Private English Class Ltd is a UK based educational business (“School”). The School needs to communicate and share personal data in order to provide its services.
The School must comply with the European Union General Data Protection Regulation (GDPR), UK Data Protection Act, 2018 and other relevant legislation protecting privacy rights.
These data protection laws require the School to protect personal information and control how it is used in accordance with the legal rights of the data subjects – the individuals whose personal data is held.
All data subjects are entitled to know:
Misuse of personal data, through loss, disclosure, or failure to comply with the Data Protection Principles and the rights of data subjects, may result in significant legal, financial and reputational damage.
In order to manage these risks, this policy sets out responsibilities for all managers, employees, contractors or subcontractors, and anyone else who can access or use personal data in their work for the School.
Policy prepared by: Data Protection Officer, May 2018
Policy review date: May 2021
This policy and its supporting procedures and guidance support School compliance with its obligations as a Data Controller and where applicable, a Data Processor under data protection law.
The School is responsible for, and must be able to demonstrate, compliance with the following Data Protection Principles (“accountability”).
In summary, these state that personal data shall be:
The School will apply the Data Protection Principles and the other requirements of data protection law to the management of all personal data throughout the information life cycle by adopting the following policy objectives.
3.1 Process personal data fairly and lawfully
This means that we will:
3.2 Inform data subjects what we are doing with their personal data.
This means that, at the point that we collect their personal data, we will explain to data subjects in a clear, concise and accessible way
We will publish this information on our website and where appropriate in printed formats. We will review the content of these Privacy Notices regularly and inform our data subjects of any significant changes that may affect them.
Where we process personal data to keep people informed about School activities and events we will provide in each communication a simple way of opting out of further marketing communications.
In these ways we will provide accountability for our use of personal data and demonstrate that we will manage people’s data in accordance with their rights and expectations.
3.3 Uphold individual’s rights as data subjects
3.4 Apply “data protection by design and default” principles to all our personal data processing.
This means that we will:
3.5 Protect personal data
This means that we will use appropriate technical and organisational measures to:
3.6 Retain personal data only as long as required
This means that we will:
Then, in line with the retention policy recommendations, we will
3.7 Manage any breaches of data security promptly and appropriately.
This means that we will take all necessary steps to reduce the impact of incidents involving personal data. Where a data breach is likely to result in a risk to the rights and freedoms of data subjects, the Data Protection Officer will liaise with the Information Commissioner’s Office and report the breach, in line with regulatory requirements, within 72 hours of discovery. The Data Protection Officer will also recommend, where necessary, actions to inform data subjects and reduce risks to their privacy arising from the breach.
4.1 What information is included in the Policy
This policy applies to all personal data created or received in the course of School business in all formats, of any age. Personal data may be held or transmitted in paper, physical and electronic formats or communicated verbally in conversation or over the telephone.
4.2 Who is affected by the Policy
These include, but are not confined to: prospective applicants, applicants to programmes and posts, current and former students, current and former employees, family members where emergency or next of kin contacts are held, workers employed through temping agencies, members of the Court and members of the Committees of the Court, volunteers, people making requests for information or enquiries, complainants, professional contacts and representatives of funders, partners and contractors.
Users of personal data
The policy applies to anyone who obtains, records, can access, store or use personal data in the course of their work for the School. Users of personal data include employees and students of the School, contractors, suppliers, agents, School partners.
4.3 Where the Policy applies
This policy applies to all locations from which School personal data is accessed including home use.
5.1 All users of School information are responsible for
5.2 The Managing Director, as the Chief Executive Officer of the School, has ultimate accountability for the School’s compliance with data protection law.
5.3 The management (including Academic manager), is a data processor and is responsible for collecting, processing and storing the data.
5.4 The tutors (teachers, both employed and sub-contracted freelancers), use the data processed by the Data Processor in order to deliver the service to end clients.
5.5 The Data Protection Officer is responsible for
The Managing Director (if not the Data Protection Officer) will monitor new and on-going data protection risks
This policy is implemented through the development, implementation, monitoring and review of the component parts of the School Information Security Management System.
These will require
8.1 Who we are:
Private English Class Ltd. was set up at the end of year 2011 and in 2012 welcomed its first students. Since then the school has established itself as a lead provider of English courses to the local communities in East Midlands.
Our Data Protection Officer can be contacted directly here:
By email: firstname.lastname@example.org
By Mail: Data Protection Officer 1st floor, 11 Market Street, Kettering, NN16 0AH, UK
8.2 The personal data we may collect or process on you is:
|User type||Personal data type||Source|
|Learners/students – publicly funded courses||Name, Surname, personal ID, passport number, address, employer’s address, current employment status, learning disabilities, email address, phone number, next of kin contact details, personal achievements, goals and aspirations, education history||From the data subject directly|
|Learners/students – privately funded courses||Name, Surname, Postcode, town, email address, phone number||From the data subject directly|
|Teachers/tutors/sub-contractors||Name, Surname, DBS, diplomas and certificates, work history||From the data subject directly|
8.3 Your data will be used for the following purposes:
Service – Information in this category is needed in order to be able to provide School’s services to data subjects. In addition it is required to address or deal with any requests or enquiries.
Notifications – Information in this category allows us to provide data subjects with key product usage information to their preferred communication method.
Marketing – Information in this category is used to send out School’s service information to parties who have requested or are highly likely to have an interest.
8.4 Our lawful basis for processing for the personal data:
Teachers / Staff Members / Sub-contractors – Our lawful basis for processing your data is Legitimate Interest, as this forms part of delivering your job responsibilities.
Students/Learners – Our lawful basis for collecting and processing your data is Contract which you are planning to sign into in order to use our services. The data is obtained from you by you initially completing our registration/application form and interviewing you by a member of our staff.
8.5 Lawful basis for processing Non-Registered Data Subjects data
We are processing your personal data based on Explicit Consent. You may opt out of this processing at any time by contacting us directly on:
Once you have opted out, we will no longer contact you with information about Private English Class services and all of your personal data will be deleted and/or anonymised within 28 days.
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available on request about the factors we shall consider when deciding whether information should be disclosed.
You can also get further information on:
Except as set out above Private English Class Ltd. will not pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements. We will never sell your data to third parties.
8.7 Retention period
School will process and store personal data for learner/students, teachers and school staff members for the duration of 2 years. After this period, the data will either be updated or deleted.
For non-School users we will process and store personal data while we are in contact with you with relevant information on our services. If we have not contacted you for a period of 1 year your data will then be removed from our system.
If you have opted out to your data being processed we will delete your data within 28 days of your opt out being received.
8.8 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
In the event that you wish to make a complaint about how your personal data is being processed by School, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and School’s Data Protection Officer.
The details for each of these contacts are:
Supervisory authority contact details
Contact Name: Information Commissioner’s Office (ICO)
Contact Details: https://ico.org.uk/concerns/
Data Protection Officer (DPO) contact details
Contact Name: Private English Class Ltd. DPO
Contact Details: email@example.com
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, School, will collect and use your personal data for (i) assessing your current skills in order to advise what services we can offer to you (ii) contacting you about key notifications and (iii) in certain cases sending marketing information about our products.
Why does Private English Class Ltd. need to collect and store personal data?
For students, parents, teachers and school staff members, in order for Private English Class Ltd. to provide those users with our services, we need to collect and process their personal data for delivering service to the right person and with the right information.
For marketing purposes we focus on contacts that have consented to receiving relevant material.
For non-registered users we need to collect and process personal information on users who have expressed an interest in our services so we can contact them with the relevant information. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Will Private English Class Ltd. share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Private English Class Ltd. in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to support in delivering our service.
We do not currently process any sensitive personal data, however in the future, if this changes and we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Private English Class Ltd. use the personal data it collects about me?
Private English Class Ltd. will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Private English Class Ltd. is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Private English Class Ltd. contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
If you are a student/learner or non-registered user Private English Class Ltd. at your request, can confirm what information we hold about you and how it is processed.
If you are a student, teacher or school staff member Private English Class Ltd. will need to receive a request from you to access the data.
If Private English Class Ltd. does hold personal data about you, you can request the following information:
What forms of ID will I need to provide in order to access this?
Private English Class Ltd. accepts the following forms of certified ID when information on your personal data is requested:
Once ID has been approved these records will not be retained.
How does School protect my personal data?
Private English Class Ltd is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Contact details of the Data Protection Officer / Managing Director
Contact Name: Private English Class Ltd. DPO
Contact Details: firstname.lastname@example.org