20th July 2018
- Introduction and General Terms
The Key is committed to protecting your personal information when you are using The Key services. We want our services to be safe and useful environments for our audience. This Privacy Notice applies to information held about you and individuals connected to your school by The Key as data controllers and processors, as described below. This Privacy and Cookies Policy relates to our use of any personal information we collect from you via the following online services:
- any The Key website that links to this Privacy and Cookies Policy;
- social media or official The Key content on other websites;
- mobile devices or applications;
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters, other correspondence and in person. In order to provide you with the full range of The Key services, we sometimes need to collect information about you.
This Privacy and Cookies Policy explains the following:
- what information The Key may collect about you;
- how The Key will use information we collect about you;
- when The Key may use your details to contact you;
- whether The Key will disclose your details to anyone else;
- your choices regarding the personal information you provide to us;
The Key is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information, including the Data Protection Act 1998 and the General Data Protection Regulations which come into effect on 25th May 2018. These laws are referred to collectively in this policy as the “data protection laws”.
No website can be completely secure; if you have any concerns that your The Key account could have been compromised e.g. someone could have discovered your password, please get in touch straight away.
We may need to update the sites and this policy at any time and without notice. Where you have given us your email address, we may use this to notify you of such changes and we will post a note on the sites to inform you that this policy has been updated. Please check this policy regularly to ensure you always understand how we use your information.
- Your Account
When you sign up for a free trial or register as a user on our sites under a membership you are providing us with personal information. As such you should not allow others to access your account, for example by sharing your login details with a colleague. All members of your school are entitled under the licensing agreement to set up their own account which they can do on the sites or by contacting the team on 0800 061 4500. For full license terms and conditions please click here.
- Who are we?
We are The Key Support Services Limited (trading as The Key), a company incorporated under the laws of England and Wales with company number 08268303 whose registered office is at 10 East Rd, Old Street, London N1 6AD – telephone number 0800 061 4500. If you have any queries about how we use your data, please contact our data protection officer at email@example.com
- What information will The Key collect about me?
We’ll only collect your information and information relating to individuals connected to your school in line with the relevant regulations and law. We may collect it from a range of sources and it may relate to any of our products or services you currently use or have used in the past.
We may collect data about you through:
- Account set up when registering for a free trial or when you take out membership of one of our products or services or create a new use account under an existing school membership
- Signing up to access free content or to receive newsletters
- Entering competitions
- Live chats, web and mobile notifications
- Telephone and email conversations
- Booking an event tickets
- Market research
We may also collect information about you and individuals connected to your school when you or they interact with us, e.g. visit our websites or mobile channels, call us or ask about any of our products and services. Some of this information will come directly from you and individuals connected to your school. We might also get some of it from publicly available sources.
The types of information we collect about you may include:
- Your name and job title
- Work or personal email addresses
- Home or work postal address
- Telephone or mobile numbers
The Key collects information about how you use The Key’s websites and Key mobile app or other The Key content online, and the device(s) you use to access the services. This includes:
- Collecting unique online identifiers such as IP addresses (which are numbers that can uniquely identify a specific computer or other network device on the internet)
- Your use of The Key’s services, such as what you read, what pages and content you visited or documents you download.
- How will The Key use the information it collects about me?
We’ll only use information on you and individuals connected to your school where we have consent or we have another lawful reason for using it. These reasons include where we:
- Need to pursue our legitimate interests
- Need to process the information to carry out an agreement we have with you
The reasons we use your information and information relating to individuals connected to your school include:
- Delivering our products and services
- To provide you with the most user-friendly online navigation experience
- Where we provide personalised services, we may analyse the information you supply, as well as your activity on our sites so that we can offer a more relevant, tailored experience.
- Managing our relationship with you, including (unless you tell us otherwise) telling you about products and services we think may be relevant for you
- Understanding how you use our content, products and services
- Undertaking content, product and service improvement
- Carrying out your instructions (e.g. setting up an account or resetting your password)
- Providing membership operations support
- Providing security and business continuity
- Undertaking risk management
- Providing our mobile app
- Protecting our legal rights and complying with our legal obligations
- To use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits from different regions or countries.
