(Edition 1, June 2018)

Privacy notice and consent
This notice explains how information about you is used.

The information we gather
SSP –  Unlocking Potential (SSP) is committed to protecting your personal information.
In this notice, references to ‘we’ or ‘us’ means SSP. References to ‘you’ means anyone using our websites, products or supplying personal data, contact details or other information to us.
Information that we gather about you may include your name, email address, IP address and any other unique means of identification or bespoke data shared with us (including but not limited to phone numbers, role, department, geographic location, log of emails and history of interactions with you) and your online behaviours and interactions with our websites or products.
We may also obtain information about you from third parties, such as your employer, our subcontractors, service providers and agents.
When we collect data from you we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom).
We will take all reasonable precautions to hold such data securely. We will comply with our obligations as data processor under the applicable laws.

Systems used to gather data
We gather information directly from you and also via our websites and other technical systems. These may include, for example, our:
*computer networks and connections
*communications systems
*authentication methods, including single sign-on and username/password credentials
*email and instant messaging systems
*intranet and internet facilities
*telephones, voicemail, mobile phone records
*tracking technologies (such as click-through links, cookies and web beacons)
*and other hardware and software owned, used or provided by or on behalf of us.

When you use our website, we may gather information about you through internet access logs, cookies and other technical means. ‘Cookies’ are text files placed on your computer to collect internet log information and user behaviour information. These are used to track website usage and monitor website activity and for other data processing reasons set out below. A cookie does not contain information that allows us to identify an individual user.
Some of the cookies we use are essential for parts of the site to operate and have already been set. You may delete and block all cookies from this site, but parts of the site will not work. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
If you need any further detail, please contact data@ssp-unlock.co.uk


Reasons for processing
We may process your personal data for our legitimate business purposes such as:
*delivery of services
*to enhance, modify, personalise or otherwise improve our services for the benefit of our customers including reporting on usage trends
*to enhance the security of our network and information systems
*to better understand how people interact with our websites or products
*improving the effectiveness of promotional campaigns and advertising
*to comply with legal or regulatory obligations and good practice
*to contact existing customers or individuals that have shown an interest in our products or services.

We always carefully consider your interests and your personal data rights before doing this. If you have any concerns about us processing your personal data for these reasons, you have the right to object. If you wish to do so, please contact data@ssp-unlock.co.uk
In other circumstances, such as for marketing activities, we will only process personal data where you have provided your consent for us to do so. You can withdraw this consent at any time and if you wish to do so please contact us at data@ssp-unlock.co.uk

How we hold and share information
SSP will only keep data for as long as is reasonable based on the nature of the data and the reason for processing. Note that we take daily backups of all our data, and some backups are held for up to 12 months. This means that if you ask for your data to be removed from our systems, it will remain in our encrypted backup files for up to our maximum retention period.
We may disclose and exchange information with subcontractors, service providers, representatives and agents, as well as with law enforcement agencies and regulatory bodies for the above reasons.
Information may be held at our offices and those of our subcontractors, service providers, representatives and agents as described above. Information may be transferred to other countries around the world, including those without data protection laws equivalent to those in the UK, where required for our processing activities. We have security measures in place to seek to ensure that there are adequate safeguards in place to protect the data we hold and we will ensure the transfer complies with data protection laws.

We do not knowingly collect personal data relating to children under the age of 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us at data@ssp-unlock.co.uk We will ask you to prove your relationship to the child but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.

Your choices
Please contactdata@ssp-unlock.co.uk if you would like to:
• correct or request information that we hold relating to you
• object to our processing of your personal data
• update your consents
• ask for all data we hold about you to be deleted
When making your choices, please bear in mind that they may affect your use and enjoyment of our services and products. If you have any concerns about the way that we process your personal data, please contact us. You also have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/).

Changes may be necessary to this policy to reflect legal or data processing developments. Any significantly different use of your data will be communicated to you. As explained above, you can amend your consents or raise an objection to our processing of your data at any time.
Last updated April 2018.