English in Chester (we, us, our, the school) is committed to protecting and respecting your (you, your) privacy. We take the privacy of all of our customers and other users seriously and take great care to protect your personal information.
English in Chester
9-11 Stanley Place
Telephone: +44 1244 318913
Please read the following policy carefully to understand what information we may collect from you, how we may use it, and your rights in respect of our use.
We will be guided by the following principles when processing data:
We collect information on you:
The General Data Protection Regulation (GDPR) establishes 6 legal bases on which we can process your data: these are Consent, Contract, Legal Obligation, Vital Interests, Public Task and Legitimate Interests. For further information about these legal bases and fuller definitions, please refer to the ICO website.
We use different legal bases for processing your data depending on the purpose for collecting your data in the first instance:
1. Booking a course at English in Chester
For all data collected as part of the process of enquiring about, applying for and booking a course or for any other related service (e.g. homestay, airport transfer, social programme, insurance to cover you during your stay, access to our online study portal e-Chester, managed via Guided e-Learning), or where you give us feedback about aspects of this provision, we process using Contract or Legitimate Interests, namely the fulfilment of the booking. This may include sharing personal data with our trusted partners such as Educational Tour Operators (ETOs), Government Agencies, Schools, insurance companies, Guided e-learning, homestay and other accommodation providers and activity and transport providers.
Where required by law to do so, we may also process your data under Legal Obligation.
Where we collect data about our clients’ health, this is managed under Consent. This data is shared internally and with transport and homestay providers only when necessary and appropriate.
2. Other services and uses of clients’ personal data
Any processing of customer data not directly related to the fulfilment of a booking or related services, such as signing up for newsletters or free lessons on our website, or sending messages to you on behalf of third parties, is managed under Consent. From time to time, we may use elements of the data you supply to target the messages we send to you. For example, we may use your location to send you information about an event or opportunity happening in your area.
During your stay at English in Chester, we may take photographs or videos of you, and the use and processing of these is also managed through Consent.
3. English in Chester and commercial partners in the UK and overseas
For all data collected as part of managing our relationship with commercial partners, such as ETOs, Government Agencies and Schools, we process using Legitimate Interest and Legal Obligation, namely the maintenance of the commercial relationship. This may include the secure sharing of some of the personal data of employees of our commercial partners with professional colleagues in other schools or associations for the purposes of developing the commercial relationship.
As newsletters to commercial partners are an important part of how we communicate with them, these are managed under Legitimate Interest.
English in Chester and our ETOs and other commercial partners (for example schools, government and national sponsors) are Joint Controllers of personal data relating to the process of marketing and booking our commercial partners’ clients.
When we transfer additional personal data, such as homestay information, to our commercial partners, this will be limited to data necessary for the performance of a contract made in the interests of the individual (which is an exemption to the 8th principle of the GDPR legislation). Through our contract with them, we require all of our commercial partners overseas to confirm that they will process this data securely in line with the requirements of GDPR or the equivalent in their country.
We remain responsible for the data held, processed or sent via our systems.
We do not sell personal data at any time.
4. English in Chester staff and personal data
For all data collected as part of the process of employing and managing staff, we process using Contract, Legal Obligation and Legitimate Interests, namely the employment of the employee. This will include data required for HMRC, pensions, insurance (including staff health insurance cover).
As newsletters to our staff are an important part of how we communicate with them, these are managed under Legitimate Interest.
When we take photographs or videos of staff, the use and processing of these for marketing purposes is managed through Consent.
5. English in Chester and homestay and accommodation providers
For all data collected as part of the process of recruiting and managing homestay providers, we process using Legitimate Interest, namely the maintenance of the relationship with the homestay. We send personal data about our homestays to students and ETOs and other trusted partners so that they know where to go on arrival in the UK and also are able to make contact with their homestay prior to arrival or if there is a problem. This may include photos and/or videos of our homestay providers.
Homestay and other accommodation providers receive basic information about students who are going to stay with them. This is limited to the information required to process the accommodation booking, and English in Chester remains the controller of this personal data and requires accommodation providers to dispose of it securely when it is no longer required for this purpose.
As newsletters to homestays are an important part of how we communicate with them, these are managed under Legitimate Interest.
When we take photographs or videos of homestay providers, the use and processing of these for marketing purposes is managed through Consent.
6. Defence of legal claims
We may process any of the personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Legitimate Interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
7. Insurance, managing risks and obtaining professional advice
We may process any of the personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is Legitimate Interest, namely the proper protection of our business against risks.
We may request health data from potential students and employees. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee. We share health data about clients’ with trusted partners only when necessary and appropriate where we have consent to do so.
The school has safeguarding responsibilities and carries out DBS checks on all staff and other people who are likely to be have direct supervisory responsibility for or unsupervised contact with young people under the age of 18. We may process and record securely risk assessments of these DBS checks where the disclosure is not clear. These risk assessments will be disposed of securely when that person no longer has supervisory responsibility or unsupervised contact with young people under the age of 18 on behalf of the school.
We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form. As part of this process, we request special category data relating to the health of the child, which we manage through Vital Interest.
We also gain consent from parents for the use of photos or video taken during their child’s stay at English in Chester through the Parental Consent Form.
How we will use information collected by our website
We may use information held about you in the following ways:
Links from our website
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use a single cookie, “sessionid”, to identify you when you visit our website, keep you logged in as you navigate our website, and store temporary information during the course application process. This functional cookie does not identify any individual, and is required for the correct operation of our website.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
You have the right to rectify, erase or restrict the processing of your data subject to the exceptions outlined in this policy. You also have the right to withdraw consent to the processing of information for which you have previously given consent. You can contact us at any time to have these details removed from our database or to update this information, subject to satisfactory proof of your identity. You can read more about your individual rights on the ICO website.
You may also request access to the data we hold on you. Provision of such information will be subject to:
a) The payment of a fee (currently fixed at £10)
b) The supply of appropriate evidence of your identity.
We may withhold personal information that you request to the extent permitted by the law.
To make any of these requests relating to your personal data, please contact us at: firstname.lastname@example.org or contact the Finance and Operations Manager (tel: +44 1244 318913)
Any wilful breach of this policy by staff will be regarded as a disciplinary offence and will be dealt with under the school’s formal disciplinary procedures.
Any request for information (personal information, requesting a correction, or to make a complaint) should be addressed in the first place to our Data Manager, who is our Finance and Operations Manager. She can be contacted at email@example.com, or on +44 1244 318913.
If you are not satisfied with the way your request is handled, you have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office. English in Chester’s registration number with the Information Commissioner’s Office is Z7642974.
Tel: +44 303 123 1113