- We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes
We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter). This could involve showing you an advertising message where we know you have a The Key account and have used The Key products or services. If you don’t want to be shown targeted advertising messages from The Key, some third party sites allow you to request not to see messages from specific advertisers on that site in future, or contact us to request removal at firstname.lastname@example.org or call 0800 061 4500.
- How we make decisions about you?
We may use automated systems to help us make decisions, for example helping us to identify the relevancy of products or services to new or existing members or non-members or to help us understand the renewal risk profile of a group of members or an individual school or account. Individuals may have a right to certain information about automated decisions we make about them and may also have a right to request human intervention and to challenge the decision. More details can be found in the ‘Rights of individuals’ section below.
- When will The Key contact me?
The Key may contact you:
- In relation to any service, activity or online content you have signed up for, in order to ensure that The Key can deliver the services, e.g. to verify an additional user on your school’s account, or to help you reset your password;
- In relation to any correspondence we receive from you or any comment or complaint you make about The Key products or services
- In relation to any tailored services you are using
- To invite you to participate in surveys or research about The Key’s current or potential products and services (participation is always voluntary)
- To update you on any material changes to The Key’s policies and practices
- For marketing purposes, as set out in section 8.
- Will I be contacted for marketing purposes?
From time to time we may send you marketing communications which we believe may be of interest to you. We may use your information and information relating to individuals connected to your school to provide information about other The Key products and services, and also products and services from our partners and other relevant third parties. We may send marketing messages by post, email, telephone, text, in app or other The Key platforms. You may opt out of receiving marketing by amending your preferences. You can do this by calling the team on 0800 061 4500, emailing us at email@example.com, or by clicking the link on any marketing emails we may send you.
- Will The Key share my personal information with anyone else?
We may share your information and information relating to individuals connected to your school with other companies in our group, for example ScholarPack, for the purpose of our legitimate business interest or another lawful basis. We will always ensure that your data is managed in accordance with this policy.
We may share your information and information relating to individuals connected to your school with others where lawful to do so including where we or they:
- Need to in order to provide you with products or services you’ve requested (e.g. fulfilling a payment request)
- Have a public or legal duty to do so
- Need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
- Have a legitimate business reason for doing so
- To provide you with services you’ve requested,
- Have asked you or the individuals connected to your business for your permission to share it, and you (or they) have agreed.
In addition, we hope we will continue to expand. So, eventually, we may have additional group companies (we will all be owned by the same company, though). If this happens, we may want to share your information around our group so they can use it for the same internal purposes as we do, as described in this policy (for example marketing where we think this might be of interest to you or we might want to store our data on one server).
It is possible that we could sell our business to a third party, or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business, so we would need to share it with the buyer and their advisers.
Sometimes, other people give us data about you which we may need for our legitimate business purposes. This may happen when you use another website that we link to. For example, we may link through to third-party payment providers. They tell us that you have paid for your products. We also might engage third-party contractors to provide us with technical or delivery services that are related to your account with us. We may have to conduct credit-referencing checks where this is a condition of our contract with you.
Generally, we will use your information within The Key. However, we may share with third party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter) some data, with appropriate security measures, to show you relevant advertising on third party sites.
Sometimes The Key uses third parties to process your information on our behalf, for example to provide services or analysis. The Key requires these third parties to comply strictly with its instructions and The Key requires that they do not use your personal information for their own business purposes, for a full list of third parties please see section 18.
- Will other Permitted Users be able to see my data?
Permitted Users at your school can view certain information relating to your school’s information in the ‘My school’ section of certain of the sites, for example Compliance Tracker. This section includes a list of all the other Permitted Users at your school, including their first name, surname and role. This allows Permitted Users to see which of their colleagues are also registered, and to ensure they are eligible, in line with our General Terms and Conditions.
On occasion, or upon receiving a request, we will email the lead user and/or the individual (or body) who authorised or organised membership on behalf of your school, to inform them that a new Permitted Users has registered with us. This is intended to help ensure that people who register are eligible to use the service.
