PRIVACY POLICY

 

A   PRIVACY POLICY – WEBSITE

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 of use 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 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 any third parties described in Section F for the purposes of administering the competition [1].

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.

[1] During the competition itself, the participating code submissions for automated marking are made using a separate competition hosting service, currently hackerrank.com. Participating schools should be aware that the competition hosting service used is completely separate from this site and that schools should assure themselves through separate due diligence of the compatibility of these service providers with their privacy requirements. No personal data is shared by this site with these providers.

C   GLOSSARY

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

This site will require teachers who wish to register for the competition to give their names, role and current school.  We will collect the 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, and when you report a problem with our site.

When teachers have hosted either round of the competition they will also submit to the site the name of each team that they entered together with the competition hosting service (currently hackerrank.com) usernames used by those teams for the purpose of matching the competition results to their schools. Teachers will be encouraged to ensure that all such usernames submitted are chosen to be anonymous. Optionally, teachers will also submit the gender balance of each team and the yeargroups which team members are currently in.

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 competition, and because it is necessary for our legitimate interest, these being known as our legal bases for processing:

  • to administer the competition, including scoring the competition, inviting teachers to award certificates and facilitate entries into subsequent rounds and arranging distribution of prize money or agreed related publicity
  • 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.

Teacher names and school information provided to us will be used only for the purposes of the competition and follow-up activities (e.g. invitations to participate in prize-givings, related outreach events or related competitions).  Relevant invitations will be issued via teachers, and students will never be contacted directly for such purposes.

Student personal data will not be collected by this site or the competition other than for arrangements for final prize distribution or agreed publicity. Usernames for each team competition submission will be collected from the supervising teacher for the purpose of matching submissions to schools and processing competition results. Schools will be encouraged to ensure that such team usernames do not contain student names within them.

Optional gender and yeargroup information will be used only for anonymised statistical analysis of results.  The latter analysis may involve sharing of anonymous performance and gender statistics with our competition partners.

We may publish prize-winning students’ names in pages on this website, but only after we have first asked the teachers of the students eligible to be featured on this page to seek and confirm the permission of those students.

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. You can withdraw your consent with respect to such marketing at any time by contacting us per the contact details provided below.

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 use Google Drive services including Google Form Surveys to input and store data which is entered into our teacher sign-up and team participation forms. We may share your data with third parties who provide services on our behalf, including without limitation 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.

This site does not share data directly with the competition hosting service (currently hackerrank.com). Participating schools will sign up for their own free accounts for teams to use when submitting their code. Participating schools should reassure themselves that these separate services satisfy their privacy requirements. Such usernames are submitted to this site by supervising teachers; these are used to connect team submissions to schools and their results when interpreting the competition leaderboard; participating schools are encouraged to ensure that such usernames are anonymised.

Teachers’ email addresses, first name and second name may be added to a MailChimp mailing list group controlled by us, and by signing up with this site 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 competition administrator about this request who will then remove this teacher’s details from the competition database.

We may also share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our site terms of use or to protect the rights, property or safety of our site, our users, and others.

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, on Google Drive storage and/or in accordance with Section F above.

There may also 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 organisation receiving the data is covered by an arrangement recognised by the EU as providing an adequate standard of data protection e.g. transfers to companies that are certified under the EU US Privacy Shield;
  • 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. In particular, the competition hosting service (currently hackerrank.com) is a third party. If you follow a link to any of these websites or use their services during the competition, 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.

Contact information for teachers may be retained to facilitate communication about future competitions.

We do not store any personal information relating to students in the competition database (assuming competition hosting service usernames have been suitably anonymised as advised). In any event, usernames will be removed from the database within one calendar year of each competition closing. This is to enable checking of results and any subsequent enquiries by teachers.  Thereafter, all such usernames will be deleted and team results will become inaccessible (except with respect to any eligible students’ names having being published on this site in accordance with their permission). Anonymous team information regarding gender and yeargroups will be retained for profiling competition uptake over time.

Requests to have data removed at any point should be communicated to pdbaker@perse.co.uk by the school coordinator.

As explained previously, the publication of any students names on this website does not take place without first asking the teachers of the students eligible to be featured on this page to seek and confirm the permission of those students. Any student wishing to be removed can, at a later date, ask to be removed by getting their teacher to send an email to pdbaker@perse.co.uk. (This is in line with our non-communication with students policy and avoids other students impersonating their friends for malicious purposes.)​

J   COOKIES

Our site uses cookies to distinguish you from other users of our site. Cookies are small text files that are placed on your device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.  This site only uses cookies that are strictly necessary for the operation of the site, e.g. to keep track of user sessions.  By using this site you agree that we can place these types of cookies on your device. As outlined above, the competition hosting service is a third-party service and schools using their service to enter this competition should refer to their separate privacy policy before making use of it.​

K   CHANGES TO THIS POLICY

Any changes we may make to our privacy policy in the future will be posted on this page.  Please check back frequently to see any updates or changes to our privacy 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.

M   CONTACT

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 Manager
The Perse School
Hills Road
Cambridge
CB2 8QF

Email:  DirectorOfIct@perse.co.uk with a copy to pdbaker@perse.co.uk

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/. ​

​​Policy last amended: October 2018

The above Privacy Policy should be read in conjunction with the associated site and competition terms and conditions.