Your privacy is important to us. This Retention Policy is where we explain to you how long we may retain personal information that is collected when you visit our site, www.accessea.co.uk

This policy should be read together with our Privacy Policy and Cookie Policy which together with this Retention Policy describe the manner in which we handle your personal information when you visit our site.

For convenience, we have divided our data protection policies into three separate pages:

1. Our Privacy Policy
   You can find our Privacy Policy on this page, which explains generally how we collect, use, store, and protect your personal information when you visit our site.
   
   
2. Our Cookie Policy
   Our Cookie Policy is available on this page and explains more about how we may collect personal information about you via cookies (it also explains what cookies are).
   
   
3. Our Retention Policy
   Our retention policy, which is this document, explains how long we may hold onto personal information collected or processed by us when you visit our site.

If you have any questions please do not hesitate to contact us at info@accessea.co.uk  or, if you prefer to call or write to us, then you can find our contact details at the bottom of this page.

WHO WE ARE
AccessEA is the trading name of the Edinburgh Academy Trading Company Ltd, (registered company number SC167036).

PURPOSE OF THIS DOCUMENT
The purpose of the Retention Policy is to explain what personal information we may collect about you when you visit our site or interact with our online services, the purpose of that collection, and how long we store that personal information for.

Our Retention Policy is broadly divided into two sections:

• Our website; and

Depending on how you interact with our site and our services we may collect different types of personal information about you. The duration that we retain that personal information will vary depending on how you interact with us. For example, we may retain information about you for a longer period of time if you have asked us to keep you updated about developments in the school.

OUR WEBSITE

This table details the personal information and we may collect about you on our site located at www.accessea.co.uk  

INFORMATION PURPOSE	INFORMATION COLLECTED	LAWFUL BASIS FOR PROCESSING	LEGITAMIT INTERESTS	RETENTION PERIOD
To register you as a new customer	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Information Location, Address, Email, telephone,   Health & medical information Medicine and allergen Information   Emergency contacts/Relationships Name, Telephone no, Relationship to another attendee.	Contract management   Consent		14 MONTHS
To process and deliver your booking/purchase	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Location, Address, Email, telephone,   Transaction	Contract Management   Lawful basis to communicate		14 MONTHS
To manage our relationship with you, including notifying you about changes to our terms or privacy notices	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Location, Address, Email, telephone,   Transaction	Contract Management   Necessary to comply with a legal obligation   Lawful basis to communicate	Record maintenance	14 MONTHS
To enable you to partake in a prize draw, competition or to complete a survey	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Location, Address, Email, telephone,   Transaction	Contract Management   Lawful basis to communicate   Consent	Business performance review   Identify development opportunities	14 MONTHS
To administer and protect our business and our website	Transaction   Technical   Usage	Lawful basis to communicate	Network security, admin and IT services	14 MONTHS
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Location, Address, Email, telephone   Marketing and communications   Usage   Profile	Lawful basis to communicate	Business services evaluation,    Growth development opportunities   Develop  marketing strategy	14 MONTHS
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences	Technical    Usage    Profile	Lawful basis to communicate	To define customer personas   Website maintenance: updated and relevant   To develop our business and to inform our marketing strategy	14 MONTHS
To make suggestions and recommendations to you about the services that may be of interest to you	Identity Title, name, gender, D.O.B., School attending, T-shirt size, age, year group   Contact Location, Address, Email, telephone   Marketing and communications   Technical   Profile   Usage	Lawful basis to communicate	Develop services and grow business	14 MONTHS

 

COOKIES
You can find more information about the types of cookies that we use and their purpose by reviewing our cookies policy. 

 

Insert table from School website and update Radiator as provider

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. You may also delete any cookies stored on your computer at any time.

You can find out more about changing cookie settings on your computer by visiting http://www.allaboutcookies.org/manage-cookies/.

Different cookies may be stored for different periods of time. In many cases these cookies are updated automatically each time you visit our site or may expire and be deleted by your device automatically. Each time you visit our site you start a new “session”. When you leave our site the session ends. The expiry period of a cookie will usually run from the date of the most recent session. This means that, each time you visit our site, the expiry period for those cookies may reset.

It is important to understand that when a cookie is placed on your device it will reside on your hard drive until it expires and is deleted or it may reside on your hard drive until you manually delete it – this entirely depends on your individual browser settings and we do not have control over this.
 

MARKETING AND OTHER COMMUNICATION
We do not use any of the personal information collected from our site or that you may pass to us by filling in forms on our site for any marketing purposes. If you have requested that we get in touch with you then we will only use your personal information to assist us in answering your query.

CHANGES TO OUR RETENTION POLICY
We may need to change this Retention Policy if it’s necessary for legal reasons or to reflect changes to our site and services or the purposes for which we may wish to collect and process your personal information. In any case, the provisions of this Retention Policy may be changed without prejudice to your rights. When we change our Retention Policy we will make the updated Retention Policy available on our site and we will also update the “Last Updated” date.

Once we change our Retention Policy, we will use our reasonable efforts to inform you. This may include asking you to agree to the updated Retention Policy before we process further information about you or it may require us to suspend access to parts of our site until you agree to the updated Retention Policy – we will only restrict access to parts of our site where we deem it is necessary for us to collect or process personal information about you.

You are welcome to contact us if you have questions about the changes.

CONTACT US
This Retention Policy was prepared with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our retention of your personal information. However, we are happy to provide additional information or explanation needed.

If you have any questions, comments or requests regarding our Retention Policy then please do not hesitate to get in touch with us. To make things easier for both of us we would appreciate it if your queries were addressed to;

AccessEA

The Edinburgh Academy Trading Company Ltd.
42 Henderson Row
Edinburgh
EH3 5BL
United Kingdom

info@accessea.co.uk or 0131 624 4919

Thank you for visiting accessEA – AccessEA is the trading name of the Edinburgh Academy Trading Company Ltd, (registered company number SC167036).

Your privacy is important to us. This Retention Policy is where we explain to you how long we may retain personal information that is collected when you visit our site, www.accessEA.co.uk

This policy should be read together with our Privacy Policy and Cookie Policy which together with this Retention Policy describe the manner in which we handle your personal information when you visit our site.

For convenience, we have divided our data protection policies into three separate pages:

1. Our Privacy Policy
   You can find our Privacy Policy here which explains generally how we collect, use, store, and protect your personal information when you visit our site.
   
   
2. Our Cookie Policy
   Our Cookie Policy is available here and explains more about how we may collect personal information about you via cookies (it also explains what cookies are).
   
   
3. Our Retention Policy
   Our retention policy, which is this document, explains how long we may hold onto personal information collected or processed by us when you visit our site.

If you have any questions please do not hesitate to contact us at info@accessea.co.uk or, if you prefer to call or write to us, then you can find our contact details on the main contact us page of the website.

WHO WE ARE
AccessEA, we are The Edinburgh Academy Trading Company Limited (company number SC167036). Our registered office is at 42 Henderson Row, Edinburgh, EH3 5BLBut, for the purposes of this Retention Policy, it’s just easier if we refer to ourselves as “we”.

WHAT THIS PRIVACY POLICY GOVERNS
This Privacy Policy applies to our site, www.accessea.co.uk and any other services that we may provide to you through our site (we’ll just call these “our services” for short).

In the context of this Privacy Policy “personal information” means information which, on its own or in combination with other information, can be used to identify you, in particular by reference to an identifier such as your name, your address, or location data.

Provided that you consent to us collecting your personal information when you visit our site then this Privacy Policy will govern how we may use that personal information.

Because we are located in Scotland the personal information that you give us or that we collect from you will be held under Scottish data protection legislation (but we’ll just refer to this as “the legislation”). The legislation requires that we tell you that we are a data controller for your personal information or, in other words, we determine the purposes for which and the manner in which any of your personal information are, or are to be, processed by us.

HOW YOU CONSENT TO US COLLECTING YOUR PERSONAL INFORMATION
When you visit our site you should see a pop-up at the top of your screen directing you to this Privacy Policy and our Cookie Policy.

By clicking or selecting the “I Agree” button that appears in the pop-up then you are demonstrating to us that you are freely giving us informed and specific consent for us to collect and process your personal information for the purposes specified in this Privacy Policy and you are accepting and consenting to the practices described.

