All Franchisees are required to have an ICO certificate this must be sent to head office once it has been processed.

Personal data regarding franchisees/employees/licensees and customers is required to be collected processed, issued and stored both manually and electronically when coming in contact with Kalma Baby.  This personal data may at certain times be collected or requested by external sources.  Under the terms of the Data Protection Act 2018 and GDPR and any other data protection legalisation consent is required to enable us to collect process issue and store personal data about you.  Acceptance to a franchise/licence/employment contract and customer bookings with disclaimers is consent to do this.  It is your duty as a franchisee/licensee/employee to ensure all customer personal information is also stored safely and securely in line with this policy and the Data Protection Act.

Disclosure of information: In certain circumstances data from the individual franchise branch maybe shared with Kalma Baby Head office or with other members of the Kalma Baby team.  This for example world be when a franchise branch is sold or transferred and customer data is passed from one franchisee to another.

Kalma Baby are the Data Controller under the Act, which means that it determines what purposes personal information held, will be used for. It is also responsible for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.  Kalma Baby may share data with other agencies such as the local authority, funding bodies and other voluntary agencies. Data collected from customers which includes schools nurseries children centres and nurseries, will be:

• Names parent and child
• DOB child
• health conditions,
• address,
• telephone numbers,
• emergency contact
• photo permissions in class
• email address

This information is required for Health and safety and child protection reasons and for session planning purposes.  The Individual/Customer will be made aware in most circumstances how and with whom their information will be shared with this includes:

Schools

Children centres

Nurseries

When the above request customer information this would be for Monitoring purposes, fire regulations, health and safety in the buildings.

The Individual/Customer will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows Kalma Baby to disclose data (including sensitive data) without the data subject’s consent.  These are:

1. a) Carrying out a legal duty or as authorised by the Secretary of State
2. b) Protecting vital interests of an Individual/Customer or other person
3. c) The Individual/Customer has already made the information public
4. d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights
5. e) Monitoring for equal opportunities purposes – i.e. race, disability or religion
6. f) Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.

Kalma Baby regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.  Kalma Baby intend to ensure that personal information is treated lawfully and correctly.  Kalma Baby and franchisee/licensee/employees adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998.

The requirement of personal information:

1. a) Shall be processed fairly and lawfully and, shall not be processed unless specific conditions are met,
2. b) Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
3. c) Shall be adequate, relevant and not excessive in relation to those purpose(s)
4. d) Shall be accurate and, where necessary, kept up to date,
5. e) Shall not be kept for longer than is necessary
6. f) Shall be processed in accordance with the rights of data subjects under the Act,
7. g) Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
8. h) Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Customers in relation to the processing of personal information.

Kalma Baby will, through appropriate management and strict application of criteria and controls:

• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
• The right to be informed that processing is being undertaken,
• The right of access to one’s personal information
• The right to prevent processing in certain circumstances and
• The right to correct, rectify, block or erase information which is regarded as wrong information)
• Take appropriate technical and organisational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information

Informed consent of Data collection is when an Individual/customer gives their consent and clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data.  Kalma Baby will ensure the data collected outlines the defined in this policy. This applies to data that is collected in person, or by completing online/written form.  We will ensure our individual/customer knows:

• Clearly understands why the information is needed
• Understands what it will be used for and what the consequences are should the Individual/Customer decide not to give consent to processing
• As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
• Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
• Has received sufficient information on why their data is needed and how it will be used

The storage of Information/records relating to Customers will be stored securely and will only be accessible to authorised staff.  It will be stored until it is needed or required statute and will be disposed of appropriately.  It is Kalma Baby/Franchisee/licensee/Employee responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.  All Individuals/customers have the right to data access the information which we hold about them. We take reasonable steps ensuring that data accuracy is kept upto date by asking data subjects whether there have been any changes.  We will ensure that:

• All franchisees have a specific responsibility for ensuring compliance with Data Protection
• Head offices acts as data controller officer and informs franchisees/employees/licencees
• Everyone processing personal information understands that they are contractually responsible for following good data protection practice
• Everyone processing personal information is appropriately trained to do so
• Everyone processing personal information is appropriately supervised
• Anybody wanting to make enquiries about handling personal information knows what to do
• Deals promptly and courteously with any enquiries about handling personal information
• Describes clearly how it handles personal information
• Regularly review and audit the way we hold, manage and use personal information
• It regularly assesses and evaluates its methods and performance in relation to handling personal information
• All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 2018.  In case of any queries or questions about this policy please contact the Data Protection Officer:

Rebecca Riley

Director

07951490757

Website Privacy Policy

This is on each franchisee website and main HQ site.  Should have any queries relating to this please contact HQ.  This privacy policy sets out how Kalma Baby Limited, Kalma baby or any of our franchises branches use and protects any information that you give Kalma Baby when you use this website.

Glossary of Terms

• Data Controller – The person who (either alone or with others) decides what personal information Kalma Baby will hold and how it will be held or used.
• Data Protection Act 2018 – The UK legislation that provides a framework for responsible behaviour by those using personal information.
• EU General Data Protection Regulations GDPR- The European regulations aimed at strengthen data protection.
• Data Protection Officer – The person(s) responsible for ensuring that we follow the data protection policy and comply with the Data Protection Act 2018.
• Individual/customer – The person whose personal information is being held or processed by us for example: a client, an employee, or supporter.
• Explicit consent – freely given, specific and informed agreement from Individual/customer of processing of personal information about them. This is needed for processing sensitive data.
• Notification – Notifying the Information Commissioner about the data processing activities, as certain activities may be exempt from notification. This link is a guide to help you to decide if you are exempt: http://www.ico.gov.uk/for_organisations/data_protection/the_guide/exemptions.aspx
• Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the Data Protection Act 2018.
• Processing – means collecting, amending, handling, storing or disclosing personal information.
• Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual volunteers or employees within (GROUP).
• Sensitive data – refers to data about:

Racial or ethnic origin

Political affiliations

Religion or similar beliefs

Trade union membership

Physical or mental health

Sexuality

Criminal record or proceedings