Privacy

Mind Recovery Net Privacy Policy

For Learners

If you are reading this you are likely to be attending a short course with a learning provider that uses Mind Recovery Net to manage their short course provision.

At Mind Recovery Net, we take privacy very seriously. We’ve updated our privacy policy to ensure that we communicate with your short course provider who uses Mind Recovery Net in the clearest way possible, how we treat personal information. We encourage You to read this Policy carefully. It will help You make informed decisions about sharing Your personal information with with a short course provider that uses Mind Recovery Net, and as a result sharing your personal information with us.

Mind Recovery Net is an online system that, when used properly by the provider, helps the provider deliver short courses more efficiently and deliver a better service to you.

It requires you to provide personal information to your provider who will in turn input and store that personal information on the Mind Recovery Net software.

Please familiarise yourself with this Privacy Policy on how we treat personal information. You can also read the Terms of Use and Security policies if you are interested.

If you do not wish for your personal information to be stored on Mind Recovery Net please contact your short course provider who will advise you on the options that you have.

For Tutors (both with and without Tutor Corner)

If you are reading this you are likely to be a Tutor with a learning provider that uses Mind Recovery Net to manage their short course provision, including managing their Tutors using Tutor Corner.

Mind Recovery Net is an online system that when used properly by the provider helps the provider deliver short courses more efficiently and deliver a better service to their Service Users.

It requires you to provide personal information to your learning provider who will in turn input and store that personal information on the Mind Recovery Net software.

Please familiarise yourself with this Privacy Policy on how we treat personal information.

If you are using Tutor Corner You are also a User of the website and therefore the Terms of Use apply to You as an Invited User.

If you do not wish for your personal information to be stored on Mind Recovery Net please contact your short course provider.

For Short Course learning providers

This Privacy policy applies to You. It also applies to your Invited Users for which you have responsibilities for, as outlined in the Terms of Use. Please provide this Policy to anyone that wishes to read it.

Privacy Policy

At Mind Recovery Net, we take privacy very seriously. We’ve updated our privacy policy (Policy) to ensure that we communicate to You, in the clearest way possible, how we treat personal information. We encourage You to read this Policy carefully. It will help You make informed decisions about sharing Your personal information with us, or sharing your Personal Information with a short course provider that uses Mind Recovery Net. The defined terms in this Policy have the same meaning as in our Terms of Use (www.mindrecoverynet.org.uk/terms) , which You should read together with this Policy. By accessing our Website and using our Service, You consent to the terms of this Policy and agree to be bound by it and our Terms of Use.

Data protection principles

The GDPR came into force on 25 May 2018 and sets out the principles we, as a data processor on behalf of the organisation that is subscribing to the Service, must adhere to when processing your personal data.

The GDPR principles are as follows:

Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.

We ensure that all the Organisations that subscribe to us have relevant Privacy Policies that any Service User is pointed to as part of accessing their Service. This allows for full transparency that your data is first passed to the Organisation and immediately shared with us as their data processor.

Purpose limitation – data must be collected only for specified, explicit and legitimate purposes.

We ensure that all the Organisations that subscribe to us have specific, explicit and legitimate reasons for collecting your data, as without that they are unable to pass that data to us to help them process it. We do that by ensuring that all Organisations are bonefide Recovery Colleges, recognised by their piers, Trust, CCG or charitable status. Where we have legitimate reason to believe that they are servicing a legitimate purpose, then we will NOT allow them to subscribe to our software.

Data minimisation – data must be adequate, relevant and limited to what is necessary.

We ensure that all the Organisations that subscribe to us have understood carefully what information is necessary to provide the Service to their Service Users in line with their organisational objectives, funding source (which is usually the relevant CCG) or governed by a recognised Trust or charitable body. It is entirely up to the Organisation to decide what data is required to be collected and we cannot and will not unreasonably restrict that. Where we feel that data collected, and stored, on our system is irrelevant or inappropriate, under the rights we have available to us in our Terms of User, we will request that the data is removed, or we will take active steps to do so ourselves.

Accuracy – data must be accurate and, where necessary, kept up to date. Inaccurate data must be erased.

We provide a system to allow the Organisations that subscribe to us to keep accurate data relevant to their Service to their Service Users, and tools to allow the data to be kept up to date, and where necessary data can be deleted by, or on behalf, of the Organisation. We make it clear in our Terms of Use that the Organisation that is subscribing to us is responsible for the accuracy of the data.

Storage limitation – data must only be stored for as long as is necessary.

We provide guidance to the Organisations that subscribe to us to consider carefully their obligations to only store data for as long as is necessary. We do not directly determine this period for any of our Organisations, as it must comply with their own Privacy Policy and operational and organisational requirements.

