Safeguard-Me Privacy Policy

References in this Privacy Policy to "we", "us", "our", "ourselves" or "the Company" are references to About-Me Ltd trading as Safeguard-Me (registered number 07931007) which has its registered office address at Grenville House, Grenville Avenue, Broxbourne EN10 7DH

Safeguard-Me Privacy Policy
Last updated: [June 2025]

1. Introduction
At Safeguard-Me, we're committed to protecting your privacy and handling your personal data responsibly. This policy explains how we collect, use, and safeguard your information when you use our digital safeguarding platform.
Who we are: Safeguard-Me is a digital platform that helps organisations manage workforce vetting and safeguarding compliance efficiently and securely.
Contact us: For any privacy-related questions, email us at privacy@safeguard-me.co.uk

2. Our Role in Data Processing
When We Act as Data Processor
When organisations use our platform to collect, store, and manage personal data for their workforce, we typically act as a data processor. This means:

• Your organisation (the data controller) determines what data to collect and why
• We process this data according to your organisation's instructions
• Your organisation remains responsible for ensuring lawful basis for processing
• We have Data Processing Agreements in place with client organisations
• Data subject requests should be directed to your organisation first

When We Act as Data Controller
We act as a data controller for:

• Platform user accounts and authentication
• Our own security monitoring and platform analytics
• Marketing communications (where you've consented)
• Customer support interactions
• Our own compliance and business operations

Joint Processing Arrangements
In some cases, we may act as joint controllers with your organisation, particularly for:

• Verification processes that benefit both parties
• Shared compliance monitoring
• Platform security measures

Where joint processing occurs, we'll ensure clear agreements are in place defining each party's responsibilities.

3. The Type of Personal Information We Collect and for What Purpose
a. Name and email address (newsletter sign up and account creation)
b. Website user data (Usage data)
c. Bank Details (account subscription)
d. Identity Documentation i.e. Passport and Drivers Licence (Digital Identification Verification)
e. Liveness Recording (Digital Identification Verification)
f. Bank Statements and Utility Bills (Address Confirmation)
g. Employment History (References, Employment Gap Checking)
h. Qualifications (Confirmation of academic achievement or official qualification to undertake a particular job role)
i. Criminal Records Information (Assessing suitability to work with children and vulnerable adults)
This includes any information that you provide by filling in forms on our website, web or mobile app. This includes information provided at the time of registering to use our site, ordering any products or services described on our website, posting any information or material or requesting further services, or any information we provide to subscribers to Safeguard-Me's software.

4. How We Collect This Information
a. Website forms (https://www.safeguard-me.co.uk) and cookies (see separate Cookie Notice)
b. Mouseflow and Google Analytics (user behaviour analytics)
c. Stripe (integration with Safeguard-Me website and web app)
d. Yoti – Identity Verification Software - Integrated with Mobile App and Web App
e. Yoti – as above
f. Yoti - or Document Upload on mobile app
g. CV, Application Form or Mobile app upload
h. Mobile app Upload, Hedd (qualification Checker)
i. Mobile App Upload, Disclosure and Barring Service, Disclosure and Barring Service Online Update Service, Verifile (Registered Body)

5. Why We Collect This Information
Why we collect this information: Organisations
a. To capture your contact details for ongoing communication
b. To improve our understanding of user behaviour and to inform the future development of our product and services
c. In order for you to purchase a subscription
Why we collect this information: Individuals
We use this data in order to create your Safeguard-Me Passport and/or to comply with safe recruitment guidelines and/or legislation. This comprises:
a. Digital Identification Verification – to prove your identity. This forms the basis of further ongoing checks i.e DBS
b. Further enhanced check, to remotely prove your identity
c. Address Confirmation. This forms the basis of further ongoing checks i.e DBS
d. Confirmation of previous employment. This checks for any gaps in employment history and to seek references from previous employers
e. This confirms your qualifications and in some cases your suitability to undertake a particular role
f. This helps assess your suitability to work with children and/or vulnerable adults

6. Methods of Processing
Data processing is conducted using IT-enabled tools in accordance with our policies and procedures and those of trusted third party data processors. Together, we employ robust security measures to prevent unauthorised access, disclosure, modification, or destruction of the Data.
These Data Processors are engaged to perform many different business functions, including but not limited to administration, sales, marketing, legal, system administration and verification services and may have access to the Data. A list of third party processors can be found at the bottom of this policy.

