Link Maker Systems Limited (hereafter "we" or “us”) are committed to protecting and respecting your privacy.
This policy (together with our terms of service and any other documents referred to in it) sets out the basis under which any personal data we collect from you, that you provide to us, or that we collect from other sources about you, will be processed by us.
This policy applies where you use our website “Link Maker” (www.linkmaker.co.uk) (hereafter referred to as "our site") or communicate with us in relation to our site or our services, whether as a guest or a registered user. “Use” of our site or services includes accessing, browsing, registering to use, uploading content to our site, downloading content from our site, or communicating with us.
Responsibility for personal data
Our site and the services available using the site is a platform to enable an organisation licensed to provide adoption or children’s social care services (such as a local authority, an adoption agency or an Independent Fostering Provider (which we refer to as an “Organisation”) or an individual registered with one of those organisations, to upload and manage their own information, and to access information uploaded by others. This includes:
- Organisations may upload information to our site about children who require adoption or fostering, or about prospective adoptive or foster parents who have registered with that organisation.
- Prospective adopters and foster carers registered with an organisation may upload their information to our website as part of using the services of that organisation. which may be accessed by organisations registered with us.
- Information that is uploaded to our site may then be accessed by other users registered with us, including prospective adopters and foster carers registered with an organisation, or organisations acting on their behalf.
- Organisations may transfer case files, using our site, to other Organisations. For example, where another organisation has been employed to family-find on behalf of an organisation.
We act as a processor (rather than a controller) in relation to personal data which is uploaded to our site and where that personal data is accessed via our site – which means we act on behalf of the organisations and individuals which upload information to our site for the purposes of using our services. That means that you, as the user uploading information to our site, are responsible for deciding what information to upload, how that personal data is used, and when it is updated or deleted, in addition to your own obligations as a controller under the applicable data protection legislation. For example, you must comply with the data protection principles as set out in the EU’s General Data Protection Regulation, which you can find out more about here www.ico.org.uk. In particular, any information which you access, download or store, must be handled and stored securely, and not disclosed without authorisation.
We do have obligations as a processor under the applicable data protection legislation, which we have reflected in this policy, and our terms of service.
We also process some personal data as a controller – which means that we are primarily responsible for it and make decisions about how that personal data is used. This relates to how you use our service at a technical level, and for our own statistical analysis to help improve the service. For example, we may collect information about your browser, and computer operating system to allow us to provide an efficient browsing experience. We have set out how we process this type of personal data in more detail below.
We have appointed a security officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the the security officer using the details set out below.
Our full details are Link Maker Systems Limited. Our registered office at Alpha House, 176a High Street, Barnet, Hertfordshire EN5 5SZ. If you want to contact us in relation to this policy, please contact the security officer by phone 0843 886 0040 or by email to email@example.com
Information we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal data in two broad categories (1) where we use that personal data for our own purposes (where we act as a controller), and (2) where we process personal data on your behalf (where we act as a processor).
Information we may collect where we process personal data on your behalf (where we act as a processor)
For Adopters and Foster Carers
- Social profile data which you give us – You may share information about yourself via the community support network. This includes the information you provide in relation to your profile to make use of the community network functionality on our site. This will include details of family make up, interests and hobbies but you control this information, and can remove it whenever you wish.
- Case data which you give us. We will receive information about adopters or carers for whom you are acting, or where an Organisation has allowed the adopter or carer to upload their own information, and about the child/children being profiled for whom you are acting. We call this “User Content”, which includes: Family case data - The information we receive in relation to adopters and foster carers for whom you are acting. This may include name, address, e-mail address and phone number, personal description and photograph, basic details about adopters and foster carers or other members of their household, and such other information as may be required by the relevant Organisation to demonstrate suitability to provide adoption and fostering care services. The required data includes, whether expressly or by implication from the data supplied, special categories of personal data so that a third-party organisation can consider suitability for placements. For example, ethnic origin, religion, physical and mental health, and sexual orientation or information about criminal convictions and offences.
- Child case data - The information you give us in relation to a child for whom you are acting, to be profiled on our site. This may include the child’s name, address, age, personal description, photograph, details of any specific health and development issues and past life experiences and such other information as may be required by an Organisation to assess a child’s need for adoption and fostering care services.
