DATA PROTECTION AND PRIVACY POLICY 2018


1. OUR VALUES

•  User privacy and data protection are human rights

•  We have a duty of care to the people within our data

•  We will never sell, rent or otherwise distribute or make public your personal information

2. RELEVANT LEGISLATION

Along with our business and internal computer systems, this website is designed to comply with the new EU General Data Protection Regulation 2018 (GDPR). This site’s compliance with the above legislation, all of which are stringent in nature, means that our customers are can be fully confident that their own compliance with the GDPR is not compromised.

3. DATA COLLECTION AND THIRD PARTY DATA PROCESSORS

Pinpoint8 collects and uses personal information for the following reasons:

3.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.

GA makes use of cookies, details of which can be found on Google’s developer guides. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

3.2 Order forms

New customers are requested to complete order details using a Pinpoint8 designed Google Form. The data is held within our Google Suite account.

3.3. Data uploaded by client customers

Student data: Name, gender, grades, KS2 average fine levels, FSM status, Pupil Premium status, SEN status, ethnicity. We also require an identification number as generated by the client and this means that the client may choose to use an identification value such as UPN, UCN or ULN. However, any unique value is accepted which means that the three mentioned are not required by Pinpoint 8 Limited. User information: Name and email address.

4. HOW WE USE DATA COLLECTED

Data uploaded by clients including user registration data is not shared with any third party organisation. User and student data belongs to the client and is not stored beyond the duration of purchased licences. Furthermore data is destroyed if a licence is not renewed at the licence renewal date. Student data is processed for calculations that are returned as results to the client as part of the agreed service.

5. HOW WE STORE DATA

We store data uploaded to our website on an Amazon EC2 server based in the USA. This is a dynamic cloud based server and we understand that Amazon is undergoing GDPR compliance procedures.

6. BREACH OF DATA AND THE RIGHTS OF USES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

Registered Pinpoint 8 users have the right at any time to learn about our data collection, data storage and data processing procedures. Users may also verify the accuracy of the data held on them. They have the right to amend or delete their personal data. We consider that we have a legitimate legal interest to hold data that is vital to the running of our operations. We also make clear that whilst the data subjects are not users of the website, they should be made aware by our client customers that their data is uploaded to pinpoint8.com. They furthermore have the right also to amend and delete data held on them.

7. DATA CONTROLLER AND OWNER

Pinpoint 8 Limited

33 Campbell-Bannerman Way

Oldbury

B69 3NE

Company No. 10358463

Email: enquiries@pinpoint8.com

8. DATA PROTECTION OFFICER

Mr. Sandeep Cooner

Director, Pinpoint 8 Limited

Email: sandeepcooner@pinpoint8.com