Privacy & Cookie Policy

1. Introduction

The purpose of this notice is to inform on how Educate Private collects and processes personal data.

The company needs to process personal data about the following people:

Current, former and prospective pupils and their parents / guardians

Suppliers and contractors, such as tutors and consultants

Current, former and prospective employees

Other individuals as part of the ongoing operations of the business

This notice will also inform which third parties the company may share your personal data with.

Educate Private is committed to protecting the rights and freedoms of all user groups in accordance with the provisions of the EU General Data Protection Regulation (GDPR).

GDPR includes rules on giving privacy information to those whose data is held by an organisation. These rules place an emphasis on making privacy notices understandable and accessible, and Data Controllers are expected to take ‘appropriate measures’ to ensure that this is the case.

Data Protection is based on eight principles, or rules for good information handling.

Data must be processed fairly and lawfully

Personal data shall be obtained only for one or more specific and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or purposes

Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed

Personal data shall be accurate and where necessary kept up to date

Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes

Personal data shall be processed in accordance with the rights of data subjects under GDPR

Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data

Personal data shall not be transferred to a country outside the EEA, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data

Processing includes obtaining, recording, retaining, storing, disclosing, destroying or otherwise using data. Fair processing means being clear and transparent about how personal information will be used.

2. Who We Are

Educate Private (the Company) is registered in England and Wales under the Companies Act (Company No. 8082311), with its registered office at 64 Wilbury Way, Hitchin, Herts, SG4 0TP, UK.

The Company operates from offices at 76 Blenheim Crescent, London, W11 1NZ, UK, and its Data Protection Officer can be contacted at this address, by telephoning 020 3176 7754 or by emailing office@educateprivate.com.

Educate Private takes it duties and responsibilities under GDPR extremely seriously and will only keep your data for as long as necessary bearing in mind the purposes for which your personal data is collected. We are registered with the Information Commissioners Office (ICO) with the registration number A8270629.

This notice may be updated from time to time to ensure continued compliance with current legislation and to reflect best practice.

3. How and Why We Collect Personal Data

When you first contact Educate Private, by email, telephone or looking at our website, you may be invited to complete an Enquiry or Registration form. This information will be recorded and may be followed up by our consulting teams in order to provide you with further pertinent information or to address your requirements.

Through the course of the school placement / tuition process personal data is recorded to enable the Company to care for the pupil and to fulfil its contractual obligations in the delivery of services. It may also be collected to fulfil legal obligations and/or the regulatory duties that it owes to its regulators and to other third parties.

The primary method the Company uses to collect personal data throughout this time will be from the information contained on the registration form and associated documents completed when applying to schools along with:

Information provided whilst the pupil is under assessment, applying to schools, on a homestay or receiving tuition

Information received from previous places of education

Information provided by the Home Office or other third party in relation to status as a home or international pupil.

Information provided by a third party in relation to funding (for example for bursaries or scholarships)

4. What Personal Data We Collect

Personal data is any paper-based or electronically stored information about an individual from which that person can be identified.

The types of personal and sensitive personal data the school or college may process include:

Name and contact information such as address, email and telephone number of the pupil, parent, guardian and fee payer

Pupil date and country of birth, ethnicity and country of domicile, passport number or national identity card details and visa status

Information relating to pupil education history such as previous schools and education institutions, courses completed, dates of study, attendance records and examination results

Information relating to fees such as banking details, scholarships and bursaries

Information which may assist with provision for the appropriate medical and pastoral care of the pupil such as any disability, medical, or dietary issues - this may also include information about family or personal circumstances where this is relevant to the assessment of suitability to receive a bursary

A photograph of the pupil will be kept for identification purposes only and we will seek consent for any other usage

5. Processing of Personal Data

We will process personal data because it is necessary for the performance of a contract with you, or in order to take steps towards entering into a contract with you.

The Company will only process data for the purpose(s) for which it was obtained unless the data subject gives permission for it to be used for another purpose or the GDPR permits the use of the personal data without specific permission

Personal data will only be disclosed to those members of staff or contractors who need access to personal data to carry out the purpose for which it was acquired. The Company adopts appropriate security measures to ensure that personal data is kept secure and not processed without proper authority. Personal data will only be kept for as long as is legislatively allowed and as best educational practice dictates.

The Company will not transfer personal data outside of the EEA unless it is satisfied that the data subject’s rights under the GDPR will be adequately protected.

It may be necessary to pass personal data on to third parties including: schools, public authorities, other public bodies such as the Independent Schools Inspectorate, HM Revenue and Customs, UK Border Agency, Department for Education, Department for Work and Pensions, Independent Schools Council health professionals and the Company’s professional advisers.

We will use your data in order to:

Communicate with you as part of the general process of providing our services

Communicate with schools and tutors on your behalf

Deal with any feedback or concerns you may have

Monitor and evaluate the performance and effectiveness of our services

Carry out research and statistical analysis

Recover monies owed to us

To comply with our legal obligations we may use your personal data in order to:

Meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements

For the prevention and detection of crime

To assist with investigations, including criminal investigations carried out by the police and other competent authorities

We may also process your personal data where:

It is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional)

It is necessary to protect the vital interests of the pupil or another person

We have a legitimate business interest to do so

We have the specific or where required explicit consent of the data subject to do so

Where we believe there is a legitimate interest we may also contact parents or pupils to promote our services on matters such as openings on waiting lists at schools or specific events and activities related to our services. You may request to be excluded from data being processed in this way.

We may ask for your consent to use your information in certain ways as an alternative to relying on any of the legal bases set out in this notice and in the GDPR. For example, we may ask for the pupil's consent and or his/her parents' consent before taking or using some photographs and videos if the photograph or video is more intrusive and we cannot rely on legitimate interests. If we ask for consent to use personal information the individual can take back this consent at any time.

Any use of information before consent is withdrawn remains valid. Please contact our DPO (office@educateprivate.com) if you would like to withdraw any consent that you have given.

6. Sensitive Personal Data

Some of the personal data the Company processes will be “sensitive personal data” which is defined as information about racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition, sexual life, or commission of or proceedings for any offence committed or alleged to have been committed.

This category of personal data will be subject to additional protections.

This information may be processed for one of the reasons set out in the previous section.

Information concerning a pupil’s physical or mental health may be disclosed within the Company, to our tutors and consultants or to the pupil’s school so that a proper level of care and facilities may be provided. It will only be sent to individuals who need to know this information to provide support.

In addition, sensitive personal data may be collected to meet government requirements, to monitor our equal opportunities policies and to ensure that under-represented groups receive appropriate support. This information may also be collected and retained in anonymised format for statistical purposes.

7. What Happens After the Conclusion of Our Services

On conclusion of our services, the Company will retain a certain amount of personal and financial data, including some sensitive data, to meet regulatory and legal requirements. We will also keep an archive of information linked to pupil records to allow us to respond to any future requests you may make for information, or where we believe there is a legitimate reason for the provision of future services.

8. Rights of Access

You have a number of rights in relation to your data under the GDPR.

These are:

The Right of Access: you may request a copy of the personal data that we hold on you

The Right to Rectification: you may ask us to correct any information we have about you that you believe is incorrect

The Right to Erasure: you may ask us to delete information that we hold on you. Please note that we cannot delete data required to be kept for our legislative and regulatory compliance

The Right to Restrict Processing: you may ask us to not process or limit the use of your data in some instances. Please note that we may not be able to comply with requests that contravene our legal and regulatory obligations

The Right to Data Portability: you may ask us to transfer the data to another organisation in a format that makes it easy for them to use

The Right to Object: you may object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights

To exercise any of these rights please contact us at office@edcuateprivate.com giving details of your request. Please note that the above rights are not absolute and we may be entitled to refuse requests where exceptions apply under existing Data Protection regulations.

9. Security, Accuracy and Concerns

The Company will take the necessary steps to ensure that the personal data it holds is kept securely and only used for the purposes for which it was given. Access to personal data will be restricted to authorised staff.

All staff will be made aware of their responsibilities with regard to Data Protection and will be given regular training to ensure their practice remains up to date.

The Company will endeavour to ensure that all personal data is accurate and up to date. Individuals must notify the Company of any changes to information held about them and of any inaccuracies of which they become aware.

Where you have given consent to our processing data and wish to withdraw it, please contact the Company’s Data Protection Officer. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide some or all of our services to you and/or it may affect the provision of those services.

Educate Private will endeavour to be transparent about its processing of your personal data. However, should you have any queries you may address them to the Company’s Data Protection Officer.

You also have the right to complain to the Information Commissioner (https://ico.org.uk/concerns) if you have any concerns in respect of the handling of your personal data by the Company.

10. Website

i. The below sets out how we will treat the personal information which you provide to us while using the website located at www.educateprivate.com (“Site”), The Site is controlled by Educate Private Limited, a company incorporated in England with its registered office at 64 Wilbury Way, Hitchin, Herts, SG4 0TP, UK (operating from offices at 76 Blenheim Crescent, London, W11 1NZ, UK)(“Educate Private” or “we” or “us”).

ii. To provide the service provided by the Site, it is necessary for us to collect and process certain personal information (“Data”), including some or all of the following: name, address, date of birth, gender, email addresses and/or mobile phone numbers, IP addresses, web-browser details, operating system details, your activities on the Site, your personal preferences relating to the services we offer (“Services”), billing and financial information such as credit/debit card numbers and/or other information relevant to customer surveys or offers. This information will be stored together with any additional information you may provide to us, and will be used to provide you with, and to improve, the Services. We may, from time to time, expand or reduce our business which may involve the transfer of certain divisions or assets of our company to other parties, and your Data, where relevant, may be transferred to such third parties. Additionally, we and/or our trusted partners may contact you from time to time with offers that may interest you and/or to inform you of other products and services. We will keep your personal information only for as long as is necessary.

iii. We may use ‘cookies’ while you access the Site to avoid the need to re-enter details on different occasions. Cookies are also used to collect general usage and volume statistical information. We may use local “shared objects”, also known as “Flash” cookies. Examples of other reasons include:

enabling us to recognise your device so that you don't have to give the same information to us several times;

recognising that you may already have given a username and/or password; and/or,

measuring how you are using the Site, to make the Site easier to use and to ensure sufficient capacity for quick delivery.

A “cookie” is a small amount of data sent from the server and stored on your computer's hard drive. Most web browsers are automatically set up to accept cookies, but you can set your browser to refuse cookies or ask your browser to show you where a cookie has been set up. These settings will typically be found in the 'options' or 'preferences' menu of your browser.

Please note that we do not recommend turning cookies off when using the Site as this may prevent you from using certain aspects of the Site.

iv. Please note that from time to time we may use third party services to display or distribute content on the Site, which may include analysis of data and/or management of content and/or services generally.

v. We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Site and you are deemed to have accepted the terms of any such amended Privacy Policy on your first use of the Site following such alterations.

vi. If at any point you believe the Data we hold is incorrect you may request to see your Data to have it corrected or deleted. If you wish to make a complaint, you can do so by contacting the Information Commissioner’s Office. If you have any questions or if you do not want us to retain or use your personal information, you may withdraw your consent (i.e. “opt out”), by contacting us at office@educateprivate.com.