Privacy notice

We are registered as a Data Controller with the Information Commissioner’s Office. This means that we are responsible for:

• determining what information we will hold about you;
• informing you about the personal data we collect about you;
• telling you from where we collect your personal data, if not from you directly
• telling you how we process and utilise your personal data;
• providing details of the legal basis for the processing; and
• telling you if there are likely to be occasions where we will share your data with other agencies or third parties

We have a responsibility to protect your data and comply with legislation, including the Data Protection Act 2018, and we take this responsibility seriously.

The type of information we collect and how we use it are set out below. Some of this information will be provided directly by yourself. On other occasions employers, trainers and other such agencies may provide it. We will only collect and retain information that we require to carry out our functions and/or to provide services to you.

There are a number of legal bases we can rely on to collect and process personal data. These are described in more detail below.

If you are a registered person, the main legal bases on which we rely when processing your information are the legal obligation and public interest legal bases which mean we are obliged to collect certain information about you and process it in certain ways. We may also rely on public interest as the lawful basis for using your contact details for the purpose of sending out newsletters or notifying you of events as we have a legal duty to support the learning and development of registered persons.

The legal bases which can be relied on to process your personal information include:

• Legal obligation - This applies where we need to collect and use your personal information to comply with a legal obligation

• Public interest - As a public body, we collect and use personal information where this is necessary to perform tasks that are in the public interest or to perform our official functions
• Vital interests –we collect and utilise information to protect the vital interests of yourself or of another individual
• Consent - We may on occasion need your consent to use your personal information. In such instances you can withdraw and adjust your consent by contacting us (see below) or manage your preferences within your SCWOnline account if you have one.
• Contract – This applies where we have a contract with you and need to process your personal data for the purposes of the contract. It also applies where we need to process your personal data in order to enter into a contract with you.
• Legitimate interests – We are also entitled to process your personal data where it is in our legitimate interests to do so, or those of a third party. We only do this where we are satisfied that your privacy rights are protected satisfactorily. You have a right to object to any processing of your personal information based on this legal basis.

This privacy notice only applies to the Social Care Wales websites and does not cover other websites that we link to. You should read the privacy notices on the other websites you visit.

Choosing not to give personal information

If you choose not to provide us with certain personal data you should be aware that we may not be able to offer you certain services. For example, we cannot register you if we cannot check your identity and verify your qualifications.

Accessing your data

You are entitled to request a copy of the personal data we hold about you by making a Subject Access Request (SAR). Please send your request through to FOI@SocialCare.Wales. You will have a response from us within 30 calendar days of us receiving your request. We will need to confirm your identity before processing your request. If you require assistance in making a SAR, please contact the Freedom of Information (FOI) mailbox and we will be in touch to offer support.

There is no charge for making a request unless you want an additional copy of the information or your requests are excessive.

You should be aware that in some cases we do not have to provide a copy of the data because an exemption applies. This could be where:

• the data is also the personal data of another person, and it would not be reasonable to disclose it to you without their consent
• disclosing the data would prejudice our regulatory functions, for example by making it difficult for us to conduct a fair fitness to practise investigation.

Further information is available in our Publication Scheme.

Controlling how we use your data

You have some rights under the Data Protection Act 2018 to control how we use your data, by asking us to amend it, delete it or limit how we use it. To exercise these rights, you should contact FOI@socialcare.wales or our Data Protection Officer Kate Salter, via kate.salter@socialcare.wales

You should be aware that there are exemptions from these rights. For example, we do not have to delete information if we are using it for our statutory functions and have legitimate grounds to continue using the data.

If you believe that information we hold about you is inaccurate or incomplete, you can ask us to review the information and correct it/add to it.

If you object to us processing your information or if you wish us to delete your information, please contact FOI@socialcare.wales so that we can consider your request and the basis for it.

Should you wish to change your preferences about how or what we communicate with you, you can do so at any time by contacting FOI@socialcare.wales.

