PerseCoding.net/ (“this site”) is operated by The Perse School, Cambridge. We are committed to protecting the privacy and security of your personal information (“personal data”).
This policy (together with our terms and conditions and any other documents referred to in it) describes how we collect and use your personal data during your use of our site for the purpose of administering The Perse Coding Team Challenge competition (“the competition”), in accordance with the General Data Protection Regulation (GDPR) and associated data protection legislation.
B Who is using your personal data
The Perse School is the “data controller” for the information that you provide to us when visiting this website. This means that we decide how to use it and are responsible for looking after it in accordance with the GDPR.
Access to your personal data within The Perse School will be provided to those staff who need to view it as part of their work in connection with the operation of this website. It will also be shared with the third parties described in Section F.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We may update this policy at any time.
By visiting our site you are accepting and consenting to the practices described in this policy.
Where we refer in this policy to your “personal data”, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).
Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure or retention.
D Types of data we collect
The international competition website https://persecoding.net/ will require teachers who wish to register to give their name, email and school. Teachers may optionally specify the name and the gender of each competing student although anonymous usernames and passwords for teachers to issue to students are also available. We will collect the vast majority of data about you when you provide that information to us, for example when you register to use our site, correspond with us by phone, e-mail or otherwise enter the competition/challenge, and when you report a problem with our site.
When you visit our sites we may also automatically collect technical information about your visit from your computer, for example, the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform.
E How we use your data
We process your data for one or more of the following reasons – only as necessary for us to meet our obligations to you or to take steps requested by you for the purpose of your participation in the two rounds of The Perse Coding Team Challenge, and because it is necessary for our legitimate interest, these being known as our legal bases for processing:
- to administer the Perse Coding Team Challenge, including scoring the competition and awarding certificates and prizes,
- to operate this website and to ensure that we understand how our site is used and to improve our website and ensure it is secure.
Name and school information provided to us will be used only for the purposes of the competition and follow-up activities (e.g. further rounds of the competition, invitations to participate in prize givings or related outreach events). Relevant invitations will be issued via teachers, and students will never be contacted directly for such purposes.
Gender information will be used only for anonymised statistical analysis of results. The latter analysis may involve passing of performance and gender statistics (but not names) to our partners.
We do not send you marketing or other types of communication by email except where you have specifically indicated that you consent to receive such communications by email request or by signing up on our main competition website. You can withdraw your consent with respect to such marketing at any time by contacting us per the contact details provided below or by using the unsubscribe link in any email.
We will only use your data for the purposes for which we collected it, unless otherwise required or permitted by law.
F Sharing your data with third parties
We may share your data with third parties who provide services on our behalf, including without limitation Eljakim Information Technology BV and MailChimp (described in the next paragraphs). All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
The databases used for the administration of the student data, teacher data and the administration of the competition are stored on secure distributed servers in the Netherlands owned and managed by Eljakim Information Technology BV. Eljakim Information Technology BV holds a ISO 27001 certificate, no. NL 217.1.1 which demonstrates that an organisation has defined and put in place best-practice information security processes. More information can be found here: https://www.itgovernance.co.uk/iso27001-benefits.
Teachers’ email addresses, first name, second name and school are added to a MailChimp mailing list group controlled by us, and by signing up with The Perse Coding Team Challenge you agree that we may use MailChimp (and transfer your contact details to MailChimp) in this way. Emails sent out from this mailing list always have an unsubscribe link that, if clicked, automatically stop MailChimp from sending out mailings to this address again from this list. It also notifies The Perse Coding Team Challenge Administrator about this request who will then remove this teacher’s details from the database.
Where your data is shared with third parties, we will seek to share the minimum amount necessary.
G Where we store or use your data
We may store data collected by the website manually or electronically. The data is stored on our secure servers and/or in accordance with Section F above.
There may be occasions when we transfer your data outside the European Economic Area (EEA), for example, when we communicate with you using a cloud based service provider that operates outside the EEA such as MailChimp. Such transfers will only take place if one of the following applies:
the country receiving the data is considered by the EU to provide an adequate level of data protection;
the transfer is governed by approved contractual clauses;
the transfer has your consent;
the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract; or
the transfer is necessary for the performance of a contract with another person, which is in your interests.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to the website and any transmission is at your own risk.
H Third party websites
Our site contains links to and from various third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
I Retaining your data
We will only retain your data for as long as we need it to fulfil our purposes, including any relating to legal, accounting, or reporting requirements.
Personal information relating to students will remain in the competition database until after the students’ data has been collected. This is to enable checking of results by the participants and their teachers. Thereafter, all such information will be deleted and results will become inaccessible
Contact information for teachers may be retained to facilitate communication about future competitions or other related opportunities.
Requests to have student or teacher data removed at any point should be communicated to email@example.com, the school coordinator.
K Changes to this policy
L Your rights
Under certain circumstances, by law you have the right to:
Request access to your data (commonly known as a “subject access request”). This enables you to receive a copy of your data and to check that we are lawfully processing it.
Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
Request erasure of your data. This enables you to ask us to delete or remove your data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
Object to processing of your data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request, it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing (for example, where you have asked us to contact you for marketing purposes) you can withdraw your consent at any time. In this event, we will stop the processing as soon as we can. However, this will not affect the lawfulness of any processing carried out before your withdrawal of consent and you may no longer be able to use the site in the same way as you did before.
If you want to exercise any of the rights described above or wish to raise any queries or concerns in relation to our processing of your personal data, please contact either or both of the following:
Data Processing Officer
The Perse School
We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/concerns/.