Privacy Policy – SEN Unity CIC

1. Who we are

We are SEN Unity – Sports, Education, Nada (Musical Sound) CIC, a Community Interest Company registered in England & Wales.

Registered Office: 222 Upper Richmond Road West, London, SW14 8AH
Company Number: 14952101
ICO Registration: ZA256141
Data Protection Lead: Mr A. Merchant — director@sen-unity.co.uk
Website: https://sen-unity.co.uk

We are the data controller — we decide what personal data to collect and how to use it, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data We Collect & How We Use It

We collect and process personal data lawfully, fairly and transparently, based on the following legal grounds: contract, legal obligation, legitimate interests, vital interests, public task, or consent.

A. Website Visitors & Commenters

When you leave a comment on our site, we collect the data shown in the comment form, plus your IP address and browser user agent string — to help detect and prevent spam.

An anonymised string (hash) created from your email address may be sent to the Gravatar service to check if you use it. Gravatar’s privacy policy is at https://automattic.com/privacy/.
Once your comment is approved, your profile picture may be visible publicly alongside your comment.
If you request a password reset, your IP address will be included in the reset email.

B. Media Files

If you upload images to this website, please avoid including embedded location data (EXIF GPS). Visitors can download and extract any location data contained in images on the site.

C. Staff & Applicants

Data Category	What We Collect	Purpose	Lawful Basis
Employment details	Name, address, DOB, NI number, bank details, contracts	Employment, payroll, HR	Legal obligation / Contract
Recruitment info	CV, references, qualifications	Hiring & onboarding	Contract / Consent
Vetting	DBS checks, identity verification	Safeguarding & legal duty	Legal obligation

D. Clients & Contacts

Data Category	What We Collect	Purpose	Lawful Basis
Contact details	Name, email, phone, address	Communication, service administration	Legitimate interests / Contract
Organisation info	Role, affiliation, relationship	Managing engagement	Legitimate interests

E. SEND Participants & Beneficiaries

Data Category	What We Collect	Purpose	Lawful Basis
Basic identity	Name, DOB, parent/carer details	Registration & safety	Contract / Vital interests
Special category — health & needs	Disability, allergies, medical conditions, care plans	Tailored support, safety, inclusion	Art. 6: Vital interests / Public task; Art. 9(2)(h): health/social care provision (DPA 2018 Sch.1)
Dietary/support needs	Access requirements, medication, allergies	Safe participation	Same as above

Note: Health and disability data is special category data under UK GDPR. We process it only to deliver safe, appropriate support — never for other purposes. Access is restricted to authorised staff and all such data is encrypted.

3. Cookies

If you leave a comment, you may opt in to saving your name, email and website in cookies — for your convenience, so you do not re-enter details. These last 1 year.

Login page: temporary cookie to check browser cookie support — no personal data, discarded on close.
Login: persistent cookies for login state and display preferences. Login cookies last 2 days; “Remember Me” extends this to 2 weeks. Screen option cookies last 1 year.
Editing/publishing content: one additional non-personal cookie indicating post ID — expires in 1 day.

4. Embedded Content

Articles here may include embedded content (videos, images, articles, etc.). Embedded content behaves exactly as if you visited the external site. These sites may collect data, use cookies, embed third-party tracking, and monitor your interaction — especially if you hold an account there.

5. Who We Share Your Data With

We never sell your personal data. We share only with:

Required third parties: DBS, HMRC, mandatory funders, regulators
Service providers: cloud, email, accounting — all bound by Data Processing Agreements
Safeguarding partners: local authorities, health/social care — only when legally required or to protect safety
Persons you explicitly consent to us sharing with

Comments may be checked through automated spam-detection services.

6. How Long We Retain Data

Category	Retention Period
Website comments & metadata	Indefinitely (to auto-approve follow-ups)
Staff records	6 years after employment ends
DBS records	As required by law/policy — reviewed annually
Client contact data	Active relationship + 3 years after last contact
SEND participant records	Duration of involvement + 3 years (or per funder/regulation)
Anonymised data	Indefinite (no individuals identifiable)
Registered user profile data	Retained while account active; users may edit/delete at any time (username cannot be changed)

7. Your Rights

Under UK GDPR you may:

Access — confirm and obtain a copy of data we hold about you
Rectification — correct inaccuracies
Erasure — request deletion where no legal/operational requirement to retain
Restriction — limit processing
Portability — receive your data in a machine-readable format
Objection — oppose processing based on legitimate interests
Withdraw consent — where consent was the legal basis

To exercise these rights: email director@sen-unity.co.uk. Requests are free of charge; we respond within 1 calendar month. We retain data we are legally required to keep for administrative, legal or security purposes even if erasure is requested.

8. Automated Decision-Making

We do not use solely automated decision-making or profiling with legal or significant effects.

9. Complaints

If you are dissatisfied:

Contact our Data Protection Lead — director@sen-unity.co.uk — response within 14 days
If unresolved, complain to the Information Commissioner’s Office:

Website: ico.org.uk/make-a-complaint
Phone: 0303 123 1113
Post: Wycliffe House, Water Lane, Wilmslow SK9 5AF

10. Updates

We may revise this notice. Material changes will be posted on this website and, where appropriate, notified directly.

SEN Unity CIC

Authorised Signatory: Mr A. Merchant

Date: 23 September 2026