All data subjects whose personal data is collected, in line with the requirements of the GDPR by Digital Detail Limited through the use of Digital Detail Limited products (including Homework Diary) and Digital Detail Limited marketing activities.
2.1 The Chief of Operations is responsible for ensuring that this notice is made available to data subjects prior to Digital Detail Limited collecting or processing their personal data.
2.2 All employees and staff of Digital Detail Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention, and their consent to the processing of their data is secured, or the legal basis for processing their data has been communicated clearly.
3.1 Who are we?
The website www.hwdiary.com is run by Digital Detail Limited, Registered in England and Wales, company number: 08853332, registered office: 2 Factory Cotts, Godolphin Road, Helston, Cornwall TR13 8QQ.
When we refer to ’’we’’, ’’our’’ or ’’Homework Diary’’ we are referring to Digital Detail Limited.
The personal data we may collect or process on you is:
|User Type||Personal Data Type||Source||Usage Category|
|Teachers and School Staff Members||Please request this information directly from your school's data controller||School’s MIS System
School’s Active Directory
|Product / Login|
|Students||Please request this information directly from your school's data controller||School’s MIS System
School’s Active Directory
|Product / Login|
|User Type||Personal Data Type||Source||Usage Category|
|All||IP Address||Server Logging||Security|
|Login Attempts||Server Logging||Security|
The personal data we collect falls into different categories (sometimes more than one). Your data will be used for the following purposes:
Product - Information in this category is needed in order to be able to provide Homework Diary to data subjects. In addition it is required to address or deal with any requests or enquiries.
Login - Information in this category is used to ensure we have a unique login method for each data subject in particular to improve website security.
Security - Information in this category is used to ensure the integrity of the Digital Detail Limited servers and protect the data held on them. This data is only held on a temporary basis and is not linked to any user data.
Our legal basis for processing for the personal data:
Students - Our legal basis for processing your data is public interest, as this forms part of the curriculum for your education, and the school has chosen our software as the primary method of communicating homework and other support services to you.
Teachers / Staff Members - Our legal basis for processing your data is public interest, as this forms part of delivering your job responsibilities.
Our data centres in London, France and Germany are run by the following third party:
OVH – https://www.ovh.co.uk/
Digital Detail Limited does not collect or process data defined as ‘special categories’ by the ICO such as: racial; ethnic origin; political opinions; religious beliefs; philosophical beliefs; trade union membership; genetic data; biometric data; health data; data concerning a person’s sex life or sexual orientation.
3.2 Legal basis for processing Student, Teacher and School Staff Member data:
We are processing your personal data based on public interests based on your school (data controllers) instructions. You may object to this processing by contacting your school directly. Your school will then work with us to block any future data coming through to our system. We will then remove / anonymise all your personal data on our system within 28 days of the request being made.
3.3 Legal basis for processing non-registered data Subjects data:
We are processing your personal data based on explicit consent (i.e. as result of an enquiry you have made to our site). You may opt out of this processing at any time by contacting us directly on:
Once you have opted out, we will no longer contact you with information about Digital Detail Limited products and all of your personal data will be deleted and/or anonymised within 28 days.
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available on request about the factors we shall consider when deciding whether information should be disclosed.
You can also get further information on:
• agreements we have with other organisations for sharing information;
• circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
• our instructions to staff on how to collect, use and delete personal data; and
• how we check that the information we hold is accurate and up to date.
Except as set out above, Digital Detail Limited will not pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements. We will never sell your data to third parties.
3.5 Retention period
Digital Detail Limited will process and store personal data for students, teachers and school staff members for the duration of the school’s license with Digital Detail Limited. If you leave the school during an active license with your school, we will delete/anonymise your personal data within 28 days of your account being deleted by your school.
For non-Digital Detail Limited users, we will process and store personal data while we are in contact with you with relevant information on our services. If we have not contacted you for a period of 1 year your data will then be removed from our system automatically.
If you have opted out to your data being processed we will delete your data within 28 days of your opt-out being received.
3.6 Your rights as a data subject:
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review – in the event that Digital Detail Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.7 below.
All of the above requests will be forwarded on should there be a third party involved.
In the event that you wish to make a complaint about how your personal data is being processed by Digital Detail Limited, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Digital Detail Limited’s Data Protection Officer.
The details for each of these contacts are:
Supervisory authority contact details
Contact Name: Information Commissioner’s Office (ICO)
Contact Details: https://ico.org.uk/concerns/
Data Protection Officer (DPO) contact details
Contact Name: Digital Detail Limited DPO
Contact Details: email@example.com
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, Digital Detail Limited, will collect and use your personal data for (i) supporting in the use of our software, (ii) contacting you about key notifications about our software and (iii) in certain cases sending marketing information about our products.
Why does Digital Detail Limited need to collect and store personal data?
For students, teachers and school staff members, in order for Digital Detail Limited to provide those users with our online services, we need to collect and process their personal data for delivering the features within our software to the right person and with the right information.
For marketing purposes we focus on main contacts, network managers or bursars with Digital Detail Limited that have consented to receiving relevant material. In respect to other individuals we will confirm their consent to receive marketing information or contact these users for additional consent.
For non-registered users we need to collect and process personal information on users who have expressed an interest in our educational software, so we can contact them with the relevant information. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Will Digital Detail Limited share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Digital Detail Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to support in delivering our product functionality to our users. When they no longer need your data to fulfil this service, they will dispose of the details in line with Digital Detail Limited’s procedures. We do not currently process any sensitive personal data, however in the future if this changes and we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Digital Detail Limited use the personal data it collects about me?
Digital Detail Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Digital Detail Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Digital Detail Limited contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
If you are a non-registered user, Digital Detail Limited at your request, can confirm what information we hold about you and how it is processed.
If you are a student, teacher or school staff member Digital Detail Limited will need to receive a request from your school (the data controller) to activate a subject access request.
If Digital Detail Limited does hold personal data about you, you can request the following information:
What forms of ID will I need to provide in order to access this?
Digital Detail Limited accepts the following forms of certified ID when information on your personal data is requested:
Once ID has been approved these records will not be retained.
How does Digital Detail Limited protect my personal data?
Digital Detail Limited are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Does Digital Detail Limited collect any other information about me?
When using our products we collect navigational / usage data. This data is anonymised and is not considered personal data. This information can consist of information such as IP address, browser type, date of visit, pageloads and login attempts (whether successful or unsuccessful).
We use navigational / usage information to operate and improve our products on an aggregated basis, and ensure the security and integrity of the system. This information is not stored alongside any personal information, so is not considered personal information itself.
Contact details of the Data Protection Officer / Chief of Operations
Contact Name: Digital Detail Limited DPO Contact Details: firstname.lastname@example.org