Privacy Policy

This policy applies to information we collect when you choose to use our websites, and also to personal information which we process further to supplying services to our clients. We take your privacy very seriously and we ask that you read this privacy policy carefully as it
contains important information on the personal information, we collect about you; what we do with your information and who your information might be shared with. Our websites are operated by Staff Absence Management Limited, Fusion Business Solutions Ltd
and FACE-Ed Ltd. Our registered office for the group is First Floor, Unit A, Cedar Court OfficePark, Denby Dale Road, Wakefield, WF4 3FU.
The group of FEPS (Fusion Education People Solutions) under Staff Absence Management Limited, Fusion Business Solutions Ltd and FACE-Ed Ltd (‘SAM’, ‘we’ or ‘us’) are a ‘data controller’ for the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (‘GDPR’) (as applicable the “Legislation”) where we control the purposes for which we process your personal information. We are the data processor where we are processing your personal data in order to provide services to our clients. Where we process information on your behalf regarding someone else, we act as a data processor and as the data controller, you confirm you have notified him/her of the processing through the necessary documentation as outlined through legislation. In either case we comply with the Legislation. Any questions about our data protection policy or how we handle your personal data should be addressed to our data protection officer. (See contact information below.)

Personal information provided by you

We collect personal information about you (such as your name, address and contact details), for example your email address when you make an enquiry, register with us or purchase products or services from us. We also collect personal information when you contact us via the online form.

Personal information provided to and by third parties

We may receive or send information about you from and to other sources (namely our clients, our companies, SAM, FusionHR, FACE-Ed, service providers, associates and consultants) which we will add to the information we already hold about you in order to supply our clients with our services and to help us improve and personalise our services.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that either; (1) the other person has a contractual relationship with you and knows that you will be transferring their personal data to us for specific purposes (i.e. that your employee is aware that you have purchased a SAMpeople, FACE-Ed or Staff Absence Management Software Licence or signed up for a FusionHR SLA) and/or (2) s/he has appointed you to act on his/her behalf and has been made aware that the following applies:

• Fusion Education People Solutions will only process his/her data under instruction from the controller for the performance of a contract entered into with Staff Absence Management Limited, Fusion Business Solutions Ltd and FACE-Ed Ltd and
• s/he has been informed of the data processing by Fusion Education People Solutions through appropriate notices, issued by the Data Controller (Employer) as set out in the legislation.

Sensitive/special category personal information

We may process sensitive personal information in certain situations, for example in the software relating to employment and recruitment checks or specific investigations. This will only be used as listed above for the purposes of supplying/hosting software for the performance of a contract.

Sensitive personal information includes information relating to:

• ethnic origin
• political opinions
• religious beliefs
• trade union membership
• physical or mental health or condition
• sexual life

We will only process your sensitive personal information (in accordance with the consent given as part of the contract and relating to the information supplied by you, the client, to be stored in the system.

A cookie is a small text file which is placed onto your computer (or other electronic device) when you use our website. We use cookies on our website.

Where applicable, this website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users.

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider, to improve the user’s experience whilst visiting the website, and better understand how you use it. This information helps us to build a profile of our users. Some of this data will be aggregated
or statistical, which means that we will not be able to identify you individually.

You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies please see our Website cookie policy.

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

We collect information about you so that we can:

• identify you and manage any accounts you hold with us
• provide the services requested
• if you agree, let you know about other products or services that may be of interest to you (see ‘Marketing’ section below)
• detect and prevent fraud
• customise our website and its content to your particular preferences
• notify you of any changes to our website or to our services that may affect you
• improve our services.

Marketing and email newsletter

We use any information submitted to us by you to provide you with further information by post and email about the products and services we offer which you have requested, and/or which may be of interest to you.

As part of our services, we supply an email newsletter which we use to inform you about products and services supplied by us. You may be contacted because you have requested a demo or brochure or because you are a client or existing contact of Fusion Education People Solutions. You can choose to unsubscribe at any point by clicking on the link at the bottom of the email.

Email marketing campaigns published by us may contain tracking facilities within the actual email. Subscribed activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include: the opening of emails, forwarding of emails, the clicking of links within the email consent, times, dates and frequency of activity (this is by no means a comprehensive list).

