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Data Controller

The data controller is:

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1.  Why we collect and use your personal data

• To enable you to access the online learning and resources on this site and participate in discussions
• To monitor usage and improve the provision of services
• To ensure access to particular online learning and resources is restricted to those entitled to use them

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2. The categories of data we collect

When you use this site, information in the following categories is collected

• Required Personal Data
• Optional Personal Data
• Technical Data
• Usage Data

Cookies

Two cookies are used by this site:

The MOODLESESSION cookie is essential. It enables your browser to provide continuity and to maintain your login from page to page. When you log out or close the browser this cookie is destroyed from your browser and on the server.

The MOODLEID cookie is optional.  It remembers your username within the browser so that when you return to this site, the username field on the login page will be already filled out for you.

No other cookies are used by this site.       

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3. Details of the data collected and the lawful basis for using your information

Category of Data	Type of Data	Lawful basis for processing
Personal Data	Your Full Name Your email address Date of joining Pathways Learning Platform Which Church of England Birmingham church you attend Pathway of interest Reason for joining Pathways	Necessary for our legitimate interests (to ensure that access to the site in general and to specific resources is only provided to people with the right access to these resources)
Resource Participation Data	Your participation in any online learning or resources on the site is recorded, including any answers to questions or comments.	Your Consent – any participation which is shared will be expressly stated on the individual modules.
Optional Personal Data	You may opt to add information to your profile.	By entering this optional information, you are providing consent for it to be stored.  You can delete/edit it at any time.
Technical Data	browser type and version time zone setting & location  operating systems of the devices used to access this site IP address used to access this service	Necessary for our legitimate interests (provision of administration and IT services, network security and to prevent fraud.)
Usage Data	pages visited on this site interaction with online learning and resources on this site submitted feedback responses	Necessary for our legitimate interests (to ensure that access to particular resources is restricted to specific groups of users, troubleshooting and site optimisation) and to record numbers for evaluation purposes.

Aggregated Usage Data

Data about the use of the various online learning and resources is aggregated and is not personal data. It is used to inform the development of the site and help optimise the use of the site and for evaluation purposes.

 

Legitimate Interest Assessment

We have a specific purpose with a defined benefit.	To provide access to online learning and resources, allow resources to be shared and facilitate communication between site users.
The processing is necessary to achieve the defined benefit.	Technical and Usage Data needs to be collected to provide this service. Details of access to the site are stored for security, for troubleshooting and to improve the site.
The purpose is balanced against, and DOES override, the interests, rights and freedoms of data subjects.	Since the processing of data is kept to a minimum and is for the purpose of a) providing the data subjects with online learning and resources that they wish to use, and b) reporting of evaluative data to fulfil funding requirements, the purpose, and our Legitimate Interest DOES override, the interests, rights and freedoms of data subjects.

For a copy of the full Legitimate Interest Assessment please contact the person named in section 7.

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4. Who we collect from or share your information with:

We collect basic personal information about you from the information you give us and from your participation in resources. We do not collect personal information about you from any other source.

This site provides access and links to different resource providers. We do not provide these sites with any information about you. Each of these will have their own privacy policy and you should read their privacy policies before providing them with your information.

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5. How long do we keep your information?

Data is kept for a maximum of three years after your last access to the site. Each January, any user who has not accessed the site in the last 24 months will have their personal identifiable data deleted. You may request that your personal data is deleted prior to this.     

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6. Your rights

You have the following rights regarding your personal data:

• The right to be informed about any data we hold about you;
  
• The right to request a copy of your personal data which we hold about you;
  
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  
• The right to request your personal data is erased where it is no longer necessary for us to retain such data;
  
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  
• The right to object to the processing of your personal data.
  
• The right to obtain and reuse your personal data to move, copy or transfer it from one IT system to another
  

To exercise these rights, please contact the Data Protection Team using the contact information provided below. The NCIs Individual Rights Policy is available on request.

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7. Queries, complaints or concerns

If you have any queries regarding this processing activity, or how the Pathways Learning Platform handles your personal data please contact, in the first instance:

Alternatively, you can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF