Protecting your privacy is important to us
Privacy Policy
All relationships are built on trust, that is why we have designed Swansea Virtual School with respect to the protection of your privacy as a priority. Access to private information is only permitted to authorised people, any attempt to access information without authorisation would be a breach of the Computer Misuse Act 1990 as interpreted in Wales.
Summary
This privacy policy is operated by the Education Directorate at Swansea Council, and relates specifically to the Swansea Virtual School website.
You may contact us with regard to this privacy policy, via:
In summary, depending on your relationship with us, we will use your personal information:
- As needed to authenticate your access to the website.
- As required by other Swansea Council teams and departments to assist with your well-being and safeguarding.
- To provide you with personalisation features, such as Welsh/English language preference.
- To provide you with support should a problem with the website arise.
- To manage and improve the Swansea Virtual School website.
- To comply with the law as defined in England and Wales, as applied in Wales.
This privacy policy, which covers all of your personal information whether collected online or offline, including by telephone or where you write to us, provides detail on those activities and explains your rights and how to exercise them.
This privacy policy shall be construed in accordance with the law in England and Wales as applied in Wales. Any changes we make to our privacy policy in the future will be posted on this page.
By using this website you confirm that you accept the terms of this privacy policy and that you agree to comply with them.
In addition to this specific webservice privacy policy; Swansea Council supply information with regards to how your information is collected, used, and protected, on a wider basis.
Our Commitments to You
The Education Directorate at Swansea Council is committed to protecting and respecting your privacy when using the Swansea Virtual School website.
Although we will do our utmost to protect your information, we cannot guarantee the security or reliability of third-party services. Your use of the internet and transmission of personal data is done so at your own risk. Once we have received your information, we will use relevant security procedures to try to prevent unauthorised access.
We will never pass on information about you given through Swansea Virtual School to third-parties other than those involved with actioning your request unless either:
a) you have given consent,
b) we have to do so to fulfil a contractual obligation, or
c) we are legally obliged to do so under law in England and Wales as applied in Wales.
We will never use any of your data in ways that might have unjustified adverse effects on you. We will never use information provided via the Swansea Virtual School website to make automated decisions that would affect you.
Swansea Virtual School may contain web links to third-party educational organisations and advice websites. If you follow a link to any external website, please note that they will have their own privacy policy and are not affiliated with Swansea Virtual School or Swansea Council. It is your responsibility to check these policies before you submit any personal data to such websites.
Swansea Council will not display or make use of commercial advertising unless directly related to the education sector on the Swansea Virtual School website. Swansea Council will not make use of third-party organisations which implement behaviour targeting, fingerprinting, or tracking services on the Swansea Virtual School website.
Although we do record analytics related to the visitors of Swansea Virtual School, these analytics are held on a private system and the data is anonymised to prevent wider fingerprinting or tracking beyond the scope of the website.
Data Controller and Processor
This privacy policy sets out the basis on which any personal data we collect from you in the course of a browsing session, or that you provide to us during a browsing session may be processed by Swansea Council.
Swansea Council will not collect any personally sensitive information about you unless you have chosen to give it to us. Therefore, the Swansea Virtual School website is structured so that you can visit it without identifying yourself or revealing any personally sensitive information.
In relation to use of the Swansea Virtual School website; Swansea Council will act as both the Data Controller and the Data Processor.
Swansea Council will handle all of your personal information in accordance with the the various data protection laws as they apply in Wales (such as but not limited to, the Data Protection Act 1998 and the General Data Protection Regulation 2018 (GDPR)).
Data Controller and Processor
This privacy policy sets out the basis on which any personal data we collect from you in the course of a browsing session, or that you provide to us during a browsing session may be processed by Swansea Council.
Swansea Council will not collect any personally sensitive information about you unless you have chosen to give it to us. Therefore, the Swansea Virtual School website is structured so that you can visit it without identifying yourself or revealing any personally sensitive information.
In relation to use of the Swansea Virtual School website; Swansea Council will act as both the Data Controller and the Data Processor.
Swansea Council will handle all of your personal information in accordance with the the various data protection laws as they apply in Wales (such as but not limited to, the Data Protection Act 1998 and the General Data Protection Regulation 2018 (GDPR)).
Information We May Collect
Swansea Council will typically collect details provided by you as well as information relating to your visits to the Swansea Virtual School website. We may collect and process the following data about you:
Information you give us. You may give us information about you by visiting the website, completing any form on our website, or by corresponding with us by phone, e-mail or otherwise. This information may include, and not be limited to, your name, e-mail address, phone number, job title, and department or team, the nature of your enquiry, and the enquiry itself. We may also collect the IP address that you used at the time of your visit to our website, and other identifiers related to your browsing session to help ensure data security and correct identification.
Information we collect about you. With regards to each of your visits to the Swansea Virtual School website, we may automatically collect technical information, including the IP address used to connect your computer to the internet, and browsing session identifiers such as – browser vendor and version, and language preference, without directly asking you. This is necessary for the website to perform correctly.
We may process this information in order to:
- Understand what we could do to help improve your experience of Swansea Virtual School, and
- respond to anonymised data queries related to usage patterns.
- Improve our services and detect or prevent fraud, abuse of our website; and
- ensure the continuity of our service without interruption.
- Facilitate your choice of Welsh or English language, and
- facilitate your access to the web application and different parts of the website.
- To comply with the law in England and Wales, as applied in Wales.
We may also process this information in order to:
- Respond to a legal enquiry, and
- to assist with ensuring the safeguarding and well-being of Swansea Council’s employees.
- To keep a record of our correspondence with you.
This information may also be used to communicate with you if we have a legal obligation to do so, or you have consented. This information will not be used for the purposes of marketing or advertising, save for those marketing and advertising activities that take place on the Swansea Virtual School website – if any, and are related to the education sector.
This personal information may also be used to ensure that content from the website is presented in the most effective manner for you and for your computer, and/or to notify you about important changes to our web application.
In such instances, Swansea Council will always give you the opportunity to opt out of consent based communications.
Any personal information collected will be treated as confidential and, save as set out in this privacy policy, Swansea Council will not disclose any of your personal information except with your specific permission, or under a legal obligation to do so when complying with the law in England and Wales, as applied in Wales.
Disclosure to Third Parties
Swansea Council will not share the details of your individual visit with any third-party outside of the Education Directorate unless required to do so by law or as described in this agreement. Any request by a third-party for access to your account should therefore be made directly to the Education Directorate and must have a legal basis recognised by Swansea Council.
Unless not required to do so under a legal obligation, Swansea Council will seek consent from the individual prior to disclosure.
Swansea Council will only share data related to browsing sessions (see IP Addresses) in order to:
Swansea Council will not share the details of your individual visit with any third-party outside of the Education Directorate unless required to do so by law or as described in this agreement. Any request by a third-party for access to your account should therefore be made directly to the Education Directorate and must have a legal basis recognised by Swansea Council.
Unless not required to do so under a legal obligation, Swansea Council will seek consent from the individual prior to disclosure.
Swansea Council will only share data related to browsing sessions (see IP Addresses) in order to:
- Comply with legal obligations, or
- enforce or apply our terms of use and other agreements, or
- protect the rights, property, or safety of Swansea Council, or
- protect the rights, property, or safety of it’s employees, or others, or
- investigate or prevent a crime, or
- obtain professional legal advice, or
- create, manage, and process analytics, or
- with your consent.
Personal information related to you obtained via Swansea Council will not be shared by Swansea Council with:
- Third-party advertisers where the advertising provision is not being used upon Swansea Virtual School, or
- social media providers and platforms.
Swansea Council may from time to time release anonymised statistics based on usage patterns of Swansea Virtual School; this data will be anonymised in such a way as to avoid identifying any individual visitor. For example, “1600 monthly visits to Swansea Virtual School.”
IP Addresses
We need to collect information about your IP address when visiting the Swansea Virtual School website in order to ensure the security of the website. We may analyse anonymised details of visits to our website, including but not limited to, peak time usage patterns, and popularity of content.
IP addresses may not necessarily identify an individual, as they may be shared amongst many people. Nonetheless, we anonymise our data when processing for analytics so as to not identify the exact IP address.
We use this information in accordance with this privacy policy.
Cookies
Most websites use cookies to make the browsing experience more efficient, and to help you use the website to it’s full potential. Cookies are a small text file that is transferred to your hard drive or the internal memory of your mobile device. You can clear cookies in your browser settings.
