Data Policy.
This policy describes the information we process to support includmi. You can find additional tools and information in the includmi settings.
Background information to the includmi service
Includmi is designed to help all chidren and young people flourish. It uses social media type functionality to give them a voice to let education, health and care professionals better appreciate how to help them feel well and happy.
All parents, early years professionals, teachers, lecturers, support staff, and social workers benefit from better communication and information sharing so that they can better support the children and young people in their care.
The app is provided free at the point of use. Local authorities pay for the app. They commission service providers who use the app by adding in children and young people like you and the team members that support you. We provide the organisations who pay for the service, a real time dashboard of how users engage with the app. This is so they can see how well includmi is performing in our role in supporting you.
Includmi’s mission is to make sure children and young people with additional and special educational needs get the integrated support that they need to flourish in life.
The objectives of the includmi app are to:
1. place the child, young person and their family at the heart of service provision and empowering them to live the life they choose.
2. better enable the provision of timely, coordinated education, health and care services, planned in partnership with each child, young person and their family.
I. What kinds of information do we collect?
To provide the Includmi app, we must process information about you. The types of information we collect depend on how you use Includmi. You can learn how to access and delete information we collect by visiting the settings in the Includmi app.
Things you and others do and provide.
Information and content you provide. We collect the content, communications and other information you provide when you use Includmi, including when you sign up for an account, create a support needs profile, share content in your posts, update your wellbeing status, update your one-page profile, chat and message or communicate with others. This can include information in or about the content you provide.
Data with special protections: You can choose to provide information in your Includmi support needs profile and elsewhere on the app about your health, additional and special education needs and disabilities, racial or ethnic origin, philosophical beliefs and sexual orientation religious views, and political views. This data is subject to special protections under GDPR.
Networks and connections. We collect information about the people, teams, service providers and service commissioners you are connected to and how you interact with them, such as people you communicate with the most or schools, settings and colleges you attend.
Your usage. We collect information about how you use includmi, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used Includmi, and what posts, videos and other content you view.
Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use Includmi. This can include information about you, such as when others comment on a photo you post, send a message to you, or view your profile information.
Device Information
As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with includmi, and we combine this information across different devices you use. For example, we use information collected about your use of includmi on your phone to better personalize the content or features you see when you use includmi on another device, such as your tablet.
Information we obtain from these devices includes:
Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use.
Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
Data from device settings: information you allow us to receive through device settings you turn on, such as access to your camera or photos.
Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network,
Cookie data: data from cookies stored on your device, including cookie IDs and settings.
II. How do we use this information?
We use the information we have (subject to choices you make) as described below to provide and support the Includmi app and related services described in the Includmi Terms. Here's how:
Provide, personalize and improve.
We use the information we have to deliver Includmi, including to personalise features and content and make suggestions for you (such as groups or events you may be interested in or topics you may want to follow) on and off Includmi. To create personalised products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide where you have given your explicit consent); how you use and interact with Includmi; and the people, places, or things you're connected to and interested in on and off Includmi.
Information across Includmi: We connect information about your activities to provide a more tailored and consistent experience, wherever you use Includmi. For example, we can suggest that you allow certain teachers or care workers to follow you on Includmi and be part of your team.
Product research and development: We use the information we have to develop, test and improve Includmi, including by conducting surveys and research, and testing and troubleshooting new features.
Provide measurement, analytics, and other business services.
We use the information we have to help partners (such as schools) measure the effectiveness of their services, and understand the types of children and young people who use their services and how children and young people interact with their services.
Promote safety, integrity and security.
We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of Includmi, and promote safety and security on and off of Includmi. For example, we use data we have to investigate suspicious activity or violations of our terms or policies, or to detect when someone needs help.
Communicate with you.
We use the information we have to send you marketing communications, communicate with you about Includmi, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
Research and innovate for social good.
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.
