Cookie Policy
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Google’s privacy policy is available at: google.com/policies/privacy.
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Privacy policy
Inspira is a leading personal development and career guidance organisation based in Cumbria. Inspira works across the North West of England helping young people and adults develop skills for life and work.
Inspira is committed to the principles of good data processing and sharing of personal information.
Inspira needs to collect personal information about people with whom it works in order to carry out its business and deliver its services.
Such people include Clients, employees (present, past and prospective), suppliers and other business contacts.

Inspira accepts its legal responsibilities and duties as a data controller to protect the rights of staff and Clients. This policy sets out the standards and controls to which the Company and its staff will adhere:

  • Processing and sharing personal information about Clients;
  • Processing information regarding suppliers, subcontractors and contract commissioners;
  • Processing and storing personal and sensitive information about past, present and future employees.

Information held by Inspira includes name, address, email address, data of birth, personal and sensitive information (such as ethnic origins, sexual life, health issues and privileged information). In addition, the company may occasionally be required to collect and use certain types of personal information to comply with the requirements of the law. No matter how the information is collected, recorded and used (e.g. on a computer or on paper) this personal information must be dealt with properly to ensure compliance with all relevant legislation.

 
Recording of Calls
Telephone calls with us will be recorded for training and quality purposes. We engage third parties to carry out quality and compliance monitoring on our behalf and customer data including recorded calls is made available to such third parties for this purpose.

 
SUMMARY OF LEGISLATIVE ACTS
The Crime and Disorder Act 1998 S.115
This act provides a legal power and duty to share information for the purposes of the Act i.e. crime prevention.
Website http://www.legislation.gov.uk/ukpga/1998/37/contents

 

Data Protection Act 1998
The purpose of the Act is to protect the rights and privacy of individuals, and to ensure that data about them is not processed without their knowledge and is processed with their consent wherever possible. The Act covers personal data relating to living individuals, and defines a category of sensitive personal data which are subject to more stringent conditions on their processing than other personal data.
It also provides legal gateways for organisations to disclose personal data in certain circumstances, for example for the purposes of prevention and/or detection of crime, or the imposition of a tax or duty.
Website http://www.legislation.gov.uk/ukpga/1998/29

 

The Human Rights Act 1998 Article 8
Article 8 offers general protection for a person’s private and family life, home and correspondence from arbitrary interference by the State. Unless such interferences satisfy the following conditions:
In accordance with law and
– in the interests of the legitimate objectives identified in Article 8(2);
and
– necessary in a democratic society. In the interests of national security, public safety or for the prevention of disorder or crime, the protection of health or morals or the protection of rights and freedoms of others.
Website http://www.legislation.gov.uk/ukpga/1998/42/contents

 

Freedom of Information Act 2000
The Freedom of Information Act gives individuals a right of access to information held by the local authority, subject to a number of exemptions. Requests for information must be made in writing (email, letter or fax) but can be received by any member of staff at the local authority. Such requests must be responded to within 20 working days.
This act is aimed specifically at local authorities and not private companies and as such Inspira will respond to requests for information from the local authority but not requests from individuals.
Website http://www.legislation.gov.uk/ukpga/2000/36/contents

 

Privacy and Electronic Communications Regulations 2003
Section 11 of the Data Protection Act allows individuals to control the direct marketing information they receive from organisations. The Privacy and Electronic Communications Regulations specifically regulate the use of electronic communications (email, SMS text, cold calls) as a form of marketing and allow individuals to prevent further contact.
Website http://www.legislation.gov.uk/uksi/2003/2426/contents/made
The Information Commissioner also provides further information at http://www.ico.gov.uk/for_organisations/privacy_and_electronic_communications/the_guide.aspx

 

Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
An amendment to the Privacy and Electronic Communications Regulations in 2011 obliged websites to inform users about their use of cookies and seek consent for setting more privacy intrusive cookies.
Website http://www.legislation.gov.uk/uksi/2011/1208/contents/made

 

Digital Economy Act 2010
The Digital Economy Act regulates the use of digital media in the UK. It deals with issues such as online copyright infringement and the obligations that internet service providers (ISPs) have to tackle online copyright infringement.
Website http://www.legislation.gov.uk/ukpga/2010/24/contents

 

Malicious Communications Act 1988
The Malicious Communications Act makes it illegal to “send or deliver letters or other articles for the purposes of causing stress or anxiety”. This also applies to electronic communications such as emails and messages via social networking websites.
Website http://www.legislation.gov.uk/ukpga/1988/27/contents

 

RESPONSIBILITY
It is the duty of all employees to accept and understand their responsibilities for Data Protection, Confidentiality and Information Sharing, and to follow any procedures in relation to this. Employees must also inform Clients of the Company’s position on privacy and data protection, Consent or concerns are to be recorded accordingly.
It is the responsibility of line managers to ensure that all employees are aware of and understand the Company’s policy and any related procedures.
It is the responsibility of the Process Holder to review this policy annually and to make revisions as necessary.
It is the responsibility of the HR Director to ensure that personal and sensitive data for employees is processed and handled in accordance with the related procedures.

 

POLICY
Data Protection Act 1998
Inspira will ensure that all staff abide by the principles set out in the Data Protection Act 1998 which require personal information to be:
• Fairly and lawfully processed.
• Able to meet the specific conditions set out in the act for processing personal data and obtaining consent for recording information (schedule 2 and 3).
• Processed for limited specified purposes.
• Adequate, relevant and not excessive for those purposes.
• Accurate and up to date.
• Kept for no longer than necessary.
• Processed in accordance with individuals’ rights.
• Kept secure.
• Not transferred to non-EEA (European Economic Areas) without adequate protection.

These principles apply equally to paper and electronic files.

All staff will follow the Inspira Procedure 26: Recording and Storing Information about Clients.
The HR department will follow the Inspira Procedure 32: Personnel Records Keeping.

 

Confidentiality
Inspira is committed to protecting the privacy of Clients and its employees. Personal information recorded about employees, Clients, contractors and commissioners on the Company’s systems will be treated as private and confidential, and as such held within the principles of Data Protection.
Inspira recognises that staff will obtain information about individuals and organisations during the course of their work or activities.
Information that is received by the Company will be shared with identified staff members to enable the best quality delivery of its commissioned services. Access to information will be controlled and unauthorised use of the Company’s Management Information Systems or Personnel files will be addressed through the Company’s disciplinary procedures.

 

Personal Data
Personal data is data that relates to an individual who can be identified from that data or any other information held or likely to be held. This may include any expression of opinion about the individual or people connected to them.

 

Sensitive Personal Data
Sensitive personal data (as defined by the Data Protection Act 1998) is a sub-set of personal data. It is defined as information describing, in relation to the data subject:
• Racial and ethnic origin
• Political opinions
• Religious beliefs or other beliefs of a similar nature
• Membership of a trade union
• Physical or mental health condition
• Sexual life
• Commission or alleged commission of any offence; or any proceeding for any offence committed or alleged to have been committed by the subject, the disposal of such proceedings or the sentence of any court in such proceedings

In most cases such information will not be stated as confidential and colleagues may have to exercise professional judgement and discretion in identifying whether information is expected to be confidential and as such considered sensitive personal information.

 

Collection of Data

Informed consent is when:
• An Individual/Client clearly understands why their personal information is needed, who it will be shared with, and the possible consequences of the subject agreeing or refusing the proposed use of the data.
• And then gives their consent.
The Company will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person (including third party), or by completing a form (electronic or paper based).
When collecting personal data, Inspira will ensure that the Individual/Client:
1. Clearly understands why the information is needed;
2. Understands what it will be used for and what the consequences are should the Individual/Client decides not to give consent to processing;
3. As far as reasonably possible, grants explicit consent, either written or verbal for the data to be processed;
4. Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress;
5. Has received sufficient information on why their data is needed and how it will be used.
Inspira will also take reasonable steps to ensure that personal information is kept up to date by communicating with Clients (data subjects) or known contacts of the client whether there have been any changes to the data.
The methods employed for communicating to Clients are through traditional follow up methods, SMS texting, Emails and social media campaigns.
Inspira may use sensitive personal data collected in respect of one product or service to market another appropriate product or service to Clients.