We may disclose your personal data to:

• companies within our group
• our agents, associates and service providers
• law enforcement agencies in connection with any investigation to help prevent unlawful activity

Any data provided that is to be used within the SAM, SAMpeople, FACE-Ed platforms will not be shared with any third party without explicit instruction from the data controller.

Our staff and associates are bound by obligations of confidentiality and trained in the protection of personal data. We comply with the Legislation and use the appropriate technical and organisational measures necessary to safeguard your personal data. We only share your
personal data with third parties who also comply with the Legislation.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).

The Licenced Software Service (SAM, SAMpeople, FACE-Ed) is provided through a centrally hosted system from a data centre(s) within the UK.

We only send your data outside the EEA where we have in place a legal agreement which complies with the Legislation.

As Fusion Education People Solutions we utilise Salesforce as our CRM. Customer Data held in our Salesforce Account for the Covered Services is stored in the United Kingdom (SFDC EMEA Data Centre Limited UM5). Customer Data backed up or submitted through plugin’s such as Einstein Analytics and Pardot may be transferred to other data centres within the same geographical region (i.e. EMEA) for processing, but will only be stored in primary and secondary data centres within the same geographical region. Salesforce operates an information security management system (ISMS) for the Covered Services in accordance with the ISO 27001 international standard. For more information please visit https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/misc/salesforcesecurity-privacy-and-architecture.pdf.

As a group, we also utilise software services, such as Capsule CRM which are hosted on Amazon Web Services (AWS) Cloud infrastructure, for more information please visit https://aws.amazon.com/compliance/gdpr-center/ and https://capsulecrm.com/security/.

We also use the financial management system Xero for invoicing, please visit https://www.xero.com/uk/campaigns/xero-and-gdpr/.

We use third party service, MailChimp.com, to deliver marketing information to current and potential clients. For more information about how MailChimp processes data, please visit https://mailchimp.com/legal/privacy/.

We use Freshdesk for client ticket tracking. You can visit their privacy policy here https://www.freshworks.com/privacy/

Where data is stored outside the EU, additional independent checks have been undertaken to ensure the data security is of a sufficient level and meets adequacy requirements, in order to satisfy the requirements of the UK GDPR.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

We store your personal data on secure servers in accordance with the criteria set out in our Retention Policy. Regulations and legislation require that we keep certain information for a dedicated time. This is all outlined in full in our Retention Policy.

The GDPR provides the following rights for individuals:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object to processing
8. Rights in relation to automated decision making and profiling (We do not carry out automated decision making and profiling)

Right to access – ie to request a copy of your information

You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please write to us at The DPO, Fusion Education People Solutions, First Floor, Unit A, Cedar Court Office Park, Denby Dale Road, Wakefield, WF4 3FU or email dpo@feps.co.uk;

• let us have proof of your identity (a copy of your driving licence or passport); and
• let us know what information you want.

Right to correct any mistakes in your information

You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please email or write to us (see ‘How can you contact us?’ below)

• let us have enough information to identify you
• let us know the information that is incorrect and what it should be replaced with.

Right to remove your details from our records or restrict how we use your information

You can ask us to stop contacting you for particular purposes or remove your information completely from our records.  There may be a legal reason why we need to keep your personal data and in that circumstance we will destroy your personal information as soon as we are legally entitled to do so.   If you would like us to stop contacting you with information about our services, please email or write to us (see ‘How can you contact us?’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email and/or newsletter;

• let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

Right to lodge a complaint with the Supervising Authority

If you have any concerns or complaints about how we use your personal data, we hope you will alert us to these directly (see the Contact information below).  If you are still unhappy you are entitled to complain to the Information Commissioners Office (ICO) which is the supervising authority in the UK. Their contact details and the procedure can be found at www.ico.gov.uk

Please contact Ben Cain, our Data Protection Officer, if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us about any other matter;

• please send an email to dpo@feps.co.uk

or

• write to us at First Floor, Unit A, Cedar Court Office Park, Denby Dale Road, Wakefield, WF4 3FU

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website or use our services.