What this Notice covers Kent School of English is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you in accordance with the General Data Protection Regulation (GDPR) and data protection legislation. Identity of the data controller Kent School of English is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. Sources of personal data KSE may collect this information in a variety of ways. For example, from application forms, your passport or other identity documents. Much of the information we collect about you will be communicated to us by an Educational Tour Operator or Educational Partner (such as a school of college). In such cases, KSE will be the co-controller – with the Educational Tour Operator or Educational Partner – of your personal information. Information will be stored in a range of different places, including on your registration form, in information management systems and other IT systems (including email). What information do we collect? KSE collects a range of information about you. This may include: Group Leaders The group leader information which is shared and which KSE and the Educational Tour Operator or Educational Partner are jointly responsible for controlling is:
- Full name
- Home address and telephone number
- Mobile phone number
- Next-of-kin details
- Characteristics (such as nationality, language spoken, gender, age,)
- Medical information (such as allergies to food, medical information given on enrolment)
- Needs arising from religious observance (special dietary requirements etc)
- Confirmation that a group leader has had a police check which deems that there is no reason why they should not work with under-18s
Students The student information which is shared and which KSE and the Educational Tour Operator or Educational Partner are jointly responsible for controlling is:
- Full name
- Home address and telephone number
- Mobile phone number
- Next-of-kin details
- Characteristics (such as nationality, language spoken, gender, age,)
- Medical information (such as allergies to food, medical information given on enrolment)
- Needs arising from religious observance (special dietary requirements etc)
- Special Education Needs and Disabilities information (such as specific learning difficulties, specific medical needs)
The Educational Tour Operator or Educational Partner shall gain the consent of the parents, guardians or legal representatives of students under the age of 18 for the collection of any of the above data by KSE in the event that it is not provided by the Educational Tour Operator or Educational Partner prior to the start of a course. Our lawful bases for processing your data Performance of a contract: in order to provide the course as agreed it is necessary for the Educational Tour Operator or Educational Partner to receive and pass on the personal information of students and group leaders Consent: in order for KSE to use photographs of students or group leaders on its website or in a newsletter or brochure Consent: for the collection by KSE of personal data from students or group leaders in the event that data received by KSE is incomplete Consent: to use selected quotes from students or group leaders in publicity materials Legal obligation: in the case of a police or safeguarding investigation Consent Information will only be passed from the Educational Tour Operator or Educational Partner to KSE once any necessary consents of the individual concerned (or their parent/guardian/legal representative in the case of students under the age of 16) have been obtained. If consent to any of the purposes for which data is to be used by KSE is withheld, the Educational Tour Operator or Educational Partner should inform KSE. Our purposes for processing your personal information The gathering and sharing of accurate and relevant personal information is necessary to support the following agreed purposes of both parties:
- to arrange suitable accommodation for students and group leaders, either homestay or residential
- to place students or group leaders in an appropriate class
- to monitor and report on student progress
- to provide appropriate care and guidance
- to enable effective management and planning of KSE services and facilities
- to support any investigations, or matters pertaining to, student safety, wellbeing of students and group leaders, safeguarding or the prevention or detection of crime in order to ensure a secure and safe environment for students and group leaders
- to comply with any legal obligation to which either party is subject
The parties shall not use shared personal data in a way that is incompatible with the agreed purposes. Who has access to your information? People who may see or use your personal information include members of the accommodation and admissions teams, managers involved in investigations relating to the wellbeing of our students and IT staff. Limited personal information (name, address and telephone number(s)) will be shared with our transport team, arrivals staff, transport companies, our out-of-hours on-call staff and with teachers and activity assistants organising students’ activities. Your name will appear on various internal KSE documents. How does KSE protect personal information? We take the security of your information seriously. We have internal policies and controls in place to ensure that your information is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. We ensure that computers and servers comply with all relevant legislation and that personal information is protected by anti-virus and firewall software. All data on KSE systems is password protected. Hard copies of personal information are kept securely and destroyed when no longer required for the performance of duties or the fulfilment of contractual obligations. Information security policies and measures are regularly reviewed and, where necessary, improved. How long does KSE keep personal information? We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Your rights As a student or group leader, you have the right to:
- Request access to, and a copy of, your personal information
- Request correction of the personal information that we hold about you
- Request erasure of your personal information.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
If you believe we have not complied with your rights, you can complain to the Information Commissioner. What if you do not provide personal information? You are under no statutory or contractual obligation to provide information to KSