Privacy policy

Draft — pending sign-off. The descriptions of what we collect and why reflect how the Exchange actually works today. The controller’s legal details are still to be confirmed and appear as highlighted placeholders. This page is excluded from search engines until they are filled in.

This policy explains what personal data The Exchange collects, why we hold it, who we share it with, how long we keep it, and what you can ask us to do with it. It covers the website and the member platform.

Who is responsible for your data

The data controller is [[CONTROLLER LEGAL NAME]], registered at [[REGISTERED ADDRESS]] (company number [[COMPANY NUMBER]], ICO registration [[ICO REGISTRATION NUMBER]]). For anything in this policy, including any of the requests described below, contact [[PRIVACY CONTACT EMAIL]].

What we collect

If you create an account

As you use the platform

If you contact us or send us a suggestion

Consent records

When you agree to something — these terms, marketing emails, topic notifications, or the terms attached to a gated download — we store the decision, when it was made, and the version of the policy it was made against. We keep an equivalent, append-only log of cookie decisions. These records exist so we can show what you agreed to and when, and so that withdrawing consent is as reliable as giving it.

Why we use it, and on what basis

Who we share it with

We do not sell your personal data. We share it only with the service providers we need to run the Exchange, and only so far as they need it:

ProviderWhat forWhat they see
ResendSending email — sign-in links, service notices and member updatesYour email address and the message content
VimeoHosting and streaming some of our videosTechnical data from your browser when you play a video, including your IP address
[[HOSTING PROVIDER AND REGION]]Running our servers and databaseEverything above, stored at rest

Some of these providers are based outside the United Kingdom. Where that is the case we rely on the safeguards described in [[TRANSFER SAFEGUARD — e.g. UK IDTA / adequacy]].

Other members can see what you post publicly, and your name on a course roster — but only if you have turned roster visibility on, which is off unless you choose otherwise.

Cookies

We currently set only the cookies needed to run the site: those that keep you signed in and protect forms against cross-site request forgery. We do not currently run analytics or advertising cookies. If that changes, this policy and the cookie policy will be updated first, and non-essential cookies will not be set before you have made a choice.

How long we keep it

We keep your account and profile data for as long as you have an account. If you ask us to erase your data, we clear or anonymise the personal details on your account and you will no longer be able to sign in.

Two things deliberately survive that process. Your CPD ledger and any certificates issued to you are retained, so a professional development record you have already relied on stays verifiable. Records of consent and of data requests are also retained, because they are the evidence that we handled your data properly. Neither is used to contact you or to rebuild a profile.

If you unsubscribe from our emails we keep your address on a suppression list. That is the only way to be sure we do not email you again.

Your rights

Under UK data protection law you can ask us to give you a copy of your personal data, correct it if it is wrong, erase it, restrict or object to how we use it, or send it to another provider. Where we rely on your consent, you can withdraw it at any time — and withdrawing is as easy as giving it.

To exercise any of these, email [[PRIVACY CONTACT EMAIL]]. We will respond within one month. If your request is complex we may need longer, and we will tell you within that first month if so. You will not be charged.

If you are unhappy with how we have handled your data you can complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint. We would rather you came to us first so we can put it right.

Changes to this policy

If we change how we use your personal data we will update this page. A change that affects something you have consented to means asking you again, not assuming your previous answer still applies.