 

Opting Out of Communications
A client has the right to ‘Opt out’ of communications (for example text messaging) regarding the company’s services, products or promotions, any requests will be recorded against the Clients record to ensure the Company’s compliance.
The Privacy and Electronic Communications Regulations 2003 Http://www.legislation.gov.uk/uksi/2003/2426/contents/made specifically regulate the use of electronic communications (email, SMS text, cold calls) as a form of marketing and allow individuals to prevent further contact.

 

Disclosure of Personal Information to external agencies or organisations
Inspira will not sell or transfer personal information regarding Clients to other organisations for profit.
Where the information has been obtained from a third party, for example, information supplied by a commissioning organisation as part of Inspira’s delivery of the service or subcontractor working on behalf of Inspira for delivery of a service then the principles for sharing such information will be detailed in an information sharing agreement that has been approved through the executive directorate.
Sensitive personal information will not be disclosed to other persons or organisations without the explicit written consent of the data subject unless there is a requirement in law to do so.
All staff will follow the procedure 27: Sharing Sensitive Personal Information about Clients.

 

Use of Cookies
Inspira websites use cookies to allow a richer visitor experience. Where an applicable website uses a cookie control system which will enable the user on their first visit to the website to allow or disallow the use of cookies on their device. All websites hosted and owned by Inspira comply with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s device.
Cookies are small files saved to the user’s device that track and store information about the user’s interactions and usage of the website. This allows the website, to provide visitor’s with a tailored and richer experience within the website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Inspira uses tracking software provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to the device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information.

 

Access to Clients Personal Data through Social Media Platforms
When a client interacts with Inspira on social media platforms, (for example, by clicking ‘Like’ on our Facebook page, posting messages to the Company’s Facebook timeline, by following Inspira or mentioning the company in a tweet on Twitter) Inspira can then subsequently interact with the client including sending messages via these platforms.
Any Personal Data Inspira may have access to through social media platforms depends upon the Clients configured personal settings on these platforms. However configured Inspira will have access to all public information regarding the client on these platforms. Inspira may also be able to access personal data that others share about Clients (because they control how that is shared, not the client).
Inspira may collect data that is accessible about a client through social media platforms, including but not limited to Facebook and/or Twitter profile picture, gender, and status.
Any interactions that Inspira conducts through social media platforms will be in-accordance with each platform’s rules. Inspira are not responsible for how the platform owners collect and handle personal data. Inspira are not responsible for what third parties post on our social media timelines.
All staff will follow Policy 24: Social Media

 

Clients right of access to their information
Every client or, in cases where it is appropriate, a person with parental responsibility, has the right to see a copy of all personal information held about them on Inspira records. Furthermore Clients have the right to request that information is removed or amended if inaccurate.
All staff will follow the Procedure 25: Clients Right of Access to Personal Information.

 

Employee’s right of access to their information.
Every member of staff has the right to see a copy of the personal information held about them by Inspira on their personnel file under the Data Protection Act 1998, and access to Medical Records Act 1990. The company reserves the right to charge an administration fee for this service.
All staff will follow Procedure 32: Personnel Record Keeping

 

Controllers of personal information
Inspira is a data controller as defined by the Data Protection Act 1998, and is committed to obtaining, processing, storing and using all personal information held about its Clients, employees (present, past and prospective), suppliers and other business contacts in accordance with the principles set out in the Act. Any personal information provided to or collected by Inspira is controlled by:
Mr David Emerson (Data Controller)
Inspira Cumbria Ltd
Gillan Way
Penrith 40 Business Park
Penrith
CA11 9BP