Fire Tech Camp Privacy Policy

Last updated: 8th May 2018

  1. Scope
    All data subjects whose personal data is collected, in line with the requirements of the GDPR.
  2. Responsibilities
    1. The Data Protection Officer / GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Fire Tech collecting/processing their personal data.
    2. All Employees/Staff of Fire Tech 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.
  3. Privacy notice
    1. Who are we? FireCamp Ltd trading as Fire Tech (“us”, “we”, or “our”) operates the http://www.firetechcamp.com website (the “Service”). We are a UK based company offering tech education services for children and teens.

      Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
      • dpo@firetechcamp.com
      • 02039507237

      The personal data we would like to potentially collect or process about  [collect from/process on] you is:

      Personal data type: Source (where Fire Tech obtained the personal data from if it has not been collected directly from you, the data subject.):
      Full Name Provided by you
      Email Address Provided by you
      Billing Address Provided by you
      Phone Number Provided by you
      How you heard about us Provided by you
      Product/Course Purchased Booking information
      Order Numbers Generated when making booking
      Student Name Provided by you
       Student Date of Birth  Provided by you
       Student School  Provided by you
       Student Gender  Provided by you
       Student Sign out options  Provided by you
       Student Medical Issues  Provided by you
       Student Educational Needs  Provided by you
       Emergency Contact Name and Number  Provided by you
       Opinions on service  Provided by you
       Payment Method  Provided by you
       Photos  Taken at camp if consent given

      The personal data we collect will be used for the following purposes:
      • Fulfill your booking
      • Prevent fraud
      • Enable us to communicate with you
      • Our Financial records
      • Child Safetey/Care
      • Analytics to optimise logistics and future camp offerings
      • Profiling to ensure we send only relevant marketing messages (e.g. avoid sending information about events in a region or age group that is not relevant)

      Our legal basis for processing for the personal data:
      • Fulfill a contract
      • Legal Obligation
      • Protect Vital Interests and provision of health or social care
      • Consent Given

      Any legitimate interests pursued by us, or third parties we use, are as follows:
      • Ensure balance in gender/learning needs in class and tutor assignment
      • Aid in logistics (e.g. ensure we have sufficient T-shirts available in the student sizes)
      • Verify students are the right age for the course
      • Determine if a region or school needs additional camps/events/resources to meet demand

      The special categories of personal data concerned are:
      • Provision of health or social care – we need to know how to respond to an emergency health care situation such as administering an EPI pen or to support students with additional learning needs.

    2. Consent
      By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
      Consent is required for Fire Tech to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

      You may withdraw consent at any time by requesting a Withdrawal of consent form by emailing dpo@firetechcamp.com [describe how the user withdraws consent in line with Withdrawal of Consent Procedure ].

    3. Disclosure
      Fire Tech will pass on your personal data to third parties for the purposes defined below. We do not pass information to for any other  parties or for any other purpose. without first obtaining your consent. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

      Third Party / Organisation Safeguards in place to protect your personal data
      Lee Hatlee (Accountant) Only accessed securely through our accounting service which has 256bit encrypted SSL and data storage. Only receives data required to keep an accurate financial record.
      Square Mile (Accountants)  Only accessed securely through our accounting service which has 256bit encrypted SSL and data storage. Only receives data required to keep an accurate financial record.
    4. Retention period
      Fire Tech will process personal data and will store the personal data for up to 7 years from last contact with the data subject. Some data is retained for a shorter period but for HMRC financial reporting, prevention of fraud and customer service some data must be retained for the full 7 years.

    5. 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 Fire Tech 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 3.6 below.

      All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data. You can request a Subject Access Request Form by emailing dpo@firetechcamp.com

    6. Complaints
      In the event that you wish to make a complaint about how your personal data is being processed by Fire Tech (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Fire Tech’s data protection representatives Data Protection Officer / GDPR Owner.

      The details for each of these contacts are:

      Supervisory authority contact details Data Protection Officer (DPO)] contact details
      Contact: Data Protection Officer
      Address line 1: Firecamp ltd
      Address line 2: 12 Hammersmith Grove
      Town: London
      Postal Code: W6 7AP
      Email: dpo@firetechcamp.com
      Telephone: 02039507237
  4. Privacy statement
    Personal Data
    Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
    “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 data, 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”.

    How we use your information
    This privacy notice tells you how we, Fire Tech, will collect and use your personal data for fulfilling orders, child safety, marketing messages for mailing lists you have subscribed to, optimising our services (selection of courses offered in a region, ensure messages that are sent to you are relevant, logistics of equipment and tutors etc), financial records and prevention of fraud. We also require your information for customer services, managing complaints and requests.  [outline further information on services and activities that you collect personal data, for example: cookies, profiling, complaints, subscriptions, etc.)

    Why does Fire Tech need to collect and store personal data?
    In order for us to provide you with our tech education services we need to collect personal data for us to know which courses you have booked, provide timely and relevant communications about your booking(s), inform you of any health, education or safety issues with your child, keep accurate records for accounting, logistics of running a camp. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

    In terms of being contacted for marketing purposes Fire Tech would contact you for additional consent.

    Will Fire Tech share my personal data with anyone else?
    We may pass your personal data on to third-party service providers contracted to Fire Tech in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Fire Tech’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

    How will Fire Tech use the personal data it collects about me?
    Fire Tech will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Fire Tech is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

    Under what circumstances will Fire Tech contact me?
    Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

    Can I find out the personal data that the organisation holds about me?
    Fire Tech at your request, can confirm what information we hold about you and how it is processed. If Fire Tech does hold personal data about you, you can request the following information:

    • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
    • Contact details of the data protection officer, where applicable.
    • The purpose of the processing as well as the legal basis for processing.
    • If the processing is based on the legitimate interests of Fire Tech or a third party, information about those interests.
    • The categories of personal data collected, stored and processed.
    • Recipient(s) or categories of recipients that the data is/will be disclosed to.
    • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
    • How long the data will be stored.
    • Details of your rights to correct, erase, restrict or object to such processing.
    • Information about your right to withdraw consent at any time.
    • How to lodge a complaint with the supervisory authority.
    • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
    • The source of personal data if it wasn’t collected directly from you.
    • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

    What forms of ID will I need to provide in order to access this?
    Fire Tech accepts the following forms of ID when information on your personal data is requested:
    • Current signed passport
    • Current UK driving licence
    • Local authority council tax bill for the current council tax year
    • Birth certificate
    • Utility bill or Bank Statement (from last 3 months)
    • National identity card

    Contact details of the Data Protection Officer / GDPR Owner:

      Data Protection Officer (DPO)] contact details
    Contact: Data Protection Officer
    Address line 1: Firecamp ltd
    Address line 2: 12 Hammersmith Grove
    Town: London
    Postal Code: W6 7AP
    Email: dpo@firetechcamp.com
    Telephone: 02039507237

Document Owner and Approval

The Data Protection Officer / GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff on the corporate intranet and is published at https://www.firetechcamp.com/privacy-policy/.

 

Change History Record

Issue Description of change Approval Date of Issue
1 Initial Issue Jill Hodges 14 April 2017
2 GDPR update Jill Hodges 8 May 2018