Privacy Notice

Three Spires Trust (TST) considers the privacy of your data carefully and seriously. This notice describes how TST handles any personal data that it collects. Personal data is any information about you by which you can be identified or be identifiable. This could include your name or email address that is not otherwise publicly available.

This notice does not apply to the practices of companies that TST does not own or control, or to individuals that we do not employ or manage.

This privacy notice sets out how TST and its academies use and protect any information that you provide when you use a TST website.

TST is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using an TST academy website, then you can be assured that it will only be used in accordance with this privacy statement.

Our TST websites contain links to other websites. This privacy notice only applies to TST websites, so when you navigate to other websites you should read their own privacy notices.

How and where we collect information

We may collect information from you whenever you contact us or have any involvement with us, for example when you:

• Visit our website
• Attend a meeting with us and provide us with information
• Social media or post
• Apply for a vacancy via our website

We collect information from you when you give it to us directly: you may provide your details when you ask us for information or contact us for any other reason. Your information may be collected by an organisation we are working with, but we are still responsible for your information.

What we do with the information we gather

We require this information to process your enquiry via a contact form (if the TST website uses one), process an application for a vacancy, for record keeping and internal analysis for advertising or marketing purposes. By providing us with your details you are agreeing for us to send you information pertaining to your enquiry by either post, telephone, or email.

You have the right at any time to stop us from contacting you if you no longer wish to be contacted. Your information will be kept inline with the TST Information Retention Schedule.

Use of aggregated data

Where data can be aggregated (and anonymised), we may use this for research purposes without restriction.

For example, we may monitor customer traffic patterns, site and services usage and related information to optimise users’ usage of the site and services, and we may give aggregated statistics to a reputable third-party.

We are entitled to do this because the resulting data will not personally identify you and will therefore no longer constitute personal data for the purposes of data protection laws.

Security

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We will not share your information with any third parties without your permission.

Our legal basis for processing your information

The use of your information for the purposes set out above is lawful because one or more of the following applies:

Where you have provided information to us for the purposes of requesting information or requesting that we carry out a service for you, we will proceed on the basis that you have given consent to us using the information for that purpose, based on the way that you provided the information to us. You may withdraw consent at any time by emailing us using the details below. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.

It is necessary for us to hold and use your information so that we can carry out our obligations under a contract entered into with you or to take steps you ask us to prior to entering into a contract.

Where the purpose of our processing is the provision of information or services to you, we may also rely on the fact that it is necessary for our legitimate interests in relation to providing the information or service requested, and given that you have made the request, would presume that there is no prejudice to you in our fulfilling your request.

Cookies

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and when it visits certain other websites.

Why do we use cookies?

We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our websites for advertising, analytics, and other purposes.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our website (bottom left corner of any page). If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.

You may also set or amend your web browser controls to accept or refuse cookies. As how you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit aboutads.info/choices/ or youronlinechoices.com

What types of cookie do we use?

The below list details the cookies used in our website.

Necessary cookies

Some cookies are required to provide core functionality. The website won’t function properly without these cookies, and they are enabled by default and cannot be disabled.

Preferences

Preference cookies enable the website to remember information to customise how the website looks or behaves for each user. This may include storing selected currency, region, language, or colour theme.

Analytical cookies

Analytical cookies help us improve our website by collecting and reporting information on its usage.

Marketing cookies

Marketing cookies are used to track visitors across websites to allow publishers to display relevant and engaging advertisements

Google Analytics

We use Google Analytics to collect information about visitor behaviour on our website and TST academy websites. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g., your name or address) so this information cannot be used to identify who you are. You can find out more about Google’s position on privacy (which includes Analytics) at: google.com/intl/en/policies/privacy/

Twitter (third-party)

We embed our Twitter feed on some of our pages and TST academy website pages. We use this to let visitors easily view or share our tweets or follow our accounts. You can view the Twitter Privacy Policy at twitter.com/en/privacy

Microsoft Bing (Third-party)

Some pages on our site and TST academy sites contain Microsoft Forms, which may place a Microsoft Bing cookie on your device to deliver targeted advertising when you visit Microsoft and other websites. You can view the Microsoft Privacy Policy at privacy.microsoft.com/en-gb/privacystatement

Changes to our privacy notice

We keep our privacy notice under regular review, you should check on regular basis to ensure that you are happy with any changes. This privacy notice was last updated on 07 July 2023.

Your rights

You have the right to request details of the processing activities that we carry out with your personal information through making a subject access request. To make a request, please contact us using the details below.

You also have the following rights:

• Right of Access You have a right to access and receive a copy of your personal data.
• Right to Rectification of information that is inaccurate or out of date or completed if it is incomplete.
• Right to Erasure of your information (known as the “right to be forgotten”). This right is not an absolute right and only applies in certain circumstances.
• Right to Object You have the right to object to the processing of your personal data in certain circumstances.
• Right to Restrict Processing You have the right to request restriction or suppression of your personal data. This right is not an absolute right and only applies in certain circumstances.
• Right to Data Portability You have the right to receive your personal data be provided to you in a format that is commonly used, structured, and suitable for transferring to another controller.
• Right to lodge a compliant with a supervisory authority If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner’s Office.

If you want to use your rights, for example, by requesting a copy of the information which we hold about you, or by asking us to correct or remove information you think is inaccurate, please contact our Data Protection Officer (DPO). Contact details below.

How to contact us

Please contact us if you have any questions about our privacy notice or about the information we hold about you:

Name: Three Spires Trust
Address: New Beacon Building, Stafford Education & Enterprise Park
Phone Number: 01785 526011
E-mail: dpo@threespirestrust.org