- Activity data - Data on expressions of interest you have made or received on behalf of a sibling group or family, the outcome of the expressions of interest; audit logs detailing who has added, edited or amended content and when. We provide this information to the user which uploaded the information to allow them to monitor family finding activity and establish accountability for changes to profile data.
Information we receive from other sources
We may receive information about you from local authorities or registered adoption/fostering agencies: For example, if you are an individual seeking to register to use our site, we check the identity of all new users with the registered Organisation and share with such Organisations the information submitted by you to this end. By submitting such information to us, you authorise us to share such information for these purposes.
- The Organisations which use our system may ask you for special categories of personal data and criminal offence data, or may share via our site family case data or child case data which may contain such sensitive types of data. This type of data is only used by an Organisation to consider an individual’s suitability for placements. Sensitive data relating to criminal convictions is in most cases shared in encrypted documents and we are not able to view the content of those documents. Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, and information about your health. Criminal offence data includes data in relation to criminal convictions and offences (including data about criminal allegations, proceedings or convictions) or linked to related security measures.
Information we collect where we use that personal data for our own purposes (where we act as a controller)
We may collect, use, store and transfer different kinds of personal data about you for our own purposes, which we have grouped together as follows:
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical data, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;.
- Usage data, which includes information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); frequency and number of views of particular profiles; application logs detailing who has added, edited or amended content and when; methods used to browse away from the page and any phone number used to call our customer service number.
- Identity data which includes first name, last name, username, title, gender, Organisation with which you are registered or which you represent, password, PIN and user type i.e. Adopter, foster carer or practitioner of an Organisation.
- Contact data which includes address, email address and telephone numbers.
- Transaction Data -
- which includes details about the products and services you have purchased from us.
- Where you pay for our services our payment services provider (Stripe) collects details about payments (bank account and card payment details) to process your payment. We do not collect financial data from you , and Stripe does not disclose your financial data to us.
- Marketing and communications data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We also collect, use and share aggregated data such as statistical or demographic data for any purpose. This aggregated data may be derived from your personal data but it is anonymised (this data does not directly or indirectly reveal your identity and therefore it is not considered personal data in law). For example, we may aggregate your usage data to show how many views a profile has had. We may aggregate your profile data to show the number of adopters in the country who have registered with a particular ethnicity, in order to show the national sufficiency of adopters or foster carers. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.
- We do not collect any special categories of personal data or information about criminal convictions and offences, except to the extent that such data is included in the information uploaded by you to our site where we act as a processor.
- Information we receive from other sources. We are also working closely with third parties (including, for example, Organisations, sub-contractors in technical, payment and delivery services, analytics providers, search information providers) and may receive information about you from them.
If you fail to provide personal data
Where an Organisation requires specific information about an individual in order to make a placement assessment or decision, where we need to collect personal data by law, or where the terms of a contract we have with you require it, and you fail to provide that data when requested, we may not be able to provide our services (for example, to provide you with access to our site and services). In this case, we may have to reject or cancel your account registration, but we will notify you if this is the case at the time.
How your personal data is collected (where we process your User Content and act as a processor)
Where we are providing our services to you, to allow adopters, foster carers and care providers to be linked to children, and to store data via our site, we only collect personal data about individuals where that individual, or an Organisation acting on their behalf, has uploaded that information to our site.
We are required by local authorities and agencies to verify a new user’s identity data with the relevant local authority or agency prior to registration of the user on our site. We do not collect further personal data as part of this process.
We also use your personal data to deliver relevant User Content to you, or content which you are permitted to view. For example, where you are not permitted to view certain content of other users, we will restrict your access, and that of other users as appropriate.
How your personal data is collected (where we process your information as a controller)
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your identity or contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site and when you report a problem with our site, request support, or give us some feedback.
- Third parties. We may receive personal data about you from various third parties and public sources as set out below:
- Technical data from the following parties:
- analytics providers such as Google based outside the EU
- Contact, and transaction data from providers of technical, payment and delivery services:
- Stripe based outside the EU
- Technical data from the following parties:
Uses made of the information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into with you or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing or use of special categories of personal data. You have the right to withdraw consent by Contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest||Retention period (see further below)|
|To process and deliver our services:
|To manage our relationship with you which will include:
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To use data analytics to improve our site, and our services, customer relationships and experiences||
|To make suggestions and recommendations to you about our services that may be of interest to you||
Link Maker Systems may contact registered users on occasion to inform them of system changes or new features. Users can opt out of marketing and communication emails on registration and from the username menu when logged in. Each email sent also offers an opportunity to unsubscribe.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your information
We may have to share your personal data with the parties set out below :
- If your Organisation has agreed to transfer a case file to another Organisation, then you may instruct us to transfer that case file on your behalf using the Transfer case process, which can be found on the admin menu for those with managers permissions. On completion of that process, the new Organisation will be responsible for the case file, and all related activity data, and that Organisation will become the new controller in relation to any personal data contained in that case file. You must not transfer a case file to another Organisation unless you have all relevant approvals, consents and authorisations to make that transfer, and that Organisation has all relevant approvals, consents and authorisations to receive access to that file.