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Integrity and confidentiality – data must be processed in a secure manner.

We provide a secure system, as defined in our Security and Terms. The Organisations, and their Permitted Users, that they are in control of giving access, are individually and collectively responsible for ensuring that any data that is legitimately exported from the system is kept secure in line with their operational polices and procedures, and ultimately in line with any employment or contractual obligations that they have as individuals to their Organisation.

Accountability – the data controller is responsible for, and must be able to demonstrate, compliance with the other data protection principles.

We support the Data Controller of the Organisations that subscribe to us, as an authorised Data Processor, as defined in their own Privacy Policies, to us to remain compliant with the relevant data protection principles. We do that in co-operation with the Organisation, given the nature and purpose of the system.

Mind Recovery Net collects Your personal information

Mind Recovery Net is a provider of online short learning course management software that’s simple, smart, and secure and gives Organisations real-time visibility of a their short course provision.

The Service involves the storage of Data about an Organisation or individual that provides short courses. That Data can include personal information. “Personal information” is information about an identifiable individual, and may include information such as the individual’s name, address, email address, telephone number.

When you access the services of the Organisation that is subscribing to Mind Recovery Net, then they are collecting your personal information directly from You, as the data controller, when you express and interest, register, enrol or book on a course at the Organisation and immediately share that data with us to help them process that data.

In this instance, You are NOT providing us with your personal information to control.

Mind Recovery Net may collect personal information directly from You when You:

  • register to use the Service,
  • use the Service,
  • contact the Mind Recovery Net support team, and
  • visit our Website.

You can always choose not to provide Your personal information to Mind Recovery Net, but it may mean that we are unable to provide You with the Service.

Mind Recovery Net will receive personal information from You about others (Learners and Tutors)

Through Your use of the Service, Mind Recovery Net will also collect information from You about someone else (Your Tutors and Your Learners). If You provide Mind Recovery Net with personal information about someone else, You must ensure that You are authorised to disclose that information to Mind Recovery Net and that, without Mind Recovery Net taking any further steps required by applicable data protection or privacy laws, Mind Recovery Net may collect, use and disclose such information for the purposes described in this Policy.

This means that You must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, Mind Recovery Net’s identity, and how to contact Mind Recovery Net.

Where requested to do so by Mind Recovery Net, You must also assist Mind Recovery Net with any requests by the individual to access or update the personal information You have collected from them and entered into the Service.

Mind Recovery Net collects, holds, and uses Your personal information for limited purposes

Mind Recovery Net collects Your personal information so that we can provide You with the Service and any related services You may request. In doing so, Mind Recovery Net may use the personal information we have collected from You for purposes related to the Services including to:

  • verify Your identity,
  • administer the Service,
  • notify You of new or changed services offered in relation to the Service,
  • carry out marketing or training relating to the Service,
  • assist with the resolution of technical support issues or other issues relating to the Service,
  • comply with laws and regulations in applicable jurisdictions, and
  • communicate with You.

By using the Service, You consent to Your personal information being collected, held and used in this way and for any other use You authorise. Mind Recovery Net will only use Your personal information for the purposes described in this Policy or with Your express permission.

It is Your responsibility to keep Your password to the Service safe. You should notify us as soon as possible if You become aware of any misuse of Your password, and immediately change your password within the Service or via the Reset Password function (https://[yourlogindomain].mindrecoverynet.org.uk/forgot)

Mind Recovery Net can aggregate Your non-personally identifiable data

By using the Service, You agree that Mind Recovery Net can access, aggregate and use non-personally identifiable data Mind Recovery Net has collected from You. This data will in no way identify You or any other individual.

Mind Recovery Net may use this aggregated non-personally identifiable data to:

  • assist us to better understand how our customers are using the Service,
  • provide our customers with further information regarding the uses and benefits of the Service,
  • enhance short course providers’ productivity, including by creating useful insights from that aggregated data and allowing You to benchmark Your performance against that aggregated data, and
  • otherwise to improve the Service.

Mind Recovery Net holds your personal information on servers located in the United Kingdom

We use top tier, third party data hosting providers’ (currently UKFast) to host our Services on servers located in the UK. Your personal information will not be transferred outside of the U.K. Personal data will remain within Mind Recovery Net’s effective control at all times.

Each and every data hosting provider’s role that we choose to use is limited to providing a hosting and storage service to Mind Recovery Net, and we’ve taken steps to ensure that our data hosting providers do not have access to, and use the necessary level of protection for, Your personal information. They do not control, and are not permitted to access or use your personal information, except for the limited purpose of storing the information. This means that Mind Recovery Net does not “disclose” personal information to third parties. If you are not happy with Mind Recovery Net storing your personal information then you should not provide Mind Recovery Net with your personal information or use the Service.