When you visit Swansea Virtual School, we use only strictly necessary cookies to enable navigation around our website, personalisation choices, and to maintain your log-in details for the duration of your authenticated session.
You may refuse to accept cookies by activating the relevant setting on your web browser; however, if you refuse cookies you may be unable to access certain parts of the website, and you may not be able to make personalisation choices.
Unless you have adjusted your browser setting so that it will refuse cookies, they will be used automatically by your browser where necessary.
If you want to learn more about cookies or if you want to know how to delete or control the cookies that are stored on your computer, you can visit:
Swansea Virtual School uses cookies for three purposes:
- To help you personalise your experience with the Swansea Virtual School website.
- To assist with authentication and session management; for security.
- Personalisation cookies allow you to decide between different languages (e.g. Welsh and English).
Information in regards to this personalisation is not stored or monitored by us and only takes place within your web browser. We would never use information derived from personalisation cookies to try to identify any individual, and will not share the information with third-parties.
Authentication and session management cookies help us to ensure that your data remains secure. They are only one part of a larger set of security measures that we utilise. We need to use these session cookies each time you access Swansea Virtual School.
Should you decide to withdraw your consent to cookies being used entirely; different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies.
To find out more out more on how to manage and delete cookies, visit:
Analytics
We use a self-hosted Plausible Community Edition (Plausible CE) installation for website analytics. Plausible CE is an open source tool that does not use cookies and does not generate any persistent identifiers.
Plausible CE generates a random string of letters and numbers that is used to calculate unique visitors on a website and resets this string once per day. All the data is isolated to a single day only. There is no way to know whether a specific individual person comes back to a site on another day. There is no way to get any kind of personal data from Plausible CE, and it does not track individual people. All the data is in aggregate only.
Plausible CE minimises any data collection in general and whatever it does track is kept fully secured, encrypted and hosted in the United Kingdom to ensure it is being covered by the strict laws on data privacy.
Access to Information
We believe that the following legal reasons permit the use of your personal data:
A. Where it is needed to provide you with Swansea Virtual School, such as:
- To manage authenticated sessions and log-in information.
- To enable you to access and view access the Swansea Virtual School website.
- For you to access Swansea Virtual School from your location.
B. Where it is in our legitimate interests to do so, such as:
- To test the performance of, create analytics based upon, Swansea Virtual School and internal processes.
- To follow guidance and best practice of regulatory bodies, such as Welsh Government.
- For management and audit of our website, server, and network operations.
- To keep records of communications between you and us.
- In order to perform our duties or comply with any legal obligations.
C. With your consent, such as.
- For you to request help, support, and guidance related to Swansea Virtual School.
Under the Data Protection Act 1998 and General Data Protection Regulation 2018 (GDPR), you have certain rights in respect of the information that both Swansea Council and the affiliated provider hold about you.
The Information Commissioner’s Office has useful information in respect of your rights over your personal data.
If you wish to exercise your rights, you should contact the Education Directorate at Swansea Council via email:
1. Your right to withdraw consent.
If you wish to withdraw consent in regards to your personal information being stored, then you will need to contact the Education Directorate at Swansea Council.
2. Your right to access the information held about you.
If you wish to obtain copy of information held within Swansea Virtual School related to you, then you should contact the Education Directorate.
With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that is held about you, as well as information about what we do with it, who we share it with, and how long we will hold it for.
3. Your right to have inaccurate information about you rectified.
You have the right to have information held about you corrected if it is factually inaccurate.
If you wish to rectify information held in relation to you, then you should contact the Education Directorate at Swansea Council.
4. Your right to object to what we do with your data, and to have restrictions placed upon it.
Where we process your personal data on the basis of our legitimate interest, you have the right to object to that processing and have restrictions placed upon it while we consider your objection.
5. Your right to have your information erased in some circumstances.
You have the right to require us to delete the information that we hold about you if it is no longer necessary for the purpose we collected it for, and there is no other legal basis on which we must, or are allowed to, retain it.
6. Your right to complain to the Information Commissioner’s Office.
You have the right to lodge a complaint about our handling of your personal data with the supervisory authority, which in the United Kingdom is the Information Commisioner’s Office. But before you do so, please contact the Education Directorate at Swansea Council first to give us a chance to put matters right.
You can contact the Information Commissioner’s Office on 0303 123 1113.