If you have an account on SCW online you can also change your preferences here.

Please note that if you do not wish us to send you communications, we would ideally wish to keep a record of this rather than delete your details completely to avoid you receiving further communications.

If you have consented to us using your image and it has been included in a publication and you wish to withdraw your consent, you should be aware that, we would be unable to destroy all copies of that document. We would, however, cease using the image in any further reproductions from the point at which you withdraw your consent.

We hold information about social care workers who are registered with us. We also hold information about social care workers who apply for registration, and social care workers who are no longer registered.

For registration purposes, we hold information about a registered person’s:

• personal details
• contact information
• identification documents
• qualifications/continuing professional development CPD (previously known as PRTL) information
• National Insurance number
• bank details
• health information

• conviction information
• disciplinary information
• criminal activity
• Data and Barring Services (DBS) listing
• equality information
• EU alerts information.

We receive this information from the registered person, their employers, universities and training providers and other sources required to verify the identify, qualifications and criteria of registration are met.

Why we hold this information

We are required under Section 80 of the Regulation and Inspection of Social Care (Wales) Act 2016 (“the Act”) to keep a register of Social Care Workers including, Social Work Students. We're responsible for making sure those on the register are suitably qualified. We collect and process this information as part of Public Task and Legal Obligations. The information is used for the following purposes:

• process applications and register workers
• maintain our Register
• compile statistics
• record qualification information
• record training, learning and development
• investigate workers’ Fitness to Practise
• maintain our online Register
• update your details
• qualification or return to practise assessment history and scores.
• depending on how they pay their annual retention fee, we also hold bank account or credit card information.

We're required to make some of this information available as follows:

• to the general public on request which will be available on the public Register on our website:
• full name
• registration number and the part/s of the Register on which you are registered
• the postal town where you work
• the fact that you have been removed or suspended from the Register

How we share it

• the outcome of your application and the reasons for our decision to your current social service employer
• we share the following information to your current social service employer and to any other social service employer considering your employment, once you are registered:
• your full work address (unless it is your home address, or we are satisfied disclosure may expose you to danger)
• your qualifications
• any conditions and warnings we impose on your registration
• decisions (and reasons for them) made in relation to your registration, for example, the outcome of hearings which may include suspension and removal from the Register.
• We may share your contact information with third party services than can provide wellbeing support and counselling. To access additional support, some providers may require further information from you using your consent. Please refer to their privacy notice for more information.

We share your information where necessary to assist other organisations to carry out their functions or where the organisation has a legitimate interest in the information. This includes:

• Universities, colleges, awarding bodies, bodies assessing qualifications (etc) to confirm your qualifications
• Various bodies in order to protect the public such as:
• your employer and any other person when needed to protect the public, such as the Police, other Social Service Employers and DBS

• Other UK Social Care Councils, the Health Professions Council (HCPC) and the Care Inspectorate Wales.
• Other regulatory bodies and similar organisations in the United Kingdom and in other countries
• Social Care Wales Fitness to Practise Panels, agents acting on our behalf and expert witnesses.
• European Alert System a system that when it’s predefined criteria (serious potential danger related to a service activity / to the conduct of a service provider) are met allows registered individuals to post and receive alerts on the details of the danger.

If there is a finding that your fitness to practise is impaired we will publish this information in any way that we think is appropriate – currently this is published on our website.

You can read our Fitness to Practise Public Information Policy that explains in more detail how this is done and when we might not publish information.

We hold this information as we have been informed you work in a profession that we register or intend to register and this information would form part of considerations in establishing if you are fit to practice should you apply to us to register in the future. We're responsible for making sure those on the register are suitably qualified.

We collect and process this information relying on the Public Interest legal basis or the Legitimate Interests legal basis and keep it for as long as is necessary to meet our purposes.

What we hold

• personal details
• contact information
• disciplinary information
• criminal information.

