Platform Privacy Policy

SUPPLY CLOUDS PRIVACY NOTICE

Supply Clouds Development Ltd (“Supply Clouds”, “we”, “us” or “our”) is a company registered in England and Wales with company number 09645746 and a registered address at 1 Blease Close, Staverton, Wiltshire, BA14 8WB, United Kingdom.

  1. PURPOSE OF THIS PRIVACY NOTICE
    • When you visit Supply Clouds’ website or native app (our “Platform”), we will collect, store and process certain personal data. This privacy notice (“Privacy Notice”) sets out the basis on which the personal data collected from you, or that you or the Agency provides to us, will be processed by us. Please read the following carefully to understand how we will use your personal data.

1.2        This website is not intended for children and we do not knowingly collect data relating to children.

  1. DATA PROCESSOR
    • Other than in respect to your Session Data and Cookie Data, for the purpose of Data Protection Laws in the UK, we are a processor of your personal data. We shall be the data controller in respect to the Session Data and Cookie Data.
    • We process your personal data on behalf of the employment agency with which you have an agreement (“Agency”). In this capacity, we are required to process your “personal data” (which has the meaning as set out in the Data Protection Act 1998 and, following 25 May 2018, the General Data Protection Regulation (the “Data Protection Laws”)) in accordance with the instructions of the Agency.
    • If you have concerns around the processing of your personal data please contact us, or the Agency.
  2. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?
    • When you visit our Platform, you, the Agency, or the relevant school may provide us with the following types of personal data, and we may collect and process such personal data in accordance with in this Privacy Notice, as follows:
      • Contact Data: This includes some or all of your name, email address, phone number, the type of mobile device on which you access the Platform and your GCM sender ID (which is a unique iOS or Android identifier for your mobile device).
      • Account Data: If you create an account on our Platform in order to benefit from our services, this includes some or all of your name, email address, phone number and your photograph.
      • Correspondence Data: Where we provide you with the opportunity to do so, this includes some or all of your views, opinions and feedback together with information we may request from you, which you choose to provide in relation to the Platform and our services.
      • Agency Data: This is the identity of the Agency with which you are connected.
      • Professional Data: This includes some or all of the main academic subject you teach, any additional academic subjects you teach, together with your professional qualifications.
      • Legal Status Data: This includes some or all of your qualified teacher status, your right to work certification, information from the Disclosure and Barring Service and a form of identification (passport, driver’s licence or ID card).
      • Reference Data: This includes some or all of your professional references and your curriculum vitae.
      • Location Data: This is your last known position.
      • School Data: This is the start and end time for each supply teacher job posting, together with any other relevant information, as provided by the relevant school.
      • Session Data: This includes some or all of your IP address, your GCM sender ID (which is a unique iOS or Android identifier for your mobile device), browser details including version, device operating system, time zone setting and time/date of access requests, the amount of data transmitted and the requesting provider. We may also capture other information about visits to our Platform such as pages viewed and traffic patterns. We are the data controller in respect to the Session Data.
      • Cookie Data: Cookies are small files which are downloaded to your device when accessing our platform. Most web browsers automatically accept cookies. Please refer to paragraph 7 below for full details about our use of cookies. We are the data controller in respect to the Cookie Data.
    • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Session Data to calculate the percentage of users accessing a specific website feature.
  3. CHANGES TO YOUR PERSONAL DATA

It is important that the personal data we hold about you is accurate and current. Please keep us informed, by updating your Supply Clouds account, if your personal data changes during your relationship with us.

  1. HOW DO WE USE YOUR PERSONAL DATA?
    • We use your personal data in the following ways:
      • We use your Contact Data to:
        • respond to communications that you send to us. The legal basis for such processing is your and the Agency’s legitimate interests;
        • enable us to push notifications to your mobile phone (using your GCM sender ID). The legal basis for such processing is for the performance of the contract between you and the Agency;
        • notify you of changes to this Privacy Notice. The legal basis for such processing is to comply with a legal obligation; and
        • market products and services to you only where you have requested that we do so, or otherwise provided your explicit consent either directly to us or through the Agency. The legal basis for such processing is that you have consented to us doing so.
      • We use your Account Data to enable you to use our services, administer your account with us and to enable us to identify you. The legal basis for such processing is for the performance of the contract between you and us.  Please note that to fully benefit from the use of our Platform you may also need to provide the Agency Data, Profession Data, Legal Status Data and Reference Data.  The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Correspondence Data to help address issues you raise with us and to improve the Platform and our services. The legal basis for such processing is your and the Agency’s legitimate interests.
      • We use your Agency Data so that you can create a user profile and enable us to advertise your services to schools, including enabling schools to screen candidate teachers on the basis of Agency the candidate teacher is registered with. The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Professional Data so that you can create a user profile and enable us to advertise your services to schools. The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Legal Status Data so that you can create a user profile and enable us to advertise your services to schools. The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Reference Data so that you can create a user profile and advertise your services to schools. The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Location Data to notify schools of your location during normal school opening hours. You may choose to activate and deactivate this functionality whenever you choose by clicking on the “Location On/off” toggle in the Platform or by turning off location services on your mobile device.  Please refer to https://supplyclouds.com/teacher-app-tutorials/ and select “Video #4 (location settings)” for instructions.  The legal basis for such processing is that you have consented to us doing so.
      • We use School Data to enable you to search relevant supply teacher job postings. The legal basis for such processing is for the performance of the contract between you and the Agency.
      • We use your Session Data to administer, maintain and improve the Platform and our services. The legal basis for such processing is our legitimate interest.
    • Where we need to collect personal data by law, or under the terms of a contract we have with you, or between you and the Agency, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services available through the Platform). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
    • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@supplyclouds.com.
    • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
    • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  2. PERSONAL DATA RETENTION
    • We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    • We shall store your personal data in line with legal, regulatory, financial and good-practice requirements.
    • Below we have set out how long we retain the various types of personal data we collect via our Platform:
Type of personal data Retention period Reason for retention
Contact Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Contact Data for the purpose of administering your account with us.
Account Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Account Data for the purpose of administering your account with us.
Correspondence Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Correspondence Data for the purpose of administering your account with us.
Agency Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Agency Data for the purpose of administering your account with us.
Professional Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Professional Data for the purpose of administering your account with us.
Legal Status Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Legal Status Data for the purpose of administering your account with us.
Reference Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Reference Data for the purpose of administering your account with us.
Location Data We retain the last known location until the earlier of: (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; (ii) the Agency instructing us to delete such data; and (iii) you delete the app from your mobile phone. We need to retain your Location Data for the purpose of administering your account with us.
School Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your School Data for the purpose of administering your account with us.
Session Data Until the earlier of (i) the termination/expiry of the agreement between Supply Clouds and the relevant Agency; and (ii) the Agency instructing us to delete such data. We need to retain your Session Data for the purpose of administering your account with us.