7. Purpose of Processing and Legal Basis
When we collect your personal information, we will:

• make sure you know why we need it
• only ask for what we need
• keep it securely - making sure nobody has access to it who shouldn't
• ask for your consent to us sharing your information, where you have a choice
• only keep it for as long as we need to
• not make it available for commercial use (such as marketing) without your permission
• provide you with a copy of data we hold on you, on request

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
Organisations
You interact with our website first as a visitor, but when your data is volunteered (Section 3: a - c) you become a user, known as a Host Organisation. The legal basis for the collection of this information is:

• Your consent
• To fulfil a contractual obligation that we/host organisation has

Individuals
Safeguard-Me or any organisation subscribing to our software as a service (host organisation) may collect your personal data and will process your personal data, in line with relevant safer recruitment guidelines and legislation, for the purposes of completing statutory or discretional vetting checks and assisting current or future employers assess your suitability to work with children and vulnerable adults.
The legal bases we rely upon to offer these services to you are:

• Your consent
• Where we/host organisation have a legitimate interest
• To comply with a legal obligation that we/ the host organisation have
• To fulfil a contractual obligation that we/host organisation has

8. Data Sharing and Third Parties
We may share your information with:

• Your organisation: Employers or volunteer coordinators who need to verify your credentials
• Collaborating organisations: Your organisation may share your details with partner organisations for monitoring and regulation purposes. These organisations will have access to your data for a maximum of 96 hours, after which access will be automatically revoked
• Verification partners: DBS, qualification bodies, and reference providers
• Service providers: Trusted partners who help us operate our platform
• Legal authorities: When required by law or to protect safety

We will never sell your personal data.

9. Data Security
Your information is protected through:

• Industry-standard encryption
• Secure data centres and regular security audits
• Multi-factor authentication protecting both our mobile and web applications
• Access controls and staff training
• Regular security monitoring and updates
• Robust security measures to prevent unauthorised access, disclosure, modification, or destruction of data

10. Data Retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data/sensitive personal data.

11. Your Rights
Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you
• The right of access to the personal data the Company processes on you
• The right to rectification of your personal data
• The right to erasure of your personal data in certain circumstances
• The right to restrict processing of your personal data
• The right to data portability in certain circumstances
• The right to object to the processing of your personal data that was based on a public or legitimate interest
• The right not to be subjected to automated decision making and profiling
• The right to withdraw consent at any time

Where you have consented to the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting the data processor for the host organisation creating your Safeguard-Me passport.
There may be circumstances where the host organisation or Safeguard-Me will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact the host organisation who created your Safeguard-Me passport and they will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
To exercise these rights, contact us at privacy@safeguard-me.co.uk

12. Cookies and Tracking
We use cookies to:

• Keep you signed in
• Remember your preferences
• Analyse platform usage
• Improve security

We also use Mouseflow and Google Analytics for user behaviour analytics to improve our understanding of user behaviour and inform future development of our product and services.
You can manage cookie preferences through your browser settings or our cookie banner. Please see our separate Cookie Notice for more details.

13. International Transfers
Your data is primarily stored within the UK. If we transfer data internationally, we ensure appropriate safeguards are in place.

14. Children's Privacy
Our platform is designed for adults working with children, not for children themselves. We don't knowingly collect data from anyone under 16.

15. Changes to This Policy
We'll notify you of any significant changes to this privacy policy via email or platform notifications.

16. Contact and Complaints
Questions or concerns? Email us at privacy@safeguard-me.co.uk
Not satisfied with our response? You can complain to the Information Commissioner's Office (ICO) at ico.org.uk/concerns/

Safeguard-Me
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