Thrive Privacy Policy

Your Privacy

At Thrive we are committed to ensuring the security and confidentiality of any personal information that we hold. Our website has been set up to assist schools, academies and other organisations, as well as parents and guardians, to obtain further information relating to the Thrive Approach.

We also operate a portal for our members to access their training records and book our courses.

What is the purpose of the Privacy Policy?

Our website is owned and operated by Fronting the Challenge Projects Limited, The Quadrangle, Seale Hayne, Newton Abbot, Devon, TQ12 6NQ.

If you have any queries about the information that we collect on our website, please contact our Data Protection Officer who can be contacted on dpo@thriveapproach.com.

Our website contains a number of pages where you can provide us with information, for example, when you register with us or when you fill in one of our contact forms.

This Privacy Policy relates to your use of website and tells you:

  • What personal information we collect about you
  • How we collect your personal information
  • How we use your personal information
  • Who we may share your personal information with
  • Any transfer of personal information outside of the EEA
  • How long we keep your personal information
  • What we do to protect your personal information
  • What choices you have in relation to your personal information

We last updated this Privacy Policy on 10th May 2018.

Personal Information we process about you

What personal information we process about you

Personal Information you give us

We may collect the following information about you:

  • Name and address
  • Email address and telephone number
  • Information about the Organisations you work with
  • Information about your training with Thrive
  • Information about your qualifications and experience
  • Information you give us in order for us to provide training to you (e.g. dietary requirements)
  • information about your use of the Website (e.g. what you have read and what actions you have taken)

Children

Thrive-Online is not intended for use by individuals under the age of 18 years and so if you are under this age please do not provide any personal information to us without the consent of your parent or guardian. As a parent or legal guardian please do not allow your children to submit personal information without your permission.

Sensitive Personal Information

Whilst we do not intend to collect sensitive personal information, this may occur inadvertently and an infrequent basis (e.g. if you tell us about a dietary requirement which reveals information about a medical condition).

If this occurs, we will have given you clear and explicit information about why we need the information and we shall only use the information for the purposes for which you gave us the information and then permanently delete it from our systems.

Personal Information we collect automatically

When you use the website, we may collect certain information automatically such as:

  • IP addresses (the name and internet address your device uses to identify itself to us)
  • Your activity in our website including times and dates of visits
  • Information on your location
  • Other websites you may have visited

If you want to know more about how we use cookies, please see our cookie statement.

How we collect your personal information?

When you contact us

We may collect personal information from you when you:

  • ring us.
  • fill in one of our paper forms at a course or event
  • complete a form online
  • register online
  • enter information into your user account
  • your organisation requests us to provide services e.g. training

Statistics

We may use personal information to produce statistics. We anonymise these statistics so that no individual can be identified from them. We use the statistics to help us improve our services and to plan for new services.

Research

We may also ask members to complete surveys and we use the information that provided for research purposes and in particular to find out how we can improve our services. You do not have to respond to a survey and can request that we stop sending them.

Marketing

We may send information about other services of ours which may be of interest to you. You have a right at any time to stop us from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please email dpo@thriveapproach.com.

How we use your personal information?

Our legal basis for using your information

The law only allows us to use your personal information in certain limited circumstances. We will most commonly use your personal information:

  • Where we need to perform the agreement we entered into when you became a member or any subsequent request (e.g. supply you with training)
  • Where we have consent (e.g. where you consented to receiving information from us)
  • Where we need to comply with a legal obligation (e.g. the provision of education)
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. to produce statisitics)

What this means in practice?

Any personal information that you give to us may be used to:

  • contact you with the information that you requested
  • book on a course or online seminar
  • manage online accounts for school, academy or other organisation employees
  • prevent and detect fraud
  • tell you about changes to our website or software
  • help us improve the Website to make it better for all users
  • get your feedback on the Website
  • administer the Website (such as troubleshooting, data analysis, research)

Sharing your personal information

Business Partners

We may need to share your information with the following third parties:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • We do not share information for marketing purposes.

Details of some organisations we work with

We work with the following organisations:

Legal Requirements and Law Enforcement

We may also disclose your personal information to third parties:

  • If we sell our business in which case the personal information that we hold will be part of the transferred assets.
  • If we are required by law, or in order to enforce or apply our terms of use. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Third Party Privacy Policies

Our website may contain links to websites owned by other organisations. If you follow a link to another website, these websites they will have their own privacy policy. We suggest that you check the policies of any other websites before giving them your personal information as we cannot accept responsibility for any other website or App.

Keeping your Personal Information

How we store your personal information

The security of your personal information is really important to us. We use appropriate technical and organisational measures to safeguard personal information. We use encryption technology where appropriate to enhance privacy and help prevent information security breaches. We use industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.

Any personal information that you provide to us will be held within the EEA.

All third parties who provide services to the Website or in relation to Personal Data are required to sign contract requiring them to have appropriate technical, administrative and physical procedures in place to ensure that your information is protected against loss or misuse.

All information you provide to us is stored on our secure servers or on secure servers operated by a third party.

Retention of information

We only hold your personal information for as long as necessary for the purposes for which we collected your information.

We have a company retention policy which lays down timescales for the retention of information.

 

Type of InformationDescription of InformationRetention Period
Thrive-Online (TOL) dataNames and dates of birth of children; name and email addresses of TOL users; names, email addresses & mobile numbers of TOL app users12 years after the last record has been created.
Thrive Administration and Booking System (TABS)Name and contact details of all customers and some suppliers including emails, addresses and telephone numbers.5 years after record creation

We have set these timescales in accordance with any applicable legislation and, where none exists, we will keep your information for the duration of your employment (or services contract) and then for a period of 7 years after which time it will be deleted.

Emails

If you chose to send us information via email, we cannot guarantee the security of this information until it is delivered to us.

Your rights

Access to information

You have the right to access information that we hold about you. If you wish to receive a copy of the information that we hold, please contact at dpo@thriveapproach.com or write to us at the address at the bottom of the page.

Changing or deleting your information

You can ask us at any time to change, amend or delete the information that we hold about you or ask us not to contact you with any further marketing information. You can also ask us to restrict the information that we process about you.

You can use the check boxes on the forms we use to collect your information, or you can also request that we change, amend, delete your information or restrict our processing by emailing us at dpo@thriveapproach.com or writing to us at the address at the beginning of this Privacy Policy.

Right to prevent Automated decision making

You have a right to ask us to stop any automated decision making. We do not intentionally carry out such activities, but if you do have any questions or concerns we would be happy to discuss them with you and you can contact us at dpo@thriveapproach.com .

Transferring Personal Information

You have the right to request that your personal data is transferred by us to another organisation (this is called “data portability”). Please contact us at dpo@thriveapproach.com with the details of what you would like us to do and we will try our best to comply with your request. If may not be technically feasible, but we will work with you to try and find a solution.

Complaints

If you make a request to us under this Privacy Policy and you are unhappy with the response, you can ask for the request to be reviewed under our internal complaints procedure. Our internal complaints procedure allows your request to be reviewed by the IT Services Manager who will do their best to try and resolve the issue.

If you have been through the internal complaints procedure and are still not happy with the result, then you have the right to complain to the Information Commissioner’s Office. They can be contacted as follows:

Website: www.ico.org.uk

Telephone: 03031231113

Address: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Changes to our Privacy Policy

We review our Privacy Policy on a frequent basis to check that it accurately reflects how we deal with your information and may amend it if necessary. You should check this page regularly to see the most up to date information.

How to Contact us

We welcome questions, comments and requests regarding this Privacy Policy which can be sent to dpo@thriveapproach.com .