Legal and Privacy Statements
(Terms and Conditions)
1.0 coms4kids (coms4you Ltd) overview of privacy and data protection
- At coms4kids we believe that privacy and data protection are human rights
- We believe that data is a liability (we teach children this too) and should only be collected and used when absolutely necessary
- We hate spam as much as you do and endeavour to prevent spam at every opportunity
- We will never sell, mis-use, make public, or distribute your personal information.
2.0 We cover ALL the relevant legislation and laws
2.1 Legislation and Laws
This website is designed to comply with all the relevant and current legislation on data protection and privacy. Links to the relevant legislative websites can be found below:
Our internal computer systems are also compliant with this legislation, for example we do not keep lists of students and parents and contact details for promotional purposes. All our data is password protected and physically stored on separate archive devices for no longer than one year. Clubs roll on and children move on to other schools. Their data is deleted as it is not required for the purpose of enrolment in new clubs.
2.2 Website Statement
Whilst the information provided on this website is given in good faith by coms4you Ltd, no warranty or representation is given concerning such information which must not be taken as establishing any contractual or other commitment binding upon coms4you Ltd. Furthermore, whilst coms4you Ltd uses reasonable efforts to include accurate and up-to-date information on the website, to the extent permitted by law, coms4you Ltd make no warranties or representations as to its accuracy. To the extent permitted by law, coms4you Ltd excludes all liability to third parties arising directly or indirectly from their use of or reliance on information or materials contained in this website.
The Web site may contain references or links to other websites on the Internet which are owned and operated by third parties. Those references or links are not an endorsement of those third parties or their products or services. coms4you Ltd reserves the right to revise this website at any time.
3.0 Personal information collection by our websites
3.1 Tracking visitors to our website and cookies
At this stage we do not use Google Analytics to track visitors to our websites. Neither do we use an analytics program, display advertisements or have affiliate links. We therefore do not require persistent cookies which would require us to show the cookies popup (EU Cookie Directive 2011). However, all websites use session cookies (tiny pieces of information which speed up loading, or assist with other functionality). These are created automatically through your browser when you visit our websites but only exist during a session. We therefore do not need your permission with regard to cookies because we aren’t using them, but we have included the EU Directive ‘cookies popup’ statement with a link to this page anyway.
3.2 The coms4kids website blog/news
Even though our website has a live blog, we have not activated the comment field on this system. This means we are not collecting any personal information about you through comments. Should we start using this facility, then these guidelines will change and we shall include a section whereby you can request the disclosure of any personal information held by the website database and associated systems. You will also be able to request that any personal information be deleted. We take child safety extremely seriously. This is a core part of our business which is why we do not encourage the open publicity that a blog can bring together with its susceptibility to spam comments and inappropriate behaviour by individuals on the web who’s aims are negative.
3.3 Email and contact forms / application forms
We use a simple code on our websites to encrypt email links. This means that spam bots are unable to harvest our email and subsequently spam us or use our email to spam others. This system is not 100% proof, but we do our best to prevent spam at every opportunity. If you use a contact form on our website, then none of the data you supply is stored on our websites or passed to or processed by any third party. The data collected is collated into an email and sent in a standard way using the SMTP (Simple Mail Transfer Protocol). All email addresses and mail servers are protected by our UK based hosting company using TLS (sometimes known as SSL). This simply means that your details sent are encrypted before being sent across the internet. On arrival, the content is decrypted by local devices at the coms4kids office.
Contact information from the contact email is used to respond to enquiry or send information as appropriate. The individual’s contact information is also used to get in touch with the individual when necessary. Such Contact information is never disclosed to a third party. Your contact information is only stored on secure mail software, e.g. Mac Mail or Outlook when we are required to maintain a business relationship with you, e.g. you provide us with a service or your enquiry remains active. We are required as part of our safeguarding and child protection obligation to keep correspondence with parents about clubs involving their children. These emails are held securely while the child is in clubs, and then archived securely thereafter. This information is not used for promotional purposes and will never be available to a third party.
4.0 How we store your personal information
(Also see section 3.3 regarding emails and contact forms) At this time, none of your personal information is stored inside a database on the server for our websites. This is because we are not using the blog functionality of the website with the comment field turned on. The only exception to this is for our website design clubs where a single name of a child is used in the admin table to identify that that website belongs to the child in question. All websites used by children are password protected and cannot be viewed by the public without that password. No other identifiable information is included anywhere on the children’s websites and sites can be accessed for inspection by parents, teachers and the coms4kids administrator for the club.
At this time GDPR requires pseudonymisation. Put simply, this means that an identifier (code) is added to sections of personal information which links this information together. The pieces of information are then separated. Without the code, your personal information and identity cannot be linked together. As stated, we do not at this time collect or store any of your personal information through our websites. Almost all web applications using a Content Management System (CMS), e.g. WordPress (this site), Joomla, Drupal, Wix, Weebly etc do not yet comply with this part of the legislation. For example, as of 2018, there are nearly 500 million WordPress sites on the web and none of them yet meet this requirement. It will take some time for this change to be developed by the application developers. As soon as it is available, then we shall implement it on all our websites.
5.0 Our hosting company is as secure as it can be
For all our websites we use a reputable UK hosting company. The hosting company industry is largely unregulated and many of the largest companies do not use sufficient levels of diligence to prevent hacking or other data breaches. The company we use complies with the Data Protection Act 1998 and has numerous measures to prevent compromise of websites and data. Our sites (including club websites used by children) are secured in a ‘container’ that includes round the clock protection from hackers using their customised WAF (Web Application Firewall). They also maintain up to date software and have closed the main routes often used by hackers. All traffic to/from our sites use encryption via https: (SSL – security certification). No website is 100% secure, but at coms4kids we endeavour to ensure that everything we do online is as secure as it can be.
6.0 Third part data processors
At this time we are not using any third part data processors, but if that changes, then these policies will be updated.
7.0 Data breaches
We undertake to report any unlawful data breach relating to our websites or their databases, and any other source from hardware and software used at coms4kids (coms4you Ltd). We will report this breach to all the required authorities within 72 hours as is the requirement under the GDPR legislation.
8.0 Who to contact
If you have an questions or concerns with regard to data or this policy, then please contact:
Director, coms4you Ltd
t: +44(0)1483 459674