If you do not click or select the “I Agree” button that appears in the pop-up at the top of your screen then we will endeavour to not collect your personal information – this is subject to the caveat below.

If you do not see a pop-up at the top of your screen then you may have already accepted our Privacy Policy and our Cookie Policy. You may also be using a pop-up blocker or similar tools that may prevent this policy from being brought to your attention. Please ensure that any pop-up blockers are disabled when you use our site. We cannot be held liable to you if you use pop-up blocks or similar tools that prevent us from complying with our obligations under the legislation.

Caveat: Even if you do not click or select the “I Agree” button there is still some information that we may automatically collect about you – this normally isn’t personal information but rather technical information sent by your device and used to connect your computer, tablet, or mobile device to the Internet, including your browser type and version, the time when you visit our site, your time zone setting, certain browser plug-in types and versions, operating system and platform. This type of information is sent by you to our site automatically and it isn’t something that we can prevent. We only use this information to administer our site including troubleshooting, load testing, traffic throughput, data analysis, performance testing, and for anonymised research and statistics purposes that we only use internally.

We will only hold your personal information as detailed in our Retention Policy.

INFORMATION WE MAY COLLECT
If you consent to us collecting your personal information then we may process the following data about you:

INFORMATION YOU GIVE TO US:
You may give us personal information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you may provide to us when you register to use our site, search our site, participate in any social media functions on our site, and when you report a problem with our site.

The information you give us may include:
Your name;
Address;
E-mail address;
Phone number;
IP address;
Personal Details of potential attendees and their parents;
Photographs and/or videos.

INFORMATION WE COLLECT ABOUT YOU:
When you visit our site we may collect information about you, including which pages you have visited (including date and time) which services and pages you viewed or searched for, page response times, download errors, files downloaded, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page.

The purpose of this information is to allow us to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, improving our site to ensure that content is presented in the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure.

INFORMATION YOU MAY PASS TO THIRD-PARTIES OUTSIDE OUR CONTROL:
On many of the pages on our site you will see ‘social buttons’. These enable you to share or bookmark pages on our site. These may include buttons for: Twitter, Google+, Pinterest, Facebook or other social features.

In order for us to implement these buttons on our site and connect them to the relevant social networks and external sites, there are scripts that are executed from domains owned by third-parties and outside of our control.

You should be aware that these sites are likely to be collecting information about what you are doing all around the Internet, including on our site. Therefore, if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting our site, and the specific pages you are on, even if you don’t click on the button but are already or automatically logged into their services, like Google and Facebook.

We recommend that you check the respective policies of each of these sites to see how exactly they use your personal information and to find out how to opt out, or delete, such personal information.

HOW WE MAY USE YOUR PERSONAL INFORMATION
When you give us your personal information then we may use it to:

1. Carry out our obligations from any contracts entered into between you and us and to provide you with information that you request from us.
2. Provide you with information about our business or The Edinburgh Academy.
3. To provide you with details of alumni relations and events and other events organised by the Edinburgh Academy Development Department.
4. Ensure that content from our site is presented in the most effective manner for you and for your computer.

If you provide us with your e-mail, telephone or mobile number then we may contact you by these electronic means (e-mail or SMS). However, we will not use your personal information for marketing purposes without your express consent.

If you do not wish to receive any information by electronic means then please get in touch with us.
 

DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, and association entities such as the The Edinburgh Academy, Edinburgh Academy Foundation and the Edinburgh Academical Club. The reason for this is that different parts of the school are responsible for different functions within the school and we need to be able to freely pass your personal information within these various units for operational efficiency.

Although we may share your personal information within members of our group, this does not mean that we will use it for advertising or marketing purposes. Unless you opt-in to receive marketing communication we will not contact you unless it is necessary for us to get in touch with you. For example, we may need to get in touch with you if you asked us to provide you with further information about your potential attendance at one of our events or activities.

Please remember that our Cookies Policy covers matters such as using your personal information for analytics purposes.

In some cases we may disclose information about you with select third-parties:

We may anonymise and aggregate your information with other users (for example, we may track that 500 men aged under 20 have clicked on a specific page on our site on any given day). We may use such aggregate and anonymised information to help reach a particular target audience or understand who uses our site.