How we share it:

We share this information where necessary to assist other organisations carry out their functions or where the organisation has a legitimate interest in the information. This includes:

1. Your employer in order to be able to share the outcome of any application you may make for registration
2. Various bodies in order to protect the public such as:

• the Police, other Social Service Employers and DBS
• Other UK Social Care Councils, the Health Professions Council (HCPC) and the Care Inspectorate Wales
• Other regulatory bodies and similar organisations in the United Kingdom and in other countries
• Social Care Wales Fitness to Practise Panels, agents acting on our behalf and expert witnesses
• European Alert System a system that when it’s predefined criteria (serious potential danger related to a service activity / to the conduct of a service provider) are met allows registered individuals to post and receive alerts on the details of the danger.

We regularly review our retention of information for this category of people. We will contact you again if/and when we receive updates or any clarification that suggests we should not retain the information.

The information we hold:

• personal details
• employment details
• contact information

We hold this information to:

• permit employers to fulfil the counter signatory/endorsement role required under the Registration Rules
• process applications

• enable verification of documents
• allow employers to have Social Care Wales Online ‘Employer Access’.

The information provided by you is held by us relying on the Public Interests lawful basis.

If you move jobs the organisation you work for should inform us. You can also do so and request we delete any accounts or records.

We do not share the personal information we collect in this way for this purpose, although applicants and registrants will be directed to the available endorsers for them via Social Care Wales Online.

The information we hold:

• personal details
• health information
• criminal information
• equality information
• qualification information
• CCTV footage (St Asaph Office).

We receive and process this information as part of a possible contractual obligation, or where it is in our Legitimate Interests to do so.

We use this information to:

• recruit and employ staff

• manage employment relationships
• ensure security of staff and premises
• comply with our legal obligations

The information is obtained directly from you, including the information you provide in a CV or covering letter or on our application form and at interview.

We may also obtain information from a third party such as a recruitment agent or via an on-line jobs board. We also create information ourselves during the recruitment process and obtain information about you from other sources to undertake various checks.

We may share some of this information with those involved in the recruitment and with referees and education organisations for verification purposes should you be successful.

Equality information is not mandatory information – if you don’t provide it, it will not affect your application. Any information you do provide will be used only to produce and monitor equal opportunities statistics.

For current and previous staff members the information we hold is:

• personal details
• health information
• criminal and disciplinary / grievance information
• equality information
• qualification information

• CCTV footage (St Asaph Office)
• financial information
• information regarding any conflict of interest
• Trade Union membership
• Photographs and videos
• Employment history.

We receive and process this information as part of a possible contractual obligation, , or where it is in our Legitimate Interests to do so.

We use this information to:

• employ staff
• manage employment relationships including pay, pensions, training and development, staff performance management
• ensure health, safety, wellbeing and security of staff
• comply with our legal obligations as an employer
• Promote training and development on our internal systems
• ensure staff training and development is fit for purpose
• monitor that our Dignity and Respect at work Policy is working
• provide a Staff ID and use this photo for electronic communications (e.g. .Microsoft Office profile picture, Teams, Sharepoint)
• Manage customer relationships e.g. staff profiles, blogs and contact information
• Promote our events

• The information is obtained directly from you either as part of your contract agreement, including the information you provide in a CV or covering letter or on our application form and at interview, or a written submission directly from you e.g. staff profile for the website.

We may also obtain information from a third party as part of the initial recruitment process and obtain information about you from other sources to undertake various checks.

We share relevant information with:

• Our payroll provider
• Her Majesty’s Revenue and Customs (HMRC)
• Our pension provider
• Our Employee Benefit Scheme Provider
• Our wellbeing service (Employee Assistance Programme).

Equality information is not mandatory information and all special category information will be processed using additional security measures due to its sensitivity. Any information you do provide will be used only to produce and monitor equal opportunities statistics.

We may share your health information with a third party acting on our behalf in matters of occupational health. On such occasions you will be invited to consent to the information being shared.

