GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller: A controller determines the purposes and means of processing personal data.
Data processor: A processor is responsible for processing personal data on behalf of a controller.
Data subject: Natural person
Categories of data: Personal data and special categories of personal data
Personal data: The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data: The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership,political opinions, religious or philosophical beliefs.
Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party: means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
New Hope Education is a trademark of New Hope CIC. which operates a franchise network or organisation of tuition centre. New Hope Education is the data controller. This means we decide how your personal data is processed and for what purposes.
For all data matters contact:
Full name of legal entity: New Hope Education
For the attention of: The Data Privacy Manager
Email address: email@example.com
Postal address: 2nd Floor (Above Birchfield Library), 3 Trinity Road, Aston, Birmingham B6 6AH.
Our websites may include links to third-party websites or we may give you links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or our app(s), we encourage you to read the privacy notice of every website you visit.
3. The purpose(s) of processing your personal data
We will not sell your data to other commercial organisations. We use your personal data for the following purposes:
To respond to your enquiries including free trial or call back request or when you call us
To identify which tuition centre is your closest or preferred location
To inform individuals of news, events, activities, offers or information about our services
To register you as a customer
To maintain our accounts and records
To enable us to tailor then deliver our service to you
For processing your employment or franchise application
To manage our employees and franchisees
When you give us explicit permission which we may also interview, photograph and or video you and your child for newspaper or magazine articles, blogs, or other written media including advertising and marketing
You may give us information about you by filling in forms on our sites https://www.nheducation.org/ or http://www.nhglobal.org.uk (our sites) or by corresponding with us by phone, e-mail, in person or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a local centre, request a free trial or call back, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: Which may include Name; Phone; Email; Address; Child’s name; age; year group; School; and Educational Needs.
Special categories of data:
Medical Information: Doctor, Doctors Surgery and Medical Conditions
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data is:
consent of the data subject. Consent is obtained from our website online forms, on the phone or in person.
performance of a contract with you
necessary for our legitimate interests (to recover debts due to us)
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data
Explicit consent of the data subject
Performance of a contract with you
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with:
Companies, Franchisees and subsidiaries of New Hope Education
Your data is transferred into a number of computerised systems managed by third parties. We use third party suppliers to perform business functions such as accounting, bookkeeping, financial, banking, review and survey collection, homework portals, mailing lists, email clients, computerised file sharing and other computerised business functions. Some of our suppliers are cloud based and we ask for confirmation that they are handling your data securely in line with GDPR regulations.
We share your information with legal, regulatory or professional bodies where we have a legal or regulatory obligation to do so
Some of our third party payment providers might pass partial bank or card details to us for verification purposes
Sometimes, with your explicit permission, we may share your data and images with individual contractors, writers or editors of magazines or newspapers, for the purposes of writing an article which may be shared in magazines, newspapers or other printed material on our website, blog or social media.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary. We may keep your data longer if there is a legal or regulatory requirement to do so. Generally we keep records for:
Employment records for up to 6 years after the last action with the exception of employees medical records which are kept for up to 30 years
Accounting and financial information will be kept for 6 years from the end of the fiscal year
Customers information is kept in accordance with OFSTED’s requirements
Potential customer’s information is kept for 3 years after the last action to ensure that we are giving each potential customer one free trial
8. Providing us with your personal data
We require your personal data initially to return your initial enquiry, call back request or trial request. When you choose to become our customer we require your personal data as it is a regulatory and contractual requirement.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
THE RIGHT TO WITHDRAW YOUR CONSENT TO THE PROCESSING AT ANY TIME, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10.Transfer of Data Abroad
We do not pass data outside of the EEA directly. Where third parties who manage our business systems use cloud storage outside of the EEA we ask that they confirm that they comply with GDPR regulations.
11.Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our The Data Privacy Manager, 2nd Floor (Above Birchfield Library), 3 Trinity Road, Aston, Birmingham B6 6AH or firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.