We, Soho Editor Ltd and Soho Editors Training Limited (we / us / our), or any successor in title are committed to protecting and respecting your privacy.
This Privacy and Cookies Policy (the Policy) (together with our Terms and Conditions and any other documents referred to in these documents) explains how we use any personal information about you (you / your) that we collect when you use the Soho Editors website (https://sohoeditors.com) or any successor in title and any of our other online products, sub-sites and all other websites owned, operated and controlled by us (collectively, the Website). Please read these documents carefully. Defined words used in the Terms and Conditions shall have the same meaning when used in this Policy. References to a ‘parent’ include a legal guardian.
By using the Website (and in particular by submitting your personal information to us via the Website or, if you are a parent, by consenting for your child to do the same), you give your consent to the collection, storage and use of your or, as applicable, your child’s personal information, as described in this Policy. If you are a parent allowing your child to use the Website, references in this Policy to ‘your personal information’ shall be to your child’s personal information.
Data protection compliance
The Website is controlled by us from our offices in the United Kingdom (UK). Personal information collected via the Website is processed in compliance with the General Data Protection Guidelines of May 2018 (GDPR) and any other subsequent Data Protection Legislation UK (Act). For the purpose of the GDPR, we are registered as a Data Controller and our Data Protection Officers are: Brian Cantwell, HR Manager, available at firstname.lastname@example.org.
If you choose to visit the Website from outside the UK, you do so at your own risk, with the understanding that personal information collected from the Website may be collected, stored and used in a country whose privacy laws may be different and less protective than those of your home country.
If you are under the age of 18, please get permission from your parent before you provide personal information through the Website.
Our legal basis for processing your information
The use of your information for the purposes set out above is lawful because one or more of the following applies:
- · Where you have provided information to us for the purposes of requesting information or requesting that we carry out a service for you, we will proceed on the basis that you have given consent to us using the information for that purpose, based on the way that you provided the information to us. You may withdraw consent at any time by emailing us at email@example.com. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.
- · It is necessary for us to hold and use your information so that we can carry out our obligations under a contract entered into with you or to take steps you ask us to prior to entering into a contract.
- · Where necessary to comply with our legal obligations.
- · Where the purpose of our processing is the provision of information or services to you, we may also rely on the fact that it is necessary for your legitimate interests that we provide the information or service requested, and given that you have made the request, would presume that there is no prejudice to you in our fulfilling your request.
- · Where necessary, the provision of information to a third party to enable them to fulfil part of a contract or request for assistance such as third party training provider or specific skills funding body, e.g. Creative Skillset.
If you want to contact us about your preferences, please contact firstname.lastname@example.org or call on 020 7743 1286.
Collection of your personal information
In operating the Website we may collect and process the following data about you:
- · Details of your visits to the Website and the resources that you access, including, but not limited to, the Internet Protocol (IP) address used to connect your device to the internet, traffic data, location data, page interaction information (such as scrolling, clicks and mouse-overs), your operating system and platform, your login information, weblogs and other communication data.
- · Information that you provide by filling in forms on the Website, such as when you register for information, sign up for an account, make a purchase, or when you apply for a training programme delivered by us or one of our partners.
- · Information provided to us when you communicate with us for any reason, whether via email, letter, through the Website or via our helpline.
Personal information collected by Soho Editors is often limited to contact details and some basic information about your area of work and employment status but may include other information necessary to provide a particular service you have requested.
Sensitive, including special category personal data may include data about your ethnic origin, nationality, gender, membership of a trade union or association, employment status, sexual orientation, caring responsibilities, number of children and, in some cases, your socio-economic background. If you are under 18 you will need to ensure your parent provides us with their consent for you to provide sensitive data about yourself.
If you are applying for a service for which government funding is available, you may need to answer certain additional questions such as your age and your current education and employment status, in order for us to evaluate whether you are eligible for that funding. By providing your information to Soho Editors, you explicitly give your consent for us to process your personal and sensitive data. However, when we collect sensitive personal data through the Website, we will ask you to consent to our uses of the data, and you may choose not to give us this consent if you so desire. Wherever the provision of information is optional, this will be made clear.