We may also take photos and videos of you at training and events. These may be shared on our internal intranet pages. You can request for your image and other personal information e.g. staff profileto be removed from external facing sites at any time by contacting FOI@socialcare.wales

Any member of staff wishing to make a subject access request for personal information relating to them should contact FoI@socialcare.wales.

We hold information about members of the public that use services or whose family members use services in which people registered with Social Care Wales are employed.

The information we hold which may be received as part of our fitness to practise investigations, includes:

• personal information
• health information

• care arrangements
• criminal activity.

We receive this information from various sources including employers, regulatory agencies, complainants and registered persons. We hold this information under the Public Interest lawful basis and we utilise it to:

• investigate and make decisions about a social care worker’s fitness to practise.

We might share this information with:

• Fitness to Practise Panels, agents acting for the Social Care Wales, expert and other witnesses and other regulatory agencies as appropriate
• Members of the public (including representatives of the media) who are entitled to attend public Fitness to Practise hearings. Social Care Wales take all reasonable steps to ensure that the identity of individuals who use services, especially where they are vulnerable, is not made public.

We produce a range of materials in a variety of formats to promote good practice, developments and resources that can add to knowledge and help improve practice within the sector.

What we hold:

• contact details
• areas of interest.

To enable us to:

• send out information in interested areas
• distribute a newsletter
• invite to attend events, webinars, training or learning
• send out surveys.

We have a legal obligation under Section 68 of the Regulation and Inspection of Social Care (Wales) Act 2016 to promote and maintain high standards in the provision of care and support services and may use information collected from the Register to engage with you.

Sometimes we may require your consent* to retain this information and will make it clear on the invitation or communication.

We might share this information with third parties who may process it on our behalf to help us contact you. We ensure that any third parties we use to help us comply with Data Protection Act 2018.

Should you wish to change your preferences about how or what we communicate with you, you can do so at any time by contacting FOI@socialcare.wales

If you have an account with SCW online you may change your preferences here

Please note that if you do not wish us to send you communications, we would ideally wish to keep a record of this rather than delete your details completely to avoid you receiving further communications.

*Registered persons are unable to stop all correspondence with us as we are obliged to send you correspondence in relation to registration, relevant qualifications and CPD opportunities and we rely on our legal obligation lawful basis to do this.

Through our media campaigns, events and other projects we often ask consent to capture photos/videos or stories for the benefit of promoting our work, good practice and developments within the sector. If you consent to this you are able to specify how we can use your information and in what format i.e. social media, on-line on our website, press stories, in our printed literature and promotional material.

We hold:

• personal stories
• photos
• videos
• contact information from you solely for the purpose of communicating with you in relation to this matter.

We hold this information to:

• promote our work and services
• to assist with the training and development needs of the workforce.

We share this information with:

• the general public via social media, our website and resources.

Your personal information and associated consent is kept by us and may be used in the formats you have agreed for up to five years. Should you wish to revoke your consent at any point during that period, you can do so by contacting FOI@socialcare.wales.

You should be aware that where your information is shared, with your consent with a third party, such as the press on put on social media, the Privacy Notice and retention period of the relevant third party will apply and we have no control over this.

We hold:

• names
• contact details
• job role
• place of employment
• access requirements
• dietary requirements

We hold this information to:

• manage our events
• assist with training and development
• gain feedback on our existing and future work.

• to keep you informed and updated of current and future work.
• build and support networks and communities of practice

We do not share this information, but on occasion utilise third party software to send details, manage the bookings and circulate surveys. All third party software is compliant with the Data Protection Act 2018.

We may also, at times, use a third party facilitator to lead meetings or forums. Any access to data will be managed by our contract with the facilitator and they will be expected to sign a confidentiality agreement as part of that process.

In order to enable event attendees to network effectively at our events, we may share delegate lists. Let us know if you do not wish your details to be shared.

We hold:

• names
• contact details
• place of employment
• CCTV footage

We hold this information to:

• manage our security and health and safety obligations. We hold use visitor registers at our offices which are used for roll call following evacuation e.g. in the event of a fire.
• we record CCTV images of people entering and leaving our premises as well as strategic positions surrounding the building. This information is recorded for security monitoring and the investigation of alleged criminal offences. The images may be shared as part of disciplinary matters or with law enforcement and courts as needed.

Where we are not the sole occupier of the building there is additional CCTV which is controlled by the building owners.

We hold:

• personal details
• contact information
• financial information
• work and personal background information
• equality information.
• dietary requirements
• accessibility requirements / additional support requirements
• criminal and disciplinary / grievance information
• qualification information as part of skills analysis
• information regarding conflicts of interest through register of interest
• political party membership

We hold this information under the Public Interest and Contract legal bases in order to:

• communicate with Board Members in the course of the work of the Board and/or Committees
• for recruitment purposes to enable a cross section of experiences and expertise on the Board
• pay fees and expenses.

We obtain the information directly from Board and Independent Members or prospective Board Members, but we may also obtain it from a third party such as a recruitment agent. We also create information ourselves during the recruitment process and obtain information about from other sources to undertake various checks.

We may share some of this information with those involved in the recruitment process and with referees for verification purposes.

Any equality information is only used only to produce and monitor equal opportunities statistics.

We share names and biographies of Board members with the public on our website.

We hold:

• name
• contact email address
• job title
• local authority
• who you work for (name of employer)
• preferred language of communication.

We hold this information to:

• provide you with access to a digital card
• communicate with you
• generate a unique reference number to identify the card.

We share the unique reference number with third parties who provide discounts in relation to the card – we won’t share your personal information with any other parties. To access some additional discounts, some providers may require further information from you using your consent. Please refer to their privacy notice for more information.

The information we hold which may be received as part of our fitness to practise investigations, includes:

• personal details

• financial information.
• personal information
• health information
• care arrangements
• criminal activity.

We hold this information relying on the legal obligation lawful basis to:

• investigate and make decisions regarding a social care worker’s continuing fitness to practise
• enable payment of expenses.

We might share this information with:

• Fitness to Practise Panels, agents acting for Social Care Wales, expert and other witnesses and other regulatory authorities.
• Members of the public (including representatives of the media) who are entitled to attend public Fitness to Practise hearings. Social Care Wales take all reasonable steps to ensure that the identity of witnesses, especially where they are vulnerable, is not made public.
• Third party services than can provide wellbeing support and counselling. To access additional support, some providers may require further information from you using your consent. Please refer to their privacy notice for more information.

We hold information about current, former and potential fitness to practise panel members.

The information we hold:

• personal details
• health information
• criminal information

• equality information
• financial information
• personal and commercial interests
• information regarding number of times sat on hearings
• any complaints received about members and any documentation in relation to investigating such complaints
• appraisal and personal development information
• qualification information
• CCTV footage (St Asaph Office).

We collect and process this information on the contractual and Public Interest lawful bases. We use this information to:

• contact our members
• ensure duty of care is maintained
• recruit and appoint panel members
• manage the administration and governance procedures for panel members appointment and reappointment
• ensure panel member training and development is fit for purpose
• ensure panel members performance and conduct complies with Social Care Wales panel member competencies and our values
• process daily rate fees and expenses
• monitor that our Dignity and respect at work policy is working

We obtain the information directly from Panel members or prospective Panel Members, but we may also obtain it from a third party such as a recruitment agent. We also create information ourselves during the recruitment process and obtain information about from other sources to undertake various checks.

We may share some of this information with those involved in the recruitment process and with referees for verification purposes.

Any equality information is only used only to produce and monitor equal opportunities statistics.

We share this information with:

• Her Majesty’s Revenue and Customs (HMRC)
• Rhondda Cynon Taf who undertake our Payroll function
• third parties who provide our information systems and process this information on our behalf all of which are GDPR compliant.