Debt collection agencies where you have breached a condition of any contract entered between us and you.

If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about you may be one of the transferred assets.

If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce any agreements with you, or to protect our rights, property, or safety of our pupils, our employees, or others.
 

WHERE WE STORE YOUR PERSONAL INFORMATION
The personal information that we collect from you will be stored within the United Kingdom. We will not knowingly transfer your personal information outside of the European Economic Area. Where it may be necessary for us to transfer your personal information outside of the European Economic Area we will get in touch with us and seek your consent.

All personal information you provide to us is stored on secure servers.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted from our site and any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access. We apply a ‘Privacy by Design’ approach to protecting your personal information in order to promote privacy and data protection compliance from the start.
 

YOU’RE RIGHTS
You have the right to ask us not to process your personal information or to restrict the purposes for which we may process your personal information.

You can exercise your right to prevent processing of your personal information by not selecting or clicking on the “I Agree” button when you visit our site or when you login or create an account on our site.

You can also exercise your right at any time by contacting us. If you consented to us collecting and/or processing your personal information but you change your mind then you can get in touch with us about erasing the personal information we hold about you.

Please be aware that, even if we receive a request from you to delete your personal information, it may be that we cannot entirely remove all of your personal information. This is usually because we have a legitimate interest to hold onto some of that personal information, for example, if you have an ongoing contract with us, there are outstanding payments due by you to us, the personal information relates to a third-party such as a pupil who attends our school, or we have a legal obligation to retain some or all of your personal information – but we’ll let you know.

ACCESS TO INFORMATION
The legislation gives you the right to access a copy of the personal information that we hold about you.

In order to request a copy you need to submit a request – details on how to get in touch can be found at the end of this policy. However, please remember that certain types of data cannot be disclosed to you as part of your request. For example, we cannot disclose information to you which identifies another individual or information that may be subject to legal professional privilege. In many cases we may be required to redact some of the documentation that you receive in order to comply with the legislation.

Additionally, we can’t just release your personal information to anyone. We can only release your personal information to you or an authorised third party who can demonstrate that you consented to have your personal information released – this is a legal requirement. Therefore, it is important for us to ensure that we confirm your identity before we can release any personal information.

If you send us a request to provide you with a copy of your personal information then we may ask you to provide some identification. We may ask you to provide a copy of your current and valid passport and/or driving license plus a utility bill (that is no more than 3 months old) and has your current address. We may also ask you to visit our office or obtain a solicitors or notary publics’ confirmation of your identification.

All of this might sound very onerous but please understand that we have an obligation to protect your personal information and we need to be certain that it is being released to the right person.

WHAT IF I DO NOT CONSENT OR WITHDRAW CONSENT?
If you do not consent to us collecting your personal information then we cannot guarantee the full functionality of our site and cannot be held responsible or liable to you for any reduction or restriction in access to our site or any of our other services.

Our site may, from time to time, contain links to and from the sites of our partners and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these sites.

HOW LONG WILL YOU HOLD ONTO MY PERSONAL INFORMATION?
Depending on how you engage with us it may be necessary for us to store your personal information for shorter or longer periods of time. Either way, we will only store your personal information for a legitimate and lawful reason. Please remember that this Privacy Policy only applies to how we may collect, store, use, and retain your personal information when you visit our site.

You can find details on how long we may hold onto your personal information on our Retention Policy.

CHANGES TO OUR PRIVACY POLICY
We may need to change this Privacy Policy if it’s necessary for legal reasons or to reflect changes to our site and services. In any case, the provisions of this Privacy Policy may be changed without prejudice to your rights. When we change our Privacy Policy we will make the updated Privacy Policy available on our site and we will also update the “Last Updated” date.

Once we change our Privacy Policy, it will become legally binding on you 30 days after we post it on our site. During that period you’re welcome to contact us if you have questions about the changes.

If you don’t agree with our changes to the Privacy Policy (regardless of whether you get in touch with us) then unfortunately we may need to restrict or limit your use of the parts of our site that require your personal information in order for us to deliver our services to you. We’re sorry we have to say that, but we hope you’ll appreciate that in order for certain parts of our site to work properly and in order for us to identify you in connection with our services we need to have everyone using our site and our services under the same rules instead of different people having different rules – that’s why we encourage you to get in touch with us if you have queries.