We will treat any information we collect in accordance with this Policy.
Cookies and user tracking
A "cookie" is a small text file deposited on your computer's hard drive when you access a website. Please read the section on cookies below, which sets out details of the cookies used on the Website.
How we use your information
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, we may use some or all of the information about you for the following purposes:
- · To provide you with information requested from us (such as event invitations, publications or e-newsletters) or information on other products or services (including general updates about Soho Editors or our partner organisations) which we feel may be of interest to you, where you have consented to receive such information.
- · To meet our contractual commitments to you.
- · To notify you about any changes to the Website, such as improvements or service/product changes, that may affect our service.
- · To deal with your comment or query, and to contact you for more information regarding a comment or query you have made.
- · To arrange and deliver services you have requested, whether online, one-to-one or via the telephone.
- · To administer our site and for internal operations including troubleshooting, data analysis, testing, research, and surveys.
- · To generate anonymous statistics to help us improve the services we offer to you (these statistics will not include information that can identify you as an individual). Sometimes we may ask you whether we can keep personal sensitive data linked to an individual learning record. This can happen when we want to monitor the progress of individuals from different backgrounds through and beyond a training programme. It may also occur when we are required to share your data with a funding organisation (like the BFI) or a training provider partner. Giving personal sensitive information is always voluntary and we will explicitly ask your permission and/or your parent’s permission to share it, and any reported statistics based on it will still be anonymous.
- · To ensure that the Equal Opportunities Policy is effective, a monitoring of applications, approvals and placements is carried out. The collected sensitive information regarding your gender, age, ethnic group, sexual orientation, caring responsibilities and in some cases socio-economic background, and any disability you may have, is used solely for monitoring purposes and will be treated as confidential.
- · To pre-populate forms on the Website requesting information you have already provided, for your convenience and ease-of-use.
Occasionally, we (or trusted third parties carefully selected by us) may wish to send you information about our (and/or their) products, services and activities. Before you are sent any such information, we will ask whether you wish to receive such information. If you confirm that you do wish to receive such information, and/or your parent confirms to us that it is OK for you to receive such information, you are consenting to the use of your personal information (and, if applicable, the sharing of it with such trusted third parties) for that purpose. If you confirm that you do not wish to receive such information, we will not use your personal information, and we will not share it with such trusted third parties, for that purpose. You can withdraw your consent at any time by contacting us by email (see below for details of how to contact us).
Storing your personal data
All information you provide to us is stored, usually within the UK or other parts of the European Economic Area (EEA), on secure servers hosted by us or third parties providing hosting or other services for us.
We store application details including personal, sensitive data in electronic forms which are filed on our secure intranet. Hard copies of application forms are stored in lockable cabinets in a secure office environment.
We take every reasonable precaution to protect against the loss, misuse or alteration of your personal information and to ensure that it will be processed in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically. You acknowledge and accept that, despite our efforts to protect your personal information, there is a risk that others may try to intercept the personal information you provide to us. Transmission of your information is entirely at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access. Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential.
Disclosing and sharing your information
We will not disclose your personal information to third parties, except where the data may be provided to a third party company, such as an email newsletter tools e.g. Mail Chimp or web agency, for the sole purpose of delivering a service on Soho Editors 's behalf (provided you, or your parent if you are a child, have consented to this).
Your personal data - your name address, contact details etc. - will only be shared with partners or funders connected by contract with the training opportunity you have applied for. Where we need to share it with a specific organisation, e.g. the Creative Skillset, we will ask your (or, if you are a child, your parent’s) permission to do so.
Your sensitive personal data including special category sensitive data, concerning characteristics such as your gender, ethnicity, disability or sexual orientation is always asked for on a voluntary basis - you can choose not to say - and diversity statistics gathered through our monitoring systems are always reported anonymously.
We may disclose your personal information if we are required to do so under any legal obligation and may use external data for the purposes of fraud prevention and credit risk reduction, or where doing so would not infringe your rights, but is necessary and in the public interest.
Other than this, we will not share your information with other organisations without your consent.
Course information and third party links
Soho Editors has taken care to ensure that the information on the website is correct. However, no warranty, express or implied, is given as to its accuracy and Soho Editors does not accept any liability for error or omission. Soho Editors is not responsible for how the information is used, how it is interpreted or what reliance is placed on it. We do not guarantee that the information on the website is fit for any particular purpose. You should also be aware that the availability of courses of study is subject to conditions applied by individual institutions at their sole discretion.
You will find links to third party websites on the Website. These third party websites should have their own privacy policies which you should check before you submit any personal data to them. We are not responsible and do not accept any liability for the privacy practices or content of such websites. Soho Editors does not endorse any of the products or services of third party organisations contained within its sites unless expressly stated.
You have the right to request details of the personal details and or processing activities that we carry out with your personal information through making a Subject Access Request. Such requests have to be made in writing.
You have the following rights: (as introduced in the UK under the GDPR in May 2018):
- · the right to request rectification of information that is inaccurate or out of date
- · the right to erasure of your information (known as the 'right to be forgotten')
- · the right to restrict the way in which we are dealing with and using your information, and
- · the right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the 'right to portability');
- · rights in relation to automated decision making and profiling including profiling for marketing purposes.
All of these rights are subject to certain safeguards and limits or exemptions, further details of which can be found in our Data Protection Policy. To exercise any of these rights, you should contact Data Protection Officer(s) at email@example.com .
If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner’s Office. Further details about how to complain can be found here.
Freedom of information
The Freedom of Information Act 2000 (FOA) provides public access to information held by public authorities. It does this in two ways:
- · Public authorities are obliged to publish certain information about their activities, and
- · Members of the public are entitled to request information from public authorities.
The FOA covers any recorded information that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland. Information held by Scottish public authorities is covered by Scotland's own Freedom of Information (Scotland) Act 2002.
Soho Editors is not a public body, and therefore is not directly subject to the FOA. The list of public bodies covered by the FOA can be found here. We will respond to requests for information from members of the public, where the provision of information in response to such an enquiry does not adversely affect Soho Editors or its stakeholders. This is entirely at the discretion of Soho Editors, and we are in no way compelled by the FOA to respond to such requests.
All Freedom of Information requests should be sent to Data Protection Officer(s) at firstname.lastname@example.org.
What are cookies?
Cookies are widely used to allow online and mobile sites to function efficiently and are often small text files that (depending on your browser settings) are deposited on your computer, mobile phone, tablet or other device when you visit a site. The cookies may be sent back to that site when you visit again and may then be used by the server to identify and track your use of the Website.
This page describes what information they gather, how we use that information and why we sometimes need to store these cookies. It also explains how you can prevent these cookies from being stored; however, this may downgrade or 'break' certain elements of the site's functionality.
For more general information on cookies see the Wikipedia article on HTTP cookies.
The cookies we set
The cookies used for the Website do not contain any information that, in itself, personally identifies you and do not provide us with access to the rest of your device. We may, however, associate the information contained in cookies with personal information that you have provided to us separately.
We use ‘session’ cookies and ‘Google Analytics’ cookies on the Website.
Session cookies allow the Website to remember users’ activity between pages.
Google Analytics and other third party cookies
The Website uses Google Analytics, which is one of the most widespread and trusted analytics solutions on the web that helps us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
We also use social media buttons and/or plugins on the Website that allow you to connect with your social network in various ways. For these to work the following social media sites, including Google+, Facebook, Twitter, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies (which will be available on their respective websites).
Unfortunately, in most cases there are no industry-standard options for disabling all cookies without completely disabling the functionality and features they add to this site as some cookies are strictly necessary for the operation or functionality of a site.
Be aware that disabling cookies will affect the functionality of the Website and many other websites that you visit too. Disabling cookies will usually result in also disabling certain functionality and features of this Website. Therefore it is recommended that you do not disable cookies.
Further information on rejection and deletion of cookies is provided at www.aboutcookies.org.
Changes to this Policy
This policy was last modified in May 2018.