We hold:

• personal details
• contact details
• Nature of complaint or concern.

We hold this information to:

• seek further information
• allow a decision to be made on a social care worker’s initial or continued assessment of fitness to practise for registration.

We might share this information with:

• Fitness to Practise Panels, agents acting for Social Care Wales and expert witnesses.
• Members of the public (including representatives of the media) who are entitled to attend public Fitness to Practise hearings. Social Care Wales take all reasonable steps to ensure that the identity of complainants, especially where they are vulnerable, is not made public.

We hold:

• personal details
• contact details
• nature of complaint.

We hold this information to:

• comply with our statutory requirement to manage complaints.

We do not share this information externally although we may publish anonymised statistics and details about complaints.

We retain the content of the complaint permanently as a corporate record.

We use Clobba software provided by Code Software UK ltd for our General Enquiries telephone system. The software used meets the requirements of ISO27001

Only code engineers have access to customer data on a need to know basis for set up and support purposes.

Code Software systems and data are hosted in Microsoft Azure hosted data centres in the EU.

Code software are registered with the Information Commissioner and are compliant with UK Data Protection Act 2018 and GDPR.

The retention period for data is currently 2 years or deletion on request.

The information collected includes:

• Calls (voice, Video and Audio Conference)
• Call detail records
• Name, email address, department, title

• All Teams meetings details including chats
• App sharing

This information is used for:

• responding to enquiries
• performance reporting
• providing IT/ call management assistance as and when required.

We are currently piloting a chatbot feature on our website. This feature can be used if users have a query relating to qualifications.

Our Supplier for the Chatbot feature is the Logic Dialog Platform.

If a user asks a question which is out of the scope of the chatbot it will ask for their consent to send their chosen contact details to a member of the qualifications team.

If users chose to send their contact details they will have the choice of sharing the following:

• email address
• contact number
• preferred method of contact

This information will be automatically deleted after 12 weeks.

The Logic Dialog Platform holds ISO20071 certification and is GDPR compliant.

We conduct and commission research on a range of topics to support our statutory remit. These relate to registration, fitness to practise, recruitment and retention. We generate statistics based on the information we hold, for example the National Social Care Data Set for Wales.

We hold:

• personal details
• information submitted by the person involved in the research

We hold this information to:

• carry out our statutory workforce intelligence function. We share this statistical information with the public on our website and in our profile reports however it is published anonymously.
• We may also share anonymous data with third parties for research purposes but any research projects must meet the criteria of our Research Support and Engagement Framework before it can be shared. The findings of any research projects using our anonymous data will be published on our website.

We provide a free coaching service to support promising social care innovations across Wales. The service is for people in social care roles who are working to innovate or improve their practice to deliver better care services.

We will hold:

• Name
• Contact details
• Organisation details
• We may ask for additional information depending on the coaching programme/ event or activity. This may include optional details, for example accessibility or dietary requirements.

We use this information to:

• provide the innovation coaching service
• provide resources and services to support you
• connect you to a wider community e.g. the coaching alumni
• develop and improve our coaching service

We collect information about you when you: 

• apply for Innovation Coaching services, 
• take part in one of our courses/events, 
• complete coaching programme and course/event evaluations and surveys 
• take part in diagnostic and coaching activities. 

If you would like us to change or delete these optional details, please contact us at FOI@socialcare.wales. 

We might share this information:

• with partner organisations and/or contractors involved in the provision of this service such as coaches from partner organisations. They will have signed up to a data sharing agreement to protect and manage your data in line with Data Protection legislation
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation

For the purposes of this service we collect and process this information as part of our legal obligations. Under section 69 of the Regulation and Inspection of Social Care (Wales) Act 2016 (“the Act”) we may give any person providing a care and support service advice or other assistance (including grants) for the purpose of encouraging improvement in the provision of that service.

We will keep your personal information (including all successful and unsuccessful applications) for 13 months after we have evaluated the course/event. This enables us to report on our activity and use evaluation data to improve future courses/events. After this point we will anonymise your information. 

