The Morrisby Organisation
Privacy Policy and Cookie Policy
30 April 2018

Background:

The Morrisby Organisation understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Sites. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Sites.  If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 12, below;

“Our Sites”

means the websites:

  • app.morrisby.com
  • ft.morrisby.com
  • manager.morrisby.com
  • www.morrisby.com
  • www.fasttomato.com

“UK and EU Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;

“We/Us/Our”

means Educational & Industrial Test Services Limited, trading as The Morrisby Organisation , a limited company registered in England under 1183700 , whose registered and trading address is Gaddesden Place, Great Gaddesden, Hertfordshire, HP2 6EX, UK.

“Candidate”

A user of Our Sites that has signed up for career guidance purposes.

“Adviser”

A user of Our Sites that manages Candidate accounts on behalf of a school/centre.

 

2. Information About Us

  • Our Sites are owned and operated by Educational & Industrial Test Services, a limited company registered in England under 1183700, whose registered and trading address is Registered Address is Gaddesden Place, Hemel Hempstead, HP2 6EX. Our VAT number is  GB209260972.
  • Our data protection officer is Steven Cole who can be contacted at support@morrisby.com  or +44(0)330 500 5000
  • We are registered with the Information Commissioner’s Office under number Z5657144 : https://ico.org.uk/ESDWebPages/Entry/Z5657144
  • We are ISO 9001 certified.
  • We have matrix accreditation: matrixstandard.com

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. It does not extend to any websites that are linked to from Our Sites (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Sites (for further details, please see section 12 on Our use of Cookies) , other data will only be collected if you voluntarily submit it when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

Information that is automatically collected for all users:

  • IP address;
  • web browser type and version;
  • operating system;
  • a list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to.

Information that is processed for Candidates:

  • name;
  • date of birth;
  • email address;
  • profile information: interests, personality, and aptitudes;
  • Qualifications and grades;
  • Work history notes;
  • career and education plans;
  • factors that may affect your performance in our assessments, including: whether English is your first language, and learning needs;
  • Notes that you might make;
  • Careers interview notes made by your adviser;
  • UCAS personal statement draft;
  • Other information your school/centre may request from you for careers guidance purposes.
  • Feedback you may give about our service;
  • Any support queries you might make;
  • A history of your actions on Our Sites;
  • School

Information that is processed for Advisers:

  • Name
  • At-work email address

5. How Do We Use Your Data?

5.1         All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679)  (GDPR). For more details on security see section 6, below.

5.2         We use your data to provide the best possible services to you. This includes:

5.2.1        Providing and managing your account;

5.2.2        Providing and managing your access to Our Site;

5.2.3        Personalising and tailoring your experience on Our Site;

5.2.4        Supplying Our products and services to you;

5.2.5        Personalising and tailoring Our products and services for you;

5.2.6        Responding to communications from you;

5.2.7        Providing and managing your account;        

5.2.8        Building a careers profile;

5.2.9        Providing personalised career, subject and course suggestions;

5.2.10        Gathering feedback and usage stats to enable Us to improve Our Sites.

5.3          In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

5.4         We will never pass on your details to any third parties for marketing purposes. However, with your permission, We may email you with offers and information that may help you with your career journey. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5          Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

5.5.1        you have given consent to the processing of your personal data for one or more specific purposes;

5.5.2        processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

5.5.3        processing is necessary for compliance with a legal obligation to which we are subject;

5.5.4        processing is necessary to protect the vital interests of you or of another natural person;

5.5.5        processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

5.5.6        processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

5.6         Our lawful basis for processing data for career guidance purposes is legitimate interests (5.5.6). We have conducted a thorough necessity and balancing test, as required by GDPR. This demonstrated an overwhelming case that the aligned legitimate interests of the individual, the school, and of Us, strongly supports the use of legitimate interests as the lawful basis for collecting personal data.

5.6.1        The data subject has a legitimate interest to receive personalised careers guidance.

5.6.2        The school has a legitimate interest in providing careers guidance for its students and meeting the Gatsby benchmarks.

5.6.3        We have a legitimate interest in achieving Our mission of “Supporting people to make optimal life decisions by providing objective, impartial and relevant information about themselves and the opportunities available"

A full copy of the documentation for the necessity and balancing test is available on request.