- External third parties in their capacity as our sub-contractors in providing our services to you, including Organisations and the specific third parties listed below:
- Clook Ltd, a subsidiary of Sub6 Ltd, who manages our server infrastructure.
- Equinix Ltd, the data centre where the servers reside.
- Zencoder Ltd, the company responsible for transcoding any videos uploaded to the site.
- Mailgun Inc, the company used to send application emails to notify you if you have a new message within your account on our Site. Mailgun Inc. are based in California state, US and are certified under the EU-US Privacy Shield for transfers of personal data from the EU to the US.
- Freshmail Ltd, the online site is used to send marketing emails.
- Sales Force Ltd, CRM systems used to store issues raised with the support helpdesk or information relating to the purchase of an Organisation’s licence.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or in order to enforce or apply our terms of service and other agreements; or to protect the rights, property, or safety of Link Maker Systems Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and the protection of minors.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where we store your personal data and our security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed.
The Link Maker servers are on a virtualised network infrastructure that is fully redundant, with load balanced components so that components can be upgraded/replaced with no loss of service. The data centre is based in the UK and is climate controlled, with high level security, fire suppression and power redundancy. In the event of a non-recoverable data centre event, then the offsite backup can be restored at an alternative data centre within 24 hours.
The LMS Disaster recovery policy and procedure's primary objective is to ensure continuity of service for licenced users. This policy describes the procedures and process to recover IT systems, applications and data from any type of major outage. Disaster recovery testing is scheduled on an annual basis to ensure that the DR procedure and plan detailed is still valid.
Link Maker Systems uses an external CESG and CHECK approved IT Security health check provider to perform both network and application level vulnerability scans annually. LMS are accredited to ISO270001, and subject to internal independent audits to ensure compliance to its information security management policies.
We limit access to User Content, contact data, and identity data to users that need to view that information for the purposes of linking an adopter, foster care or care placement provider with a child in care.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where you have chosen a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
How long will you store my personal data for?
Where we act as a controller, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal requirements.
Details of retention periods for different aspects of your personal data where we act as a controller, are in the table above.
Where we process your personal data as a processor, we retain that information for the following periods:
- Your profile data as part of our community support network is deleted at the request of the user or once 3 years has passed since the last interaction you had with the community support network or your profile.
- Case data is deleted at the request of the relevant individual’s Organisation or an inactive case is deleted if there has been no activity against the case for 3 years if your organisation has an active licence, or 3 months if your Organisation’s licence has expired. Data is marked for deletion and after 14 days the data is anonymised in accordance with the ‘Anonymisation Code of Practice’ issued by the ICO. This anonymised data is held for statistical purposes.
- A user record is deleted on request from the user, or if the user has not logged on for 3 years.
In some circumstances you can ask us to delete your data: see "Request erasure" below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Under certain circumstances, and depending on our relationship with you as a controller or processor, you have rights under data protection laws in relation to your personal data. You may:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data held about you and to check that it is being lawfully processed.
- Request correction of your personal data that is held about you. This enables you to have any incomplete or inaccurate data held about you corrected, though the accuracy of the new data you provide may need to be verified.
- Request erasure of your personal data. You can ask for your personal data to be deleted or removed where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data. You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data. This enables you to ask that processing of your personal data be suspended in the following scenarios: (
- if you want us to establish the data’s accuracy; (
- where use of the data is unlawful but you do not want it to be erased; (
- where you need the data to be held even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party. You can ask to be provided with, or that a third party you have chosen is provided with, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us OR email firstname.lastname@example.org.
No fee usually required - You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you - We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond - We try to respond to all legitimate requests. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This version was last updated on October 2018 and historic versions can be obtained by contacting us.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.