Some of our products offer a function to comment on an article or to add your own notes. Depending on the product, you may be asked for your permission to display your name, role and school, and you may be able to withhold this permission and instead be acknowledged anonymously using your role and a general description of your type of school and its broad geographical location (for example, headteacher, secondary school, East of England). Please check the individual products for details. Please note that our Compliance Tracker product does not offer a function for notes and comments to be private, as these need to be visible to the other Permitted Users for this product from your school.
- Sharing aggregated or anonymised information
We may share aggregated or anonymised information within and outside of The Key, with partners such as research groups, policy groups, the DfE, or Ofsted. Neither you nor individuals connected to your school will be able to be identified from this information.
- Offensive or inappropriate content on The Key websites
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on or to The Key websites or otherwise engage in any disruptive behaviour on any The Key services, The Key may remove such content.
Where The Key reasonably believes that you are or may be in breach of any applicable laws, for example on hate speech, The Key may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. The Key would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection law.
- How long will The Key keep my information?
We’ll keep information in line with our data retention policy. For example, we’ll normally keep your core information for a period of seven years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as managing your subscription or account. If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.
- How we protect your data
All information you provide to us is stored on our servers, and we have implemented reasonable and appropriate security measures to protect the data including HTTPS and the industry standard for encryption and SSL technology. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee that data breaches will never occur. Please keep your password safe and log out of inactive sessions.
For safety purposes, we may require users to verify their accounts (because we want to make sure you are not a robot, and are eligible to register for an account with us) and we might ask for your phone number, credit-card number, separate email address or for other ways to verify your identity. We won’t use this information for unexpected reasons.
We also do not recommend that you put email addresses, URLs, phone numbers, full names or addresses, credit-card details or other identifying or sensitive information in any online chat function on the sites.
- Your rights
You have a number of rights in relation to the information that we hold about you under the data protections laws. These rights include:
- The right to access information we hold about you and to obtain information about how we process it
- In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so
- In some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
- The right to request that we rectify your information if it’s inaccurate or incomplete
- In some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it
- The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing it and/or to refuse your request. You and individuals (including individuals connected to your school) can exercise your rights by contacting us at firstname.lastname@example.org
- Individuals also have a right to complain to the UK Information Commissioner’s Office by visiting www.ico.org.uk, or to the data protection regulator in the country where they live or work.
- You have the right to ask us not to process your data for marketing purposes at any time by contacting us in the usual way or emailing us at email@example.com or calling 0800 061 4500.
- You have the right to access information we hold about you. Simply email us at firstname.lastname@example.org and we will tell you how to do this.
- What are Cookies?
A cookie is a piece of text stored on the hard drive of your computer, mobile phone or other portable device by your web browser. Broadly, this tool distinguishes you from other visitors to our websites and stores information about your website visits, recognises you and your preferences each time you visit our websites, and ensures each site functions for you as we intend it to and enables us to provide the services you request.
There are different types of cookies:
These are specific to your browsing session and expire when your browser is closed or when you leave the site. These cookies ensure that you are recognised when you move from page to page within the sites, and any information entered is remembered.
These cookies remain, even when you have closed the browser. These cookies remember information such as your login details, so you don’t have to type them in every time you use the sites. Permanent cookies are stored on your device (browser or mobile device), and expire at a fixed point in time, or until you choose to delete them.
First and Third-party cookies
First-party cookies are those set by The Key. Third-party cookies are placed by third party sites and are typically persistent. These cookies gather information on user activity, so that the sites can remember something about you at a later time, such as personalisation preferences or collecting statistics so that The Key can improve the sites. Unless you choose to tell them, the third party sites will never know who you are even if they assign your browser a cookie.
These cookies also have different functions:
These cookies collect information about how visitors are using the sites, e.g. which pages are most popular, when errors are being generated and testing different designs. Additionally, performance cookies allow us to count the number of visitors and measure how effective advertising metrics, user experience and site performance.
These cookies allow The Key to provide services, such as live chat, and remember choices you have made, so that we can better serve personalised content to you.
Strictly necessary cookies
These cookies are required for the sites to perform correctly, e.g. allowing you to use your credentials to register, log in and access member-only articles and resources.
