PACE PROJECT UK — GENERAL PRIVACY POLICY

Last updated: 13 September 2026

Privacy Policy

PACE Project UK is a parent-led SEND information and discovery project. We create practical information and resources, help families discover SEND provision and opportunities, gather parent experiences and maintain directories of SEND-related provision.

This Privacy Policy explains how PACE Project UK collects, uses, stores and protects personal information when you use the PACE website, contact us, subscribe for updates, communicate with us as a provider or organisation, or otherwise interact with PACE.

A separate Parent Research Privacy Notice explains in more detail how information submitted through PACE parent questionnaires and research is handled.

1. Who is responsible for your information?

For data-protection purposes, the controller is:

Ruth Garner, trading as PACE Project UK
Website: paceprojectuk.org
Email: ruth@paceprojectuk.org

If you have questions about how your information is used, or wish to exercise your data-protection rights, please contact us at the email address above.

2. Information we may collect

The information we collect depends on how you interact with PACE.

Website visitors

When you visit the PACE website, technical information may be processed by the website and services used to operate it. This may include:

  • IP address;
  • browser and device information;
  • pages visited;
  • referring website;
  • approximate geographic information derived from technical data;
  • website performance and analytics information; and
  • cookies and similar technologies.

We use this information where appropriate to operate, secure and understand use of the website.

Non-essential cookies, including analytics cookies where applicable, should only be used in accordance with your cookie choices.

Contacting PACE

If you contact PACE by email, website form or another communication channel, we may collect:

  • your name;
  • email address;
  • organisation, if applicable;
  • information contained in your message; and
  • other information you choose to provide.

Please do not send confidential case files, medical records, legal documents or detailed personal information about a child unless PACE has specifically requested it and explained how it will be handled.

PACE does not provide individual legal, medical or SEND case advice.

Email updates and newsletters

If you choose to subscribe to PACE updates, we may collect:

  • your name or first name;
  • email address;
  • subscription preferences; and
  • limited engagement information, such as whether an email was opened or a link clicked, if the email service we use provides this information.

Signing up is voluntary.

Where consent is required for email marketing, we will ask you to actively opt in. You can unsubscribe at any time.

Providers and organisations

If you are a SEND provider, organisation or professional communicating with PACE, we may collect:

  • your name;
  • job role;
  • organisation or service;
  • business email address;
  • telephone number;
  • website and social-media details;
  • information about your provision;
  • accessibility information;
  • SEND and age suitability;
  • qualifications or outcomes;
  • referral and access information;
  • funding information;
  • locations;
  • information you ask us to amend or publish; and
  • correspondence between you and PACE.

Some information about organisations and services may already be publicly available. Where PACE obtains personal contact information from another source, we will handle it in accordance with applicable data-protection requirements.

Parent research

PACE conducts parent-led research and questionnaires.

Because those activities require additional explanation, please read the separate PACE Parent Research Privacy Notice before participating.

3. Why we use personal information

Depending on the circumstances, PACE may use information to:

  • operate and secure the PACE website;
  • understand how people use PACE;
  • respond to enquiries;
  • communicate with providers and organisations;
  • create, check and update provider listings;
  • maintain the SEND Opportunity Finder and Post-16 SEND Finder;
  • send updates that people have chosen to receive;
  • conduct parent research;
  • create parent-led guides, reports and resources;
  • improve PACE information and services;
  • correct inaccurate information;
  • maintain appropriate records; and
  • comply with legal obligations.

4. Our lawful bases

UK data-protection law requires us to have a lawful basis when we process personal information.

Depending on the activity, PACE may rely on:

Consent

We may rely on consent where you have actively chosen to provide information for a particular purpose or signed up to receive communications for which consent is required.

You can withdraw consent at any time.

Legitimate interests

We may rely on legitimate interests where it is reasonably necessary to operate and develop PACE and doing so does not override your rights and interests.

Examples may include:

  • responding to ordinary enquiries;
  • maintaining provider and organisational information;
  • communicating with organisational contacts;
  • administering and securing the website;
  • preventing misuse;
  • maintaining records; and
  • improving PACE resources.

Where we rely on legitimate interests, our interest is in operating and developing a useful, safe and accurate SEND information and discovery service.

Legal obligation

We may process or retain information where this is necessary to comply with a legal obligation.

Separate rules apply where special-category personal information is involved. Our Parent Research Privacy Notice explains how we minimise this risk within PACE research.

5. Provider information and public listings

PACE publishes information about SEND services, provision, organisations and opportunities.

Information intended for public provider listings may be displayed on the PACE website.