III. How is this information shared?
Your information is shared with others in the following ways:
Sharing on Includmi
People and accounts you share and communicate with
When you share and communicate using Includmi, you choose the audience for what you share – your team. For example, when you post on Includmi, you select the audience for the post, such as a team member, or a customised list of people. Similarly, when you use Includmi to communicate with teachers or schools and settings, those people and organisations can see the content you send. Your team can also see your profile and the actions you have taken on Includmi.
Public information can be seen by people that have been approved to use Includmi by the local authority in your area or by support team organisations (such as your school) that your local authority has commissioned to help you, on or off Includmi. This includes your Includmi username; any information you share with your Support Team. Your Support Team will be made visible to you through requests to view your profile. You will see this under Find Members. It is up to you whether you share your private profile with them.
Content others share or reshare about you
You should consider who you choose to share with, because people who can see your activity on includmi can choose to share it with others on Includmi that you have consented to. For example, when you share a post or send a message to specific teachers or accounts, that information is public to them and the rest of the support Team you have consented to and the administrator of the local authority or service provider that employs your team of professionals - for example your school SENCO is likely to be the Includmi administrator for your school. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone in your approved team.
People can also use Includmi to create and share content about you with the audience you choose. Your Team. For example, people can see and comment on your posts and wellbeing status, mention you in a chat, or share information about you in their messages. If you are uncomfortable with what others have shared about you on Includmi, you can learn how to report the content.
New owner.
If the ownership or control of Includmi changes, we may transfer your information to the new owner.
Partners who use our analytics services.
We provide aggregated statistics and insights that help your local authority, your school and support organisations understand your wellbeing, how people are engaging with their posts, listings, videos and other content on and off the Includmi. For example, administrators of Includmi in organisations that are approved by the local authority receive information about the number of people or accounts who viewed, reacted to, or commented on their posts, as well as aggregate wellbeing, demographic and other information that helps them understand interactions with their service or account.
Local authorities and service providers.
We provide information and content to service providers such as schools who support our business, such as by analysing how our app is used, providing customer service, or conducting surveys.
Researchers and academics.
We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that supports our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and wellbeing.
Law enforcement or legal requests.
We share information with law enforcement or in response to legal requests in the circumstances outlined below.
V. What is our legal basis for processing data?
We collect, use and share the data that we have in the ways described above:
as necessary to fulfil our Includmi Terms of Use
to allow local authorities and those service providers that they approve, such as schools and teachers, to perform their public task
safeguarding concerns can be shared where this is necessary as part of the performance of a task in the public interest or in the exercise of official authority
to allow individuals that are contracted by the local authority or service providers that they have contracted with to comply with specific obligations under the contract.
consistent with your consent, which you may revoke at any time through the Includmi settings and Team settings;
as necessary to comply with our legal obligations
to protect your vital interests, or those of others;
as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalised, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
VI. How can you exercise your rights provided under the GDPR?
Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:
the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications; and
the right to object to our processing of your data where we are pursuing our legitimate interests or those of a third party.
VII. Data retention, account deactivation and deletion
We store data until it is no longer necessary to provide our services, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, when you search for something on Includmi, you can access and delete that query from within your search history at any time, but the log of that search is deleted after the time set by your local authority. We may require that you provide evidence of your identity before we delete that copy in accordance with the information governance requirements agreed with your local authority.
To delete your account at any time, please contact the administrator for you school or setting and they can action this for you.
VIII. How do we respond to legal requests or prevent harm?
We access, preserve and share your information with regulators, law enforcement or others:
In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards.
When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised use of Includmi, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or services), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent mental and/or bodily harm.
Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least three months to prevent repeat abuse or other term violations.
IX. How will we notify you of changes to this policy?
We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our app.
X. How to contact includmi with questions
If you have questions about this policy, you can contact us as described below.
The data controller responsible for your information is the local authority in which you are using the app.
Includmi is the data processor for your information which you can contact at
data@includmi.com
You also have the right to lodge a complaint with includmi’s lead supervisory authority, the Information Commissioners Office, or your local supervisory authority.
Date of Last Revision: 3 December, 2020