6. How and Where Do We Store Your Data?

6.1         We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. For further information please refer to our Data Retention Policy.

6.2         Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Sites and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.

6.3          Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.

6.4         Steps W e take to secure and protect your data include, but are not limited to:

  • The use of firewalls;
  • The use of antivirus and antimalware software;
  • Regular security reviews;
  • Encrypted data storage;
  • P enetration testing and vulnerability scans;
  • Intrusion detection monitoring;
  • Restricting access to data to those that need it;
  • Our Sites only use encrypted data transfer, using https.
  • Secure destruction of paper records.

6.5          Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Who Has Access to My Data?

We restrict access to your data to those that need access to help provide the career guidance services that you have signed up for. This is strictly limited to the following people and organisations.

7.1         Employees and directly employed freelance contractors of The Morrisby Organisation have access to your data. This is required for Us to provide Our services and fully support Our users and customers. All Morrisby employees and contractors are DBS certified.

7.2         Any Advisers that your school/college/centre has explicitly chosen to give access. You can view which advisers and teachers have access to your data within the account section of Our Sites.

7.3         We may compile statistics about the use of Our Site including data on traffic, usage patterns, assessment and questionnaire answers, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, and partners. Data will only be shared and used within the bounds of the law.

7.4         I n certain rare circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

8.1         We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.2         In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

9. How Can You Control Your Data?

9.1         When you submit information via Our Sites, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and  at the point of providing your detail or by managing your Account ).

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1         You may access  certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.

10.2          You may restrict your internet browser’s use of Cookies. For more information, see section 12.

10.3         You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this will prevent your further use of our services.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at   support@morrisby.com , or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

12.1         Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.2         By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Sites for more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

12.3         All Cookies used by and on Our Sites are used in accordance with current English and EU Cookie Law.

12.4         Before Cookies are placed on your computer or device , subject to section 12.5 and section 12.8 , you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.

12.5         Certain features of Our Sites depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.6 but please be aware that Our Sites may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.6          The following first party Cookies may be placed on your computer or device:

Name of Cookie

Purpose

Strictly Necessary

_RequestVerificationToken

Security, to prevent Cross Site Scripting attacks

Yes

cc_cookie_accept

To track whether someone has accepted the cookie policy

Yes

.MorrisbyAuth

Authentication

Yes

.ASPXROLES

Authorisation

Yes

AdviserSettings_XXXX

Storing various interface settings for the adviser

Yes

and the following third party Cookies may be placed on your computer or device:

Name of Cookie

Provider

Purpose

[Various]

YouTube

For various embedded videos

[Various]

Tawk.To

Online chat support for advisers

[Various]

Wistia

For embedded videos

 

12.7         Our Sites uses analytics services provided by Google Analytics . Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. This, in turn, enables Us to improve Our Sites and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making then a better and more useful experience for you.

12.8         The analytics service(s) used by Our Sites use Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Sites and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.

12.9          The analytics service(s) used by Our Sites use the following Cookies:

Name of Cookie

First / Third Party

Provider

Purpose

_ga

Third party

Google Analytics

Tracking site usage

_gat

Third party

Google Analytics

Tracking site usage

_gid

Third party

Google Analytics

Tracking site usage

 

12.10         You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.11         You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.

12.12         It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13. Summary of Your Rights under GDPR

Under the GDPR, you have:

  • the right to request access to, deletion of or correction of, your personal data held by Us;
  • the right to complain to a supervisory authority;
  • be informed of what data processing is taking place;
  • the right to restrict processing;
  • the right to data portability;
  • object to processing of your personal data;
  • rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Sites or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Automated Decision-Making and Profiling

14.1         We do not use your data for automated decision-making.

14.2         Where We use your personal data for profiling purposes, the following shall apply:

  1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  2. Appropriate mathematical or statistical procedures will be used;
  3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

14.3         We profile your personal data only for the purposes of providing personalised careers guidance.

Contacting Us

If you have any questions about Our Sites or this Privacy Policy, please contact Us by email at support@morrisby.com, by telephone on +44(0)330 500 5000, or by post at Gaddesden Place, Great Gaddesden, Hemel Hempstead, Hertfordshire, HP2 6EX. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.