How to contact our DPO and the ICO?

 

2.0              Who is SSAI?

·         SSAI provides a diverse range of clients with access to products and services covering a broad spectrum of knowledge and compliance for School Safety Audit & Certification across a range of educational institutions.

·         When providing these services, we take our responsibilities regarding data protection very seriously and are bound by all applicable data protection laws in respect of the handling, processing and collection of data.

·         All employees who handle personal and business data are fully trained to ensure that the data is processed in line with Local Data Protection Legislation and the General Data Protection Regulations (2018).

 

1.0              Personal Data We Collect

·         The type and frequency of any personal data collected will always depend on how our website and services are used.

·         If you do not wish to provide us with certain categories of personal data, you may not be able to use our services in their entirety.

·         Personal data provided to us: -

Ø  We use electronic contact forms and chat facilities across our websites. These forms will prompt users to input basic contact details so we can generate service quotes, provide newsletter updates and respond to enquiries. You may also provide data to us when registering for an event, newsletter, magazine, seminar or vacancy or when corresponding with us by phone, email, letter or social media. It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes.

·         Personal Data collected by us-

Ø  Where you ask us to provide services, we may be required to process additional categories of personal data relating to you or other parties to ensure that the provision of services are delegated to the right users. We may also collect additional data from you as part of our recruitment process, during your employment or when you visit our offices via CCTV. We may also ask to verify your identity in limited circumstances by providing valid photographic identification.

·         Personal data from other sources: -

Ø  We may receive information about you and/or your company from specific third parties such as business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers. SSAI also receives referrals from other clients and purchases marketing lists from external companies. 

·         Special Categories of Data: -

There may be instances where we need to process Special Category Data provided by you or other users of our services during the lifetime of our service. Special category data is a more sensitive type of data which reveals insights about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life, or sexual orientation. We may also process data that relates to criminal and/or civil offences 

Ø  as well as child data in some very limited circumstances, and you will be made aware of this if we need to collect this data from you. Sensitive data collection will only take place where it is applicable to the provision of the services that we are contracted to provide. The fundamental rights of the data subjects are always assessed to ensure that the processing is fair, transparent and lawful.

·          Online Identifiers: -

Ø  When you visit our website, a record of your device’s IP address is retained which is used anonymously in order to determine website and page visitors.

Ø  For more information on how we use online identifiers or cookies please visit our website cookies policy.

 

1.0              Our Legal Basis for Processing

·           Before processing any personal data, we ensure that at least one lawful basis under GDPR is met.

·           We will not disclose personal data for any purpose other than what the data was originally collected for; unless there is an overriding legal basis that enables this processing.

·           We may collect, hold, use and disclose the information collected to compile statistical data and to maintain our database; to develop or improve our website; respond to any queries; notify you of any upcoming marketing, training or other events that we think may be of interest to you; provide you with publications; manage quality control and compliance issues; manage systems administration; provide you or your organisation with advice; notify you about important changes or developments to our services; contact you for your views on our services or to determine the suitability for employment.

·           We may also process your personal data in the following circumstances.

 

2.0              To Perform Our Service Under the Contract:

·         We process information in order to support and maintain our existing or potential contractual relationships under the lawful basis ‘performance of a contract’.

·         We may process personal data in order to provide various supporting client services, take payments and to make improvements to our website.

·         We record all calls made to our staff members including internal, inbound or outbound calls.

·         The lawful basis which we often rely on to process data for the duration of servicing on your account and for the decision to enter an initial or any subsequent contract is under our ‘legitimate interests’.

·         Ensuring our administrative and IT systems are secure and robust against unauthorised access also falls under this basis.

·         For fraud prevention: -

Ø  Due to the products we offer to companies, we also have a ‘legal obligation’ to validate the status of companies we work with which may involve identifying and verifying individual data subjects as part of our ‘legitimate interests’ to safeguard against criminal or fraudulent activities.  We also need to ensure that VAT / GST/ Income Tax is paid accurately in line with the nature of the services we provide. 

·         To Defend Legal Issues: -      

Ø  We have a ‘legitimate interest’ to process data which may assist us in connection with the establishment.

·         To Process Sensitive Data: -  

Ø  In some cases, where the processing is deemed high risk or highly sensitive, we may ask for your ‘consent’ before we undertake the processing. For example, when providing information on reasonable adjustments before an interview. Where consent is used as the lawful basis for the processing, you will be entitled to withdraw that consent at any time as well as exercise your data privacy rights.

·         When you apply for a vacancy:         

Ø  You provide several pieces of data to us directly during the recruitment exercise. In some cases, and to facilitate our ‘Legitimate Interests’ we will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies. Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins. We have a Legal Obligation to ensure you have a right to work in the location and make reasonable adjustments for you if you have a disability. The ongoing lawful basis we rely on to process your data will be under our legal obligations or legitimate interests which may include assessments made on salary.