Targeting and/or advertising cookies
These cookies track your visits to the sites, the links you have clicked and the articles you have viewed. The Key uses this information to target and personalise our advertising, so that is more relevant to your needs.
- Can I refuse cookie tracking?
Most web browsers allow some control of most cookies through the browser settings. If you turn off cookies, you may not be able to use all of our services. However, you will still be able to see article content.
The Key is committed to protecting your data and the information we collect about you online. You can withdraw your consent to accept cookies through settings on some of the most popular browsers, using the links below.
- What cookies does The Key use?
Below are two tables to explain The Key‘s cookie functions and why they’re used. They are placed on your device automatically when you visit the sites. Some last only for the duration of your visit (session ID cookies) and these help you navigate the sites and use your browser ‘back button’, for example. Others are persistent and last after you leave the sites.
The following are first-party cookies used on the sites.
|The Key authentication||Our system may issue cookies to your computer when you log on to the Sites. Cookies make it easier for you to log on to and use the Sites during future visits as they will remember your IP address and the settings associated with it. They also allow us to edit the content of the Sites for you so that you see information that is relevant to your chosen subscription and account settings.||https://thekeysupport.com/privacy-policy|
|The Key performance||We need to use certain cookies and local storage devices to ensure users of the Sites have the best possible experience, such as assisting with your navigation, ensuring pages load up quickly and respond faster to your requests, and so that you find what you are looking for easily.||https://thekeysupport.com/privacy-policy|
The following are third-party cookies used on the Sites.
|Google Tag Manager||We use Google Tag Manager to manage tags, cookies and triggers, for marketing and analytical purposes||https://policies.google.com/privacy||Check browser settings|
|Google Adwords||We use Google Adwords to advertise products, campaigns and the Sites to new and returning users.||https://policies.google.com/technologies/ads||www.google.com/settings/ads|
|Google Optimize||We use Google Optimize to place users into AB testing experiments, website testing & enhanced personalisation.||https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage||Check browser settings|
|DoubleClick||We use Doubleclick in order to build a detailed view of your interests, so that we may show you relevant adverts.||ttp://www.google.co.uk/policies/privacy/ads/||www.google.com/settings/ads|
|Vimeo||We embed videos from our private Vimeo channel, a service provided by Vimeo, LLC (Vimeo).||http://vimeo.com/privacy||https://vimeo.com/cookie_policy|
|YouTube||We embed videos from YouTube using the privacy-enhanced mode.||https://www.youtube.com/static?template=privacy_guidelines&gl=GB||Check browser settings|
|Hotjar||We use Hotjar to aggregate data on how visitors to the Sites are using them, building sample heatmaps of scrolling, clicking and mouse movement||https://www.hotjar.com/legal/policies/privacy||https://www.hotjar.com/opt-out|
|Hubspot||We use Hubspot to identify site visitors, analyse the performance of email campaigns, track contact form submissions, evaluate paid media activity and monitor clicks through to landing pages.||https://legal.hubspot.com/privacy-policy||Check browser settings|
|Keen IO||We use Keen IO to store data on user activity on the Sites.
Keen IO is an analytics service provided by Keen Labs, Inc. (Keen IO) that helps improve web applications by tracking how users interact and engage.
|Embedly||We use Embedly, a media platform provided by Embedly, Inc. (Embedly) to embed videos and media from other websites.||http://embed.ly/legal/privacy||Check browser settings|
|Zendesk||We use Zendesk Support, Help Centre, Talk and Chat, customer service software provided by Zendesk, Inc. (Zendesk) to allow users to contact our member support team.||https://www.zendesk.co.uk/company/customers-partners/privacy-policy/||http://www.youronlinechoices.eu/|
|Social networks||We use Facebook, LinkedIn and Twitter remarketing and advertising to advertise our content to new and previous users.||Facebook: https://www.facebook.com/about/privacy/update
If you would like to know more about cookies, including flash cookie and local storage devices, the following websites provide useful information: www.allaboutcookies.org, and www.youronlinechoices.eu.
Thank you for visiting our website.
Last updated 20th July 2018. © The Key Support Services Limited.