Mind Recovery Net takes steps to protect your personal information

Mind Recovery Net is committed to protecting the security of Your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your personal information is stored on secure servers that have SSL Certificates issued by leading certificate authorities, and all Data transferred between You and the Service is encrypted. You can find out more about our security arrangements and our data protection measures on our Security statement.

However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that Your information will be secure at all times. Transmission of personal information over the Internet is at Your own risk and You should only enter, or instruct the entering of, personal information to the Service within a secure environment.

We will advise You at the first reasonable opportunity upon discovering or being advised of a security breach where Your personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.

Mind Recovery Net only discloses Your Personal Information in limited circumstances

Mind Recovery Net will only disclose the personal information You have provided to us to entities outside of Action Starter (the ultimate owner of Mind Recovery Net) if it is necessary and appropriate to facilitate the purpose for which Your personal information was collected pursuant to this Policy, including the provision of the Service.

Mind Recovery Net will not otherwise disclose Your personal information to a third party unless You have provided Your express consent. However, You should be aware that Mind Recovery Net may be required to disclose Your personal information without Your consent in order to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify You if we are required by law to disclose Your personal information.

Mind Recovery Net does not store Your credit card details

If You choose to pay for the Service by credit card (only short course training providers are charged for using the platform. Tutors and learners are not. See Pricing for more details.). Your credit card details are not stored by the Service and cannot be accessed by Mind Recovery Net staff. Your credit card details are encrypted and securely stored by Stripe Limited to enable Mind Recovery Net to automatically bill your credit card on a recurring basis. You should review Stripe’s Privacy Policy (https://stripe.com/gb/privacy) to ensure you are happy with it.

You may request access to Your personal information

It is Your responsibility to ensure that the personal information You provide to us is accurate, complete and up-to-date. You may request access to the information we hold about You, or request that we update or correct any personal information we hold about You, by setting out Your request in writing and sending it to us at privacy@mindrecoverynet.org.uk

Mind Recovery Net will process Your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet Your request, we will let you know why. For example, it may be necessary for us to deny Your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for us to process Your request in the manner You have requested. In some circumstances, it may be necessary for us to seek to arrange access to Your personal information through a mutually agreed intermediary (for example, the Learning Provider).

We’ll only keep Your personal information for as long as we require it for the purposes of providing You with the Service.

Mind Recovery Net uses cookies

In providing the Service, Mind Recovery Net utilises “cookies”. A cookie is a small text file that is stored on Your computer for record-keeping purposes. A cookie does not identify You personally or contain any other information about You but it does identify Your computer.

We and some of our affiliates and third-party service providers may use a combination of “persistent cookies” (cookies that remain on Your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when You close Your browser) on the Website to, for example, track overall site usage, and track and report on Your use.

We do not use third party ad services on Mind Recovery Net.

You can set your browser to notify You when You receive a cookie so that You will have an opportunity to either accept or reject it in each instance. However, You should note that refusing cookies may have a negative impact on the functionality and usability of the Website.

We do not respond to or honour “Do Not Track” requests at this time.

You can opt-out of any email communications

Mind Recovery Net sends billing information, product information, Service updates and Service notifications to You via email. Our emails will contain clear and obvious instructions describing how You can choose to be removed from any mailing list not essential to the Service. Mind Recovery Net will remove You at Your request.

You are responsible for transfer of Your data to third-party applications

The Service may allow You, the Subscriber, or another Invited User within the relevant subscription to the Service to transfer Data, including Your personal information, electronically to and from third-party applications. Mind Recovery Net has no control over, and takes no responsibility for, the privacy practices or content of these applications. You are responsible for checking the privacy policy of any such applications so that You can be informed of how they will handle personal information.

Mind Recovery has a privacy complaints process

If You wish to complain about how we have handled Your personal information, please provide our Privacy Officer with full details of Your complaint and any supporting documentation:

  • by e-mail at privacy@mindrecovery.net.org.uk, or
  • by letter to The Privacy Officer, Action Starter Limited, Innovation Birmingham, Faraday Wharf, Holt Street, Birmingham, B7 4AA

Our Privacy Officer will endeavour to:

  • provide an initial response to Your query or complaint within 10 business days, and
  • investigate and attempt to resolve Your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.

This policy may be updated from time to time

Mind Recovery Net reserves the right to change this Policy at any time, and any amended Policy is effective upon posting to this Website. Mind Recovery Net will make every effort to communicate any significant changes to You via email or notification via the Service. Your continued use of the Service will be deemed acceptance of any amended Policy.

Last updated: May 2018

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