All data subjects whose personal data is collected, in line with the requirements of the GDPR and the Data Protection Act 2018 by Life on Time ltd.
2.1 The Managing Director is responsible for ensuring that this notice is made available to data subjects prior to Life on Time collecting or processing their personal data.
2.2 All Employees and Staff of Life on Time who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured or the legal basis for processing their data has been communicated clearly.
3. PRIVACY NOTICE
3.1 Who are we?
We are Life on Time ltd, a personal development and wellbeing company. The platform youHQ enables schools to fulfil their PSHE requirements while also giving schools the opportunity to help improve student wellbeing and personal development.
When we refer to ’’we’’, ’’our’’ or ’’Lifeontime’’ we are referring to Life on Time ltd the business.
Our Data Protection Officer and data protection representatives can be contacted directly here:
|By Mail:||Data Protection Officer 1 Shearers Close, Weavering, Maidstone Kent ME 14 5UQ|
The personal data we may collect or process on you is:
Registered Data Subjects
Non-Registered Data Subjects
The personal data we collect falls into different categories (sometimes more than one). Your data will be used for the following purposes:
Product – Information in this category is needed in order to be able to provide Life on Time software to data subjects. In addition it is required to address or deal with any requests or enquiries.
Login – Information in this category is used to ensure we have a unique login method for each data subject in particular to improve website security.
Marketing – Information in this category is used to send out Life on Time product information to parties who have requested or are highly likely to have an interest.
Company – Information in this category is used to send out company information on Life on Time and its products and services.
Our legal basis for processing for the personal data:
Students – Our legal basis for processing your data is Contract. We have this in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide.
Teachers / Staff Members – Our legal basis for processing your data is Contract. We have this in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide.
Any legitimate interests for, in particular, non-registered data subjects is pursued by us, or third parties we use, are as follows:
Mailchimp – www.mailchimp.com
Life on Time does not collect or process data defined as ‘special categories’ by the ICO such as: Racial; Ethnic origin; Political opinions; Religious beliefs; Philosophical beliefs; Trade union membership; Genetic data; Biometric data; Health data; Data concerning a natural person’s sex life or Sexual orientation.
3.2 Legal basis for processing Student, Teacher and School Staff Member data
We are processing your personal data based on our Contract with your school. You may object to this processing by contacting your school directly. Your school will then work with us to block any future data coming through to our system. We will then remove / anonymise all your personal data on our system within 28 days of the request being made.
3.3 Legal basis for processing Non-Registered Data Subjects data
We are processing your personal data based on either Explicit Consent or for legitimate reasons.
Our legitimate interest is to promote the products and services we provide. From time to time we
would like to contact you with details of these products and services.
We process personal information for certain legitimate business purposes which include, some or all, of the following:
• Where the processing enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of the customer.
• To identify and prevent fraud.
• To enhance the security of our networks and information systems.
• To better understand how customers interact with our social media and web sites.
• To provide communications which we think will be of benefit and interest to you.
• To determine the effectiveness of our promotional campaigns and our advertising.
You may opt out of this processing at any time by contacting us directly on:
Once you have opted out, we will no longer contact you with information about Life on Time products and all of your personal data will be deleted and/or anonymised within 28 days.
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available on request about the factors we shall consider when deciding whether information should be disclosed.
You can also get further information on:
- agreements we have with other organisations for sharing information
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
Except as set out above Life on Time will not pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements. We will never sell your data to third parties. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:
|Third party Name||Safe Guards in place to protect your data||Purpose|
|123-REG.CO.UK||We store data needed to manage and run customer accounts. 123 Reg is committed to keeping its customers’ data secure, and all data we hold on you is protected by appropriate measures, including encryption. The only 123 Reg employees who can access your data are those who need to access your data for business, such as our support teams helping you over the phone, and all such access is logged. In addition to this, all staff who need to access your data have been trained on respecting your rights, and wider data protection issues.||Product database (inc personal data from school platform)|
|Mailchimp.com||Please see their security information here https://mailchimp.com/about/security/||Marketing|
In addition to the above exceptions, you provide your general consent to Life on Time, with appropriate safeguards and procedures, to utilise media channels such as Facebook, Twitter and Google to provide company updates and product information.
3.5 Retention period
Life on Time will process and store personal data for students, teachers and school staff members for the duration of the schools license with Life on Time. If you leave the school during an active license with your school we will delete/anonymise your personal data within 28 days of your account being deleted by your school.
For non-Life on Time users we will process and store personal data while we are in contact with you with relevant information on our services.
If you have opted out to your data being processed we will delete your data within 28 days of your opt out being received.
3.6 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – in the event that Life on Time refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.7 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.5 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Life on Time (or third parties as described in 3.5 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Life on Time’s Data Protection Officer.
The details for each of these contacts are:
Supervisory authority contact details
|Contact Name:||Information Commissioner’s Office (ICO)|
Data Protection Officer (DPO) contact details
|Contact Name:||Life on Time DPO|