For some programmes we need to keep some of your information for longer than 13 months. For example, we need to keep financial records for the standard Welsh Government period of 7 years. 

If you would like to update your details or if you no longer wish to be contacted for collaboration purposes, please email FOI@socialcare.wales

We have developed a ‘Project finder’ service as part of our Insight Collective platform. The aim of Project Finder is to curate an online collection of research and innovation projects from social care practice across Wales. This could include a service, model, product or research project, with the aim to support the spread of innovations and research by sharing information and lessons learned. Please note: the projects featured are not endorsed or sponsored by Social Care Wales.

We hold:

• Project lead name
• Project lead email address
• Postcode of the project
• Organisations website address (if applicable)
• Organisation collaborators who have been involved in developing the project

We hold this information to:

• Share on our public website to achieve the aims of Project Finder
• Contact you to ensure that the information remains up to date

For the purpose of this this service, we collect and process this information using the Consent legal basis. You can withdraw your consent at any time, without reason, by contacting FOI@socialcare.wales.

We work with employers to find out about what's happening in the sector and to support them in their roles. We share this information with the rest of our organisation to help:

• Provide the ‘Employer Offer’

• shape our work
• share what's available to employers to support them and the workforce
• help employers to understand their regulatory responsibilities and make this as straightforward and efficient as possible.

This work focuses on adult social care employers.

We hold:

• Name
• Contact information
• Job title
• Organisation
• County

We use this information to:

• Engage with adult care employers
• To provide employer support
• To provide information and events
• Contact you for feedback and evaluation

Employers will be able to opt out at any time by contacting the team or by contacting FOI@socialcare.wales.

We hold:

• personal information
• contact details.

We hold this information to:

• comply with statutory requirements
• process requests for information
• compile statistics.
• consider if our publication scheme is sufficient

We keep the content of these requests for the following time:

• Freedom of Information requests that are still classed as open are kept for 1 year. Documents which are subsequently opened are kept for 2 years.
• Freedom of information requests which have been closed are kept for 10 years.
• Subject Access Requests are kept for 5 years

We might share this information with:

• the Information Commissioner’s Office
• the public when we publish Freedom of Information requests and responses on our website, although such information is published anonymously.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently, as well as to provide analytical information to the owners of the site.

We use Civic Cookie control to manage cookie permissions.

Consent mode, the consent state and Civic is managed within Google Tag Manager (GTM)

By default, consent mode is set to deny as any page loads on our sites. Until a preference has been made no cookies will be placed on the

users browser and the Civic cookie banner will remain present

On first visit, you are presented with the option to set your

preferences and can accept or reject cookies in their preferred

language using Civic.

The Civic cookie banner will provide users with information about the

categories of cookies are used on the site and allow them to set their

preferences for each category

• You can update their cookie preferences at any point during a visit
• Preferences made in Civic are recorded by Civic
• User preferences made in Civic update the consent state in GTM
• Updates to the consent status (accept/deny) will allow/block tags in.GTM preventing cookies from being set

We have one main website in addition to a number of specific purpose sites.

When someone visits our sites we collect standard internet log information such as the page they asked for, internet protocol address, browser type, browser language, the date and time of the request. We do this to find out things such as the number of visitors to the various parts of the site.

We collect this information in a way that does not identify anyone. We do not attempt to find out the identities of those visiting our website. We will not associate any data gathered with any personally identifying information from any source.

If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

The information we hold:

• IP address. Collected via Google Analytics

We hold the information to:

• collect standard internet log information
• compile statistics.

We share this information with:

• third parties who provide our information systems and process this information on our behalf.

We embed videos from our official YouTube channel using YouTube's privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

The search engine on our website is provided by Craft CMS. If you have accepted the use of cookies, when searching our website a record of your search term is logged and stored within Google Analytics, this information is used to help us improve the content our website.