 

  1. COOKIES
    • Our Platform uses the following categories of cookies:
      • Strictly necessary cookies: These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to load webpages.
      • Analytical/performance cookies: These cookies allow us to recognise and count the number of visitors to our Platform and to see how visitors move around our Platform. This helps us to improve the way our Platform works, for example, by ensuring that visitors are finding what they are looking for easily.
    • You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

 

Cookie name

 

Category Description Expiry Period
_ga Analytical/performance cookies Google Analytics tracking cookie 2 years
XSRF-TOKEN Strictly necessary cookies Security cookie used to verify that the authenticated user is the one actually making the requests to the platform 2 hours
laravel_session Strictly necessary cookies Used to identify a session instance for a user 2 hours

 

  • Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.
  • You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.
  1. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
    • We may need to share your personal data with selected third parties in the following limited circumstances:
      • Third party service providers: This may include providers of certain systems and services that we use to host, administer and maintain our Platform, including for example the servers used to host our Platform. This includes our developers, Platform Twenty Limited.
      • Third party service providers for marketing purposes: If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms.
      • To comply with legal or regulatory requests: If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.
      • Prospective buyers or sellers: In the event that Supply Clouds Development Ltd buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Supply Clouds Development Ltd (or substantially all of its assets) is acquired by a third party, your personal data held by Supply Clouds Development Ltd, or within such assets, may be transferred to such third party.
  1. PRACTICES REGARDING EXTRA-EU TRANSFERS OF PERSONAL DATA
    • We will not transfer your personal data outside of the EU, except to selected third party service providers as set out in paragraph 8 above, for example if we utilise cloud-based platforms to store personal data, which may involve use of geographically distributed data centres.
    • In the case of these extra-EU transfers, where the transfers are not to countries that provide an adequate level of protection (for example, relying on a Privacy Shield certification where the transfer contains a US entity), we will use reasonable efforts to put in place appropriate safeguards to cover transfers of personal data including, for example, signing standard contractual clauses and/or data protection clauses adopted by the European Commission.
    • If there are any other circumstances which would require us to transfer personal data outside of the UK, we will seek your consent to transfer your personal data outside of the UK. In the event of such a transfer, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity.
  2. THIRD PARTY WEBSITES

Our Platform may contain links to third party websites. If you follow a link to a third party website, please note that this Privacy Notice does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

  1. YOUR LEGAL RIGHTS
    • As a result of us collecting and processing your personal data, you have the following legal rights:
      • to access personal data we hold on you;
      • to request us to make any changes to your personal data if it is inaccurate or incomplete;
      • to request your personal data is erased where we do not have a compelling reason to continue to process such personal data in certain circumstances;
      • to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the personal data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
      • to object to, or restrict, our processing of your personal data in certain circumstances;
      • if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
      • if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
      • to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
      • to lodge a complaint with a data protection supervisory body, which at present, is the Information Commissioner’s Office.
  1. ACCESSING YOUR PERSONAL DATA
    • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
  2. CONTACTING US
    • If you have any questions or comments about this Privacy Notice or your personal data, or if you want to exercise any of your rights, including as set out in paragraph 11 above, or you wish to withdraw your consent where we have stated we are processing your personal data based on your consent, then please contact Supply Clouds Development Ltd at:
      • e-mail us at: info@supplyclouds.com; or
      • write to us at: Supply Clouds, 1 Blease Close, Staverton, Wiltshire, BA14 8WB, UK.
  1. CHANGES TO THIS PRIVACY NOTICE
    • Any changes we may make to this Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Notice.
    • This Privacy Notice was last updated in May 2018.