·         For Marketing Purposes:        

Ø  SSAI is one of Exclusive Global Licensee of ACCAB. There may be occasions where several divisions in the group are involved in the delivery of the services you are contracted to receive. On occasion, we may share data with our affiliated divisions under our ‘legitimate interests’ to enhance the delivery of any services you have. You can opt out of group marketing by emailing us at: info@school-safety.org

Ø  As part of our business-to-business sales strategy we may contact companies and individuals of companies about our products and services. To do this, we rely on our shared ‘legitimate interests’ in doing business together. This lawful basis also applies to any purchased data we may use from our various lead sources and when we share your data across our group databases.

Ø  For more detailed information on our lead sources please visit the respective company privacy notices below to learn more about their individual data acquisition and handling practices. You can also opt out of updates and marketing by clicking on the unsubscribe button at the footer of our email communications.

·         Full information about our data processing obligations for each product we sell can be obtained via our Group Data Protection Officer upon request.

·         Their contact details are disclosed at the bottom of this notice.

 

1.0              Data Sharing and International Transfers

·         Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial, technological or administrative assistance.

·         When we share data with an external third party; these operations are governed by a Data Processing Agreement (DPA) and we perform regular due diligence on any external companies we work with to ensure that high levels of data integrity are maintained.

·         Any transfers taking place outside the EEA are only permitted with the provision of an Adequacy decision, Standard Contractual Clauses (SCC’s) or any other lawful transfer mechanism.

·         Where necessary, we may need to share data with external organisations such as law enforcement, regulatory bodies, fraud prevention agencies, partners or advisors.

·         Before any data is shared, we ensure that all technical and organisational controls are firmly in place and a data protection impact assessment is undertaken, where applicable, if the sharing or transfer is considered high risk.

·         We do not sell your data to any third parties.

 

2.0              Data Storage and Security

·           We have a dedicated Information Security team who are in place to offer protection across all our networks and IT assets to assist with data security and data loss prevention.

·           All our systems are robustly secured, and we are ISO27001 Certified.

·           We also have a specialised Incident Response Team on hand to respond quickly to any data related issues including the prevention and detection of cyber criminals.

·           Cloud providers we use have servers based within the location jurisdictions. As a company we promote a ‘paperless’ culture where possible.

 

3.0              Data Retention

Companies within the SSAI only keep your data for as long as necessary, unless there is an overriding legal ground. We will not retain data if it is deemed unlawful to do so.

·         Data may be held for purposes relating to the establishment, exercise or defence of legal claims which the group or our clients may face.

·         Where we represent you in any legal case, we retain the data for seven years from the conclusion of the litigation case.

·         We will also typically keep data concerning your account for at least seven years from the date you end your contract with us.

·         Some data may be deleted before this time period depending on the category of that data in line with our commercial legitimate interests and retention schedule, for example, data provided to us in the course of an unsuccessful job application will be retained no longer than 6 months after the recruitment exercise.

·         Personal data that is no longer necessary is deleted securely in line with SSAI Data Disposal Policy. Our Data Retention and Data Disposal policies are available upon request.

 

1.0              Your Data Privacy Rights

·         All data subjects have individual rights. On a case by case basis, you have the following rights in relation to your personal data processed by SSAI:

Ø  The right to be informed about how your personal data is collected and used.

Ø  The right to request access to a copy of any personal data that we hold about you.

Ø  The right to rectify personal data we may hold which is identified as incorrect or misleading.

Ø  The right to erasure of any personal data; also known as ‘the right to be forgotten’.

Ø  The right to restrict further processing of your personal data.

Ø  The right to data portability where technology allows us to send personal data onto a new controller.

Ø  The right to object to the processing or certain processing activities.

Ø  Rights in relation to automated decision-making including profiling

·         As an organisation we do not operate any automated decision-making systems.

·         Please be aware that the rights listed in this section only apply to individuals and cannot be used to request data relating to business entities.

·         Please be aware that your rights of access do not entitle you to physical or digital copies of any documentation we hold, nor can we facilitate Freedom of Information requests ‘FOI’.

 

2.0              Queries and Complaints

·         SSAI has a dedicated representative who can be approached for any questions, comments and requests regarding this privacy policy or our Data Privacy Management System.

·         Frequently asked questions about or GDPR compliance can be accessed here.

·         Our Group Data Protection officer welcomes communication around our policies and practices and they can be directly contacted on the details below, which are also publicly available on the ICO register.

·         You can also write them at: info@school-safety.org  

·         SSAI Data Protection Officer Address:

Ø    Suite #58, Arihant Industrial Premises, Off Link Road, Goregaon (W), Mumbai - 400 065, Maharashtra, India

·         Data Protection Officer:  info@school-safety.org

·         If you’re not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can approach the regulator for further guidance website.

 

2.0              Additional Information

·         This version was last updated and reviewed July 2022.

·         We regularly review and monitor regulatory guidance for any industry changes which may impact our business operations or your rights and freedoms.

·         In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, SSAI data or an online identifier.

·         We are legally known as SSAI, and our address is:

Ø  Suite #58, Arihant Industrial Premises, Off Link Road, Goregaon (W), Mumbai - 400 065, Maharashtra, India.