CONTACT US
This Retention Policy was prepared with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our retention of your personal information. However, we are happy to provide additional information or explanation needed.

If you have any questions, comments or requests regarding our Retention Policy then please do not hesitate to get in touch with us. To make things easier for both of us we would appreciate it if your queries were addressed to:

The Edinburgh Academy Trading Company Ltd.
42 Henderson Row
Edinburgh
EH3 5BL
United Kingdom

info@accessea.co.uk

+44 (0)131 6244920 

COMPLAINTS
If you are not satisfied with the way that we have handled any of your requests or queries relating to our use of your personal data then you can contact the Information Commissioner’s Office at www.ico.org.uk. The Information Commissioner’s Office is the statutory body responsible for overseeing data protection legislation and law in the United Kingdom.

 

 

AccessEA, The Edinburgh Academy Trading Company Ltd, as employers, will ensure, so far as is reasonably practicable, the health, safety and welfare of all its employees, during the course of their working activities.

AccessEA also accepts the responsibility for the health, safety and welfare of all pupils; persons contracted to carry out work on AccessEA premises, authorised visitors or any stakeholders so far as they may be affected by the activities of AccessEA.

To ensure the above, it is the policy of the AccessEA:

To provide and maintain plant and systems of work that are, so far as is reasonably practicable, safe and without risks to health.

To ensure, as far as is reasonably practicable, the safety and absence of risk to health in connection with the use, handling, storage and transportation of articles and substances.

To provide such information, instruction, training and adequate supervision, as is necessary, to ensure, so far as is reasonably practicable, the health, safety and welfare of staff, visitors, course attendees and all other stakeholders. 

Where we undertake construction projects, and commercial events on site all responsibilities will be written into contracts with third parties. We will ensure all activities are planned and implemented safely and professionally, with effective segregation maintained to safeguard staff and the public.

To ensure, so far as is reasonably practicable, the provision of a safe place of work, with safe access and egress.

To provide and maintain a healthy working environment including adequate welfare facilities. It should be noted that the Health & Safety at Work etc. Act 1974 places, upon employees, the duty to take reasonable care for the health and safety at work of themselves, as well as of others, who may be affected by their acts or omissions.

Employees must also co-operate with their employer, so far as is necessary, to enable any duty or requirement imposed on the employer by any relevant statutory provisions to be performed or complied with. They must not interfere recklessly with or misuse anything that is required by law to be provided for health and safety.

The allocation of duties, with regard to health and safety, and the particular arrangements laid down by AccessEA, as employer, to implement the Policy, are set out in the following parts of the Health & Safety Policy. The Policy will be kept up-to-date.

To ensure this, the Policy and the way in which it has operated will be reviewed annually, or sooner, if necessary, to keep abreast of changing legislation and AccessEA requirements.

COVID-19 SECURE POLICY
COVID-19 means that we have to do things differently. And, as guidance is updated and evolves, we’ll keep changing things to make sure we are following the latest advice and have the most appropriate measures and systems in place.

There are three key prongs to our COVID-19 approach. The AccessEA ‘three As’ are: Advance Planning, Adjustments and Assessment

Advance planning:
1. We’ve reduced the number of places at our camps in line with the latest COVID-19 advice.
2. We’ve put in one-way signage and hand-washing stations at camp venues and asked that people don’t come into the reception area if there are already two people there.
3. We’ve set up an isolation area on site for children or team members should they become ill at camp.

Adjustments
1. We wear face masks when greeting parents and children at drop off and when administering first aid.
2. We’ve changed some camp activities so they fall in line with advice about COVID-19, especially if they are inside.
3. We clean and sanitise facilities and equipment more frequently.

Assessments
1. We’re continually assessing our processes and looking at what we can do to stay ahead of the COVID-19 pandemic.
2. We ask that parents and carers check the health of their child before attending camp to make sure they have no COVID-19 symptoms.
3. Our team take regular lateral flow tests to make sure they are COVID-19 free.