1. Who we are

Solas Way Ltd is registered in England and Wales under company number 17392676.

Registered office:
71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

Email: hello@solasway.com

Solas Way is the data controller for the personal information described in this Privacy Notice.
 

2. What information we may collect

Depending on the service you use, we may collect:

• your name and contact details

• information about the child or young person you are seeking support for

• age, year group and local authority information

• details about education, SEND, attendance, wellbeing, behaviour and support

• EHCPs, SEN support plans, school reports, professional reports and other documents you choose to provide

• information about health, disability or other sensitive matters where relevant

• information you provide through forms, emails, meetings or telephone calls

• payment and transaction information

• booking information

• testimonials and feedback where you choose to provide them

We aim to collect only information that is relevant to the service being provided.
 

3. Children and young people’s information

Much of our work relates to children and young people.

Their information may be provided to us by a parent, carer or another authorised person as part of a request for support.

Children have their own data protection rights, and their information should be handled with particular care. ICO guidance emphasises that organisations must take additional account of children’s rights and best interests when processing their personal data. 

We do not ask families to provide more information about a child or young person than is reasonably necessary for the service.
 

4. Special category data

Some information we receive may be classed as special category data, particularly information about:

• health

• disability or medical conditions

• ethnicity

• religion

• other sensitive personal circumstances

UK GDPR requires both an Article 6 lawful basis and an additional Article 9 condition before special category data can be processed.

Where sensitive information is necessary to provide a requested service, we may rely on explicit consent as the relevant Article 9 condition.

Where information needs to be processed or shared because of a safeguarding concern, different legal conditions may apply.
 

5. Why we use personal information

We may use personal information to:

• provide Advocacy Strategy Sessions

• review EHC needs assessment requests

• prepare Action Plans and written recommendations

• communicate with clients

• manage bookings and payments

• respond to enquiries

• provide customer support

• maintain appropriate business and accounting records

• manage complaints

• safeguard children, young people or adults at risk

• send testimonials or marketing communications where appropriate permission has been given

• improve Solas Way services and resources
   

6. Our lawful bases

Depending on what we are doing, we may rely on:

Contract
Where processing is necessary to provide a service you have purchased or requested.
 

Legitimate interests
Where necessary for the reasonable operation, administration and improvement of Solas Way, provided those interests do not override your rights.
 

Legal obligation
Where we need to keep or disclose information because the law requires us to.
 

Consent
Where you have specifically agreed to a particular use of your information, for example certain marketing or testimonial uses.

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Vital interests or safeguarding-related grounds
Where information must be used or shared to protect someone from serious harm.
 

The ICO requires organisations to identify an appropriate lawful basis for each processing activity rather than treating one basis as applying to everything.
 

7. How we use uploaded documents

Documents such as EHCPs, school reports and professional reports may contain significant amounts of personal information.

We use these documents only for the purpose for which they were provided, such as preparing for a Strategy Session or completing an EHCNAR Review.

Please avoid sharing information about other children, families or third parties unless it is genuinely relevant.

8. Who we may share information with

We do not sell personal information.

Information may be processed through organisations that help us operate the business, including:

• Wix, for website hosting, forms, bookings and payments

• Google Workspace, including email, calendar and Google Meet

• payment providers used through Wix

• accounting, banking or professional service providers where necessary

We may also share relevant information with statutory or safeguarding agencies where necessary to protect a child, young person or another person from harm.

Where possible and appropriate, we will explain this before information is shared.

 

 

9. International data transfers

Some of the technology providers we use may process information outside the UK.

Where this occurs, we expect appropriate safeguards to be used in accordance with UK data protection law.

 

 

10. How long we keep information

We only keep personal information for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, safeguarding and professional-record requirements.

Retention periods may differ depending on the type of information involved.

We will periodically review the information we hold and securely delete information when it is no longer required.

 

 

11. Security

We take reasonable steps to protect the information entrusted to us.

This includes using secure business accounts and systems, restricting access to information, and taking particular care with sensitive SEND and health-related information.

No online system can be guaranteed to be completely secure, but we aim to use appropriate technical and organisational safeguards.

 

 

12. Testimonials

If you provide a testimonial, we will only publish it where you have given permission.

You can choose how your testimonial is attributed, for example by first name, initials or anonymously.

We will not intentionally publish identifying information about your child or their school unless separately agreed and appropriate.

 

13. Marketing

We will not add you to marketing communications simply because you purchased a service.

Where consent is required, we will ask for it separately.

You can unsubscribe from marketing communications at any time.

 

14. Your rights

Depending on the circumstances, you may have rights including:

• access to your personal information

• correction of inaccurate information

• deletion of information

• restriction of processing

• objection to certain processing

• data portability

• withdrawal of consent where consent is relied upon
   

These rights are subject to some legal limitations.
 

The ICO confirms that children have their own data protection rights as well as adults.

 

15. Safeguarding

Privacy and confidentiality are important, but they are not absolute.

If we believe a child, young person or another person may be at risk of significant harm, we may need to share relevant information with appropriate agencies.

The ICO recognises safeguarding children and people at risk as a specific substantial-public-interest condition for processing special category data in appropriate circumstances.
 

Please see our Safeguarding Policy for more information.

 

16. Complaints and concerns

If you have questions about how we use your information, contact: hello@solasway.com

You also have the right to raise a concern with the Information Commissioner’s Office (ICO).

 

17. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our services, systems or legal obligations.

The latest version will always be available on our website.