Privacy Policy

Last Updated: May 2025  · Effective Date: May 2025
Organisation: Open World 2 Limited
Registered Address: 28 Daventry Road, Romford, RM3 7QT, United Kingdom

1. Introduction

Open World 2 Limited ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring you have a positive experience on our website. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.openworld2.co.uk) and use our services.

We are a Data Controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We take data protection seriously and comply with all applicable laws and regulations.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our website.

2. Information We Collect

2.1 Information You Provide Directly

Contact Forms: When you submit our contact form or placement enquiry, we collect: full name, email address, phone number, subject of enquiry, message content, date and time of submission.

Email Communications: email address, subject matter, message content, and any attachments you choose to provide.

Career Applications: full name, email address, phone number, CV or resume, cover letter, employment history, qualifications and certifications.

Telephone Enquiries: your name and phone number, call date and time, details of your enquiry, and any notes made during the call.

2.2 Information Collected Automatically

Website Usage Data: IP address, browser type and version, operating system, pages visited and time spent on each page, referring website URL, search queries used, date and time stamps, click stream data, and approximate geographic location based on IP.

Cookies: We use cookies and similar tracking technologies to enhance your experience. See Section 7 for more details.

Analytics: Google Analytics helps us understand how visitors use our website, including page interaction information, user journey data, and conversion tracking.

3. How We Use Your Information

3.1 Primary Purposes

Service Provision: responding to your enquiries and requests, processing placement applications, providing information about our services, managing career applications, arranging property viewings or consultations.

Communication: sending you requested information, responding to questions or concerns, providing updates about our services, confirming receipt of your enquiry.

Record Keeping: maintaining accurate records of enquiries, tracking placement requests, recording application history, documenting communications.

3.2 Legal and Safety Purposes

Compliance: complying with legal obligations, responding to legal requests, protecting our legal rights, safeguarding young people in our care.

Safety: preventing fraud and abuse, ensuring website security, protecting against unauthorised access, maintaining data integrity.

3.3 Marketing and Service Improvement

Marketing (with your consent): sending newsletters about our services, informing you of service updates, promoting relevant programmes or initiatives, sharing anonymised case studies and success stories.

Service Improvement: analysing user behaviour and preferences, improving website functionality, enhancing user experience, developing new services.

Legitimate Interests: operating an efficient website, improving our services, conducting business analysis, managing our online presence.

4. Legal Basis for Processing

Under UK GDPR, we process your personal information based on the following legal bases:

• Contract Performance (Article 6(1)(b)): processing necessary to fulfil enquiries about our services and process placement or career applications.
• Legal Obligation (Article 6(1)(c)): complying with safeguarding requirements, meeting regulatory obligations, responding to legal requests, tax and accounting requirements.
• Legitimate Interests (Article 6(1)(f)): operating and improving our website, fraud prevention and detection, business administration, website security, marketing communications (where you haven't opted out).
• Consent (Article 6(1)(a)): marketing communications (where you have explicitly opted in), non-essential cookies, additional processing beyond our core services.

5. Who We Share Your Information With

5.1 Service Providers

Email service providers, website hosting providers, analytics services (Google Analytics), customer relationship management (CRM) systems, and payment processors (if applicable). All third-party processors have signed Data Processing Agreements ensuring they process data only as instructed, maintain appropriate security measures, respect data subject rights, and comply with UK GDPR.

5.2 Legal and Regulatory Authorities

We may disclose information when required by law or court order, necessary to protect safety or property, responding to legal requests from authorities, complying with safeguarding obligations, or required by local authority or social services.

5.3 Business Transfers

In the event of merger, acquisition, bankruptcy, or sale of assets, information may be transferred as part of the transaction. We will provide notice to affected individuals and appropriate safeguards will be maintained.

5.4 Consent-Based Sharing

We will not share your information with unrelated third parties without your explicit consent, except as required by law.

5.5 Anonymised / Aggregated Data

We may share anonymised or aggregated data that cannot identify individuals for statistical analysis, industry benchmarking, published reports, or anonymised case studies.

We do NOT sell your personal information to third parties.

6. Data Retention

• Contact Enquiries: retained for 12 months after final contact.
• Placement Enquiries: retained for 24 months after completion of placement process; longer if you are a current service user or on the waiting list.
• Career Applications: retained for 12 months; if hired, retained for entire employment plus 7 years.
• Email Communications: retained for 7 years for legal compliance.
• Website Analytics: 26 months (Google Analytics default).
• Cookies: session cookies deleted when you close your browser; persistent cookies up to 2 years.

7. Cookies and Tracking Technologies

Cookies are small text files placed on your device when you visit our website. We use essential cookies (always active), analytics cookies (consent required, e.g. Google Analytics — 26 months), marketing cookies (consent required), and third-party cookies (e.g. embedded YouTube and social platforms). You can manage preferences via our cookie banner, withdraw consent at any time, and disable cookies in your browser settings. We respect "Do Not Track" signals where supported.

8. International Data Transfers

Your personal information is primarily stored and processed within the United Kingdom. Some third-party providers (Google Analytics, email providers, hosting) may be located outside the UK. For transfers outside the UK, we use Standard Contractual Clauses (SCCs), supplementary safeguards, and rely on adequacy decisions where available. You may ask where your data is stored and request information on safeguards.

9. Your Rights Under UK GDPR

You have the following rights regarding your personal information:

• Right of Access — request a copy of the personal information we hold about you.
• Right to Rectification — request correction of inaccurate personal information.
• Right to Erasure ("Right to be Forgotten") — request deletion in certain circumstances.
• Right to Restrict Processing — request we limit how we use your information.
• Right to Data Portability — receive your information in a machine-readable format.
• Right to Object — object to marketing or processing based on legitimate interests.
• Rights Related to Automated Decision-Making — including the right to human review.
• Right to Withdraw Consent — at any time where processing is based on consent.

10. Exercising Your Rights

Email enquiries@openworld2.co.uk with the subject line "Data Rights Request — [Your Name]" and include your full name, email address, the specific right you're exercising, and supporting details. We respond within 30 calendar days (extendable by two months for complex requests). We may verify your identity to protect against unauthorised access.

11. Children's Privacy

Our website is not intended for children under 13 years old and we do not knowingly collect personal information from children under 13. If you are a young person currently in or receiving services from Open World 2, your privacy and data protection are paramount and additional safeguards apply. Parents and guardians may contact us to understand what information we hold.

12. Data Security

We implement industry-standard technical, organisational and physical safeguards including SSL/TLS encryption, secure passwords and access controls, regular security updates, firewalls, staff data protection training, vendor data processing agreements, locked facilities, and secure document storage and disposal. If we discover a data breach we investigate immediately, mitigate, notify affected individuals where high risk, and report to the ICO within 72 hours where required.

13. Contact Us

Email: enquiries@openworld2.co.uk
Phone: 01708 787 298
Address: 28 Daventry Road, Romford, RM3 7QT, United Kingdom
Response time: within 5 business days.

Information Commissioner's Office (ICO): www.ico.org.uk · casework@ico.org.uk · 0303 123 1113 · Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

14. Policy Changes

We may update this Privacy Policy. Changes will be posted on this page and significant changes will be announced. Your continued use of our website constitutes acceptance.

Last Updated: May 2025