PACE may contact providers to:

  • check information;
  • correct inaccuracies;
  • obtain missing information;
  • understand referral or funding routes;
  • confirm suitability and accessibility information; and
  • keep listings current.

A listing on PACE does not in itself mean that PACE endorses, recommends, accredits or guarantees a provider.

6. Email communications

If you subscribe to PACE email updates, we will use your email address for the type of communications described when you sign up.

You will be given a straightforward way to unsubscribe.

We will keep appropriate records of subscription and unsubscribe requests.

Providing your email address for an enquiry or questionnaire does not automatically subscribe you to PACE marketing or newsletter emails.

This distinction is important: current ICO guidance generally requires active consent before sending electronic marketing to individuals unless a relevant statutory exception applies.

7. Cookies and analytics

PACE may use cookies and similar technologies to operate the website and understand how it is used.

Some cookies are necessary for the website to function.

Where consent is required for non-essential cookies, including analytics cookies, these should not be activated until you have made your choice.

You can change or withdraw your cookie preferences using the cookie controls provided on the website.

A separate Cookie Policy or cookie information panel should explain the cookies currently in use.

This is worth checking technically on your site: ICO guidance says users must be told what cookies do and why, and consent is generally required for non-essential cookies.

8. Who processes information for PACE?

PACE may use trusted service providers to operate the project. Depending on the services currently in use, these may include:

  • website hosting providers;
  • Google Forms;
  • Google Sheets;
  • Google Drive;
  • email services;
  • newsletter services;
  • website analytics;
  • website plugins;
  • website security services; and
  • backup services.

These organisations may process personal information on our behalf or, in some circumstances, under their own privacy terms.

PACE does not sell personal information.

9. International transfers

Some technology providers used by PACE may store or process information outside the UK.

Where a restricted international transfer takes place, PACE will use providers and transfer arrangements that meet applicable UK data-protection requirements, such as relevant UK adequacy regulations or appropriate safeguards where required.

Information about relevant safeguards can be requested by contacting ruth@paceprojectuk.org.

This is deliberately more precise than your original “we aim to use reputable providers” wording. The ICO distinguishes between adequacy arrangements and appropriate safeguards for restricted transfers.

10. How long we keep information

PACE will not keep identifiable personal information longer than reasonably necessary for the purpose for which it was collected.

As a general guide:

  • newsletter subscription information is retained while you remain subscribed and for a limited period afterwards where necessary to maintain an unsubscribe record;
  • provider contact and listing information may be retained while a listing is active and for a reasonable period afterwards;
  • enquiry correspondence may be retained for a reasonable period where needed to respond, maintain appropriate records or deal with follow-up;
  • website security information may be retained for the period necessary for security and technical purposes; and
  • parent-research information is subject to the retention arrangements described in the separate Parent Research Privacy Notice.

Fully anonymised information that can no longer reasonably identify an individual is not treated in the same way as identifiable personal information and may be retained for PACE resources, research findings and historical analysis.

11. Security

PACE takes reasonable organisational and technical steps to protect information.

These may include:

  • password-protected accounts;
  • limiting access to personal information;
  • using reputable technology providers;
  • separating research contact details from questionnaire responses where possible;
  • reviewing material before publication;
  • removing identifying information where appropriate; and
  • deleting information when it is no longer required.

No internet-based system can be guaranteed completely secure.

12. Children’s information

PACE is primarily designed for parents, carers, providers and organisations.

PACE does not intentionally ask children to submit personal case information through the parent questionnaire.

Parents and carers are asked not to provide names or other information that identifies their child when contributing to PACE parent research.

See the Parent Research Privacy Notice for more information.

13. Your data-protection rights

Depending on the circumstances and lawful basis, you may have rights including:

  • the right to be informed;
  • the right to access personal information held about you;
  • the right to correct inaccurate information;
  • the right to request erasure in certain circumstances;
  • the right to request restriction of processing in certain circumstances;
  • the right to object to certain processing;
  • the right to data portability in certain circumstances; and
  • the right to withdraw consent where processing is based on consent.

These rights do not apply identically in every situation.

To make a request, contact:

ruth@paceprojectuk.org

The ICO’s current guidance confirms that privacy notices should explain the purposes, lawful bases, recipients, retention, international transfers and applicable rights, among other information.

14. Complaints

If you have a concern about how PACE handles your information, please contact:

ruth@paceprojectuk.org

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data-protection regulator.

Information Commissioner’s Office

15. Automated decision-making

PACE does not currently use personal information to make solely automated decisions about individuals that have legal or similarly significant effects.

16. Changes to this policy

We may update this Privacy Policy as PACE develops or the way we use information changes.

The current version will be published on the PACE website with its most recent update date.

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