Words First Limited is required by law to notify you when we process your personal data and to obtain your consent to process certain types of personal data. Words First Limited is an establishment in the UK and we are therefore subject to the Data Protection Act of 2018 as well as regulations contained in the UK GDPR.
This privacy notice is to inform you about how we collect, store, process and retain your data that we obtain through this website.
Contents
The Terms Used in this Notice
General Information
Types of Data We Hold
How we collect and store your data
How we process your data
How we share your data
How long we keep your data
Your Personal Data Right
How we keep your data secure
Application of this Notice
The Terms Used in this Notice
This section provides you with some definitions and explanations of the terms used in this notice.
Personal Data
According to the Data Protection Act of 2018, personal data is “any information that relates to an identified or identifiable living individual.” Personal data in this notice means any information about you which allows us to identify you based on that information. Examples of personal data include your name, your staff records, photographs, videos of you, and other personal details.
The Company
Where this notice refers to “the company” it means Words First Limited, and the staff employed by Words First Limited. Words First Limited is a multi-disciplinary team of highly skilled professionals supporting children with SEN and the staff supporting those professionals.
Data Controller
A data controller makes decisions about what data to process. In this case, Words First Limited is the data controller of the data we collect about you.
Data Processing Principles
The GDPR and Data Processing Act require us to apply all data processing principles when processing your data. These principles require that:
- Data is only processed lawfully, fairly and in a transparent manner.
- Data is only processed for specific legitimate purposes.
- Data collection is limited to what is necessary for the purposes of processing.
- Data is accurate and kept up to date.
- Data is not stored for longer than is necessary to achieve the purpose of processing.
- Appropriate safeguards are implemented to prevent the unlawful or unauthorized processing of data.
- Data is only transferred in accordance with the Data Protection Act and the GDPR.
Cookies
A cookie is a file which is stored on your computer’s hard drive. If you agree to a cookie, the cookie file is added to our computer, and it will then perform a function depending on the type of cookie file that has been stored. Cookies can help us to analyze web traffic. Cookies may store information about what websites you visit and may, for example, save preferences or images so that webpages load faster or function more efficiently when you visit them again. They may help web applications to respond to you as an individual.
General Information
This notice is designed to inform you about how we collect and store your data, what data we process, what your rights are in terms of that data, and how we delete the data we have stored about you.
This notice applies to all website users but does not override any other specific consents you may have signed with Words First as a client.
Types of Data We Hold
Our website is designed to provide you with information on our company and we also offer various services through our website. The data we collect will depend on your choices on our website however the following are the general types of data we may collect and store about you.
The types of data we hold about you include:
- Your name
- Your address
- Your email address
- Your phone number
- Your IP address
- Basic transactional details
- You have the option to store your payment details but that is voluntary
How we collect and store your data
Our website uses cookies to store basic information about you, generally your IP address. You can manage your cookie preferences using the “Manage Cookie” tab on our website. The cookies we use on our website include:
Necessary Cookies
These cookies are absolutely essential for our website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously. These cookies do not store any of your personal data like IP address details.
Functional Cookies
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedback, and other third-party features. These cookies are used when you share something from our website on your social media pages like Facebook.
Performance Cookies
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics Cookies
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics, the number of visitors, bounce rate, traffic source, etc.
Advertisement Cookies
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Our cookies are consent based. You can withdraw your consent at any time using the “manage cookie” feature on the website.
We also offer services, training, and resources via our website. If you choose to purchase a training course or services from the website, then you will provide information to Words First Limited and this information will be stored based on your consent to store the information.
Our website also offers a contact form. If you use the contact form to contact us then the information you enter into the contact form will be provided to us on the basis of your implied consent when filling out the form.
How we process your data
The law requires us to inform you about the types of data we process and the legal reason for that processing.
We will always consider your interests, rights, and freedoms. Where your information is used for other reasons, other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Words First Limited essentially relies on four main lawful grounds to process your data lawfully. These grounds are consent, contractual performance, legal obligation, and legitimate interests.
Most of the data obtained from our website is processed in terms of the lawful consent provided by you. You are at liberty to withdraw this consent at any time should you wish to do so.
Depending on the purpose of the processing, the lawful grounds for processing may vary. For example, we may process your name based on consent when you purchase something from our website. We may process your name at a later stage based on contractual performance to deliver your purchases to you. We could process your name at another stage based on legal obligation when we provide HMRC details of payments received for services purchased. And finally, we may process your name as part of our legitimate interests to alert you to a new product or service using opt out marketing consent.
