The Development Manager Ltd (and its trading names: TDM, TDM Wyre Academy, TDM VLE Middleware, TDM Open Source Software Services- also referred to in this policy as : “we”, “us”, “our”) is committed to ensuring that your privacy is protected.
For legal & privacy issues, our address is:
TDM, County House, St Mary’s Street, Worcester, WR 1QH.
This Policy describes the Personal Information that we gather from you in connection with the service(s) we deliver, how we use and disclose such information, and the steps we take to protect such information.
Depending on the level of your involvement with us the information we collect about you will vary. For example, if you are just browsing our website we will collect some information via cookies, but if you fill in a form to access one of our services the relevant form will ask you for personal information needed for us to deliver the resources and/or service(s) we deliver. This will depend on the request you are making.
By using our service(s), you consent to the privacy practices described in this Policy as well as the terms of any agreement you have made with The Development Manager Ltd. In connection to the service(s) we deliver.
We are committed to ensuring that your privacy is protected, and we strictly adhere to the provisions of the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and we are compliant with the EU General Data Protection Regulation (GDPR), which comes into force on the 25th May 2018.
The GDPR provides the following rights for individuals:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling
What Personal Information do we collect about you?
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our service(s) if that information is necessary to provide our service(s) to you or if we are legally required to collect it.
Personal information provided by you
We ask you to provide certain Personal Information when you apply to use our services, request a resource, indicate that you would like us to contact you, send us customer service-related requests, or use our service(s).
You may provide us with your name, email address, town, nationality, position, job role, company information, qualifications attainment, and any other information you communicate to us, such as when you contact our support team, when you provide your business card at trade shows or events.
You may also provide us with information that you add to your profile, such as a picture for your profile, depending on the type of service(s) you are requesting/using from us.
Personal Information provided by stakeholders or other service providers
Personal Information Obtained from your Interaction with our websites or service(s) platform(s)
When you interact with our websites we use technology that helps us identify and analyse your interaction with the content and the features of these sites.
We have different platforms that serve different purposes, and these will be available to you depending on the level of service(s) we offer to you.
We may also automatically record certain information from your device by using various types of technology, including web beacons. This automatically collected information tracks your interaction with our websites so may collect information such as your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use our website(s), the pages or other content you view or otherwise interact with on our website(s), and the dates and times that you visit, access, or use the Service(s). We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.
We use this information to analyse and improve our service(s), including by assessing how many users access or use our service(s), which content, products, and features of our service(s) most interest our visitors, what types of offers our customers like to see, and how our service(s) perform from a technical point of view.
Personal Information Obtained from Your Interaction with Social Media Tools
We may use social media tools such as LinkedIn, Facebook, Twitter, Instagram to promote the service(s) we deliver. These third-party buttons implemented in our websites may function as web beacons. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by TDM and is subject to that third party’s own data collection, use, and disclosure policies.
How we may use your personal information?
When We may process your Personal Information?
We may use your personal information when:
• You have consented to the use of your Personal Information.
• We need your Personal Information to provide you with service(s) we can offer, requested by you, or to respond to your enquiries.
• We have a legal obligation to use your Personal Information.
• We or a third party, have a legitimate interest in using your Personal Information, including to ensure and improve the safety, security and performance of our products and services.
Why we may use the Personal Information we obtain about you?
• To operate and manage the service(s) we deliver to you. For example, giving you access to our learning platforms and learning environments to deliver our programmes.
• To comply with our legal obligations when we are required to do so by government bodies and/or by law.
• To communicate with you in relation to the service(s) we deliver to you, for example: updates on security risks, announcements of webinars/workshops, relevant news related to the service(s), and customer service related communications.
• To evaluate and improve our business and service(s) and performing activities that will allow us to do so, such as: developing new improved services; managing our communications; determining the effectiveness of our content, newsletter and advertising; determining your level of satisfaction; analysing our products, services and websites.
• To send you marketing communications about services, offers, events we run in relation to the service(s) we offer to you, bi-annual newsletters, surveys and any other relevant communications.
• To understand and analyse the usage trends and preferences of our customers and perform data analysis to understand trends.
• To communicate with customers – people who are using our service(s). For example, to send you progress reports, send you financial communications, etc.
• To enforce any agreement, you have made with The Development Manager Ltd.
• To comply with applicable law and industry standards.
Depending on the level of service(s) you have with us some of these communications may be mandatory from the funding authority. For example, to perform customer satisfaction services, to request updated information from you, etc. You will be made aware of these if you engage with our service(s).
You may have the right under applicable law to opt out of receiving promotional communications as described below under “Your Rights and Choices” section.
How do we control your personal information?
• We may need to share the Personal Information we collect with our stakeholders who help us deliver the service(s) to you. We do this when it is reasonably necessary for us to disclose your Personal Information.
• We may need to disclose your personal information where we are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions.
• We also may share Personal Information with our service providers who perform services on our behalf and in relation to the purposes described in this Privacy Notice (e.g. customer relationship management platforms, customer data management system platform, finance system platforms, virtual learning environments platform)
We require these service providers to comply with certain data protection obligations and only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements. We only engage with service providers that have data protection safeguards in place that comply with general data protection regulations and electronic communications regulations.
• We may also need to disclose your Personal Information to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection or other legal duties.
What are your rights and choices?
• You may choose to restrict the collection or use of your personal information in
the following ways:
o Whenever you are asked to fill in a form on our website(s), look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
o If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us to: email@example.com
• Where required by law, we obtain your consent for the processing of certain Personal Information, when we process Personal Information deemed sensitive pursuant to applicable law, or when we carry out other processing activities for which consent is required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time, however we may not be able deliver the service(s) we provide to you if you choose to do so, this will not affect the lawfulness of the processing before your consent withdrawal.
• You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to The Development Manager, County House, St Mary’s Street, WR1 1HB.
• If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
• Please note that these rights may be restricted and subject to conditions under applicable law.
How safe is your information?
Protecting your security and privacy is extremely important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Act 1998 and the GDPR. Our website(s) and platforms we use to deliver our service(s) are protected by various levels of secure technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.
The information we collect is stored in secure cloud vaults that operate inside the EEA. All information is stored in an encrypted form. Information held by Microsoft or Google on our behalf may be transferred outside of the EEA but only where there are appropriate protections in place and in line with GDPR guidance.
TDM Information Security Strategy
Due to the nature of the service(s) we deliver TDM have always looked after our customers’ data in line with UK and EU government guidelines and regulations. TDM have been registered with ICO since its very beginnings and we have developed a variety of policies and procedures that together form our Information Security Strategy.
All TDM’s staff are inducted and trained on these policies and procedures.
We review these once a year as a minimum to keep them up to date with new regulations and guidelines.
Related Standards, Policies and Processes
• Access Control Procedures
• Clear Desk and Screen Policy
• Computers and electronic communications policy
• Confidentiality Policy
• Data Protection Policy
• Document Retention Policy
• Information Security Policy – Acceptable Use Policy
• Mobile Computing Devices Policy
• Mobile Policy
• Monitoring Policy
• Safeguarding Policy
• Secure Hosting Policy
• Storing and transferring work data policy
First issue – Taking into account our privacy statement and data protection policy, to comply with General Data Protection Regulation to come into place 25th May 2018