Below is a simple outline of the data categories we have, and the legal basis that applies to the processing of that data. If you require more detailed information, please feel free to contact our DPO with your requests for further information.
| Data Type | Lawful Basis for Processing |
| Name | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| Address details | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| Email Address details | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| Phone Number details | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| IP Address | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| Basic Payment details | Consent. Contractual performance. Legal Obligation. Legitimate Interest |
| Special Category Data | Explicit consent |
| Criminal Offence Data | Explicit consent |
Special Category Data
The law defines certain kinds of data as special category data, and there are specific laws and rules which govern how we process special category data. These special categories of data include, race, religion, beliefs, trade union membership, genetic data, biometric data, and data about your health, sex life and sexual orientation.
We do not process or store any special category data via our website.
How we share your data
Your personal data will always be treated as strictly confidential. It is stored securely on our website, and only authorized individuals can access your data. Your data will only be shared with third parties, where you have purchased an item from the website, where it is necessary for the performance of our tasks or where you first give us your prior consent to share your data. Your data will only be shared with a third party when the party receiving the data has been advised of their responsibilities to keep this data secure under the rules and regulations of the GDPR.
How long we keep your data
In terms of the Data Privacy Principles, we are only allowed to keep your data for as long as is legally necessary. For website records, we may need to keep some data for longer periods if we are legally required to do so. For example, it is current best practice to keep financial records for a minimum period of 3 years to support HMRC audits.
This means that we will delete your data, or archive it for statistical, historical, or analytical purposes when the data is no longer needed.
In general, the following retention periods apply to your data:
| Data Type | Data Retention |
| Name | For as long as you consent and for 3 years if the data relates to a financial transaction |
| Address details | For as long as you consent and for 3 years if the data relates to a financial transaction |
| Email Address details | For as long as you consent and for 3 years if the data relates to a financial transaction |
| Phone Number details | For as long as you consent and for 3 years if the data relates to a financial transaction |
| IP Address | For as long as you consent and for 3 years if the data relates to a financial transaction |
| Basic Payment details | For as long as you consent and for 3 years if the data relates to a financial transaction |
| Special Category Data | Not stored or processed in any way |
| Criminal Offence Data | Not stored or processed in any way |
Your Personal Data Rights
The law provides you with a certain number of rights in terms of your personal data. These rights are designed to allow you to know what data we hold about you and how we process that data. As a Words First Limited client or website user, you have the following rights:
Your Right to Access
At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and from where we obtained the information.
Your Right to Rectification
You have the right to request that incorrect data is corrected.
Your Right to Erasure
You can request that the data we hold about you is erased. The right of erasure is not absolute and will depend on the data and why it is being stored. Tax records, for example, are legally required to be stored for a certain period of time. Your request will be dealt with in writing and explanations of what data has been erased and what data has been retained will be provided to you.
Your Right to Withdraw Consent or Object to Processing
Where you provided information through consent, you have the right at any time to withdraw your consent to processing. Where data has been processed based on legal grounds other than consent you have the right to object to that processing.
How to Exercise your Rights
To exercise your rights, you can contact our DPO to begin a subject rights request. Rights requests can be made orally or in writing. Our DPO will always respond to a rights request in writing, without undue delay and within one month of receiving any subject rights request.
There are no fees or charges for a request but if the request is found to be manifestly unfounded or excessive then we may discuss a fee for additional or further information requests.
You can contact our DPO:
Brigitta Schwulst at dpo@wordsfirst.uk or you can contact our office on 0208 050 4191 or lodge your objection at 119 Valley Road, Kenley.
You also have the right to contact the Data Protection Authority within your country to lodge a complaint regarding your data rights:
The UK Information Commissioner: 0303 123 1113 or via email: https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House.
How we keep your data secure
Words First Limited take data protection and security very seriously. We are committed to ensuring that your information remains secure. In order to prevent unauthorized access or sharing of your information, we have implemented suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
We have a comprehensive privacy policy framework at Words First Limited and we strive to ensure that we meet the requirements of the Data Protection Act of 2018 as well as the regulations in terms of the UK GDPR.
Application of this Notice
This notice applies to all current Words First Limited website users and clients and takes effect from 4th October 2024
This notice will be available on our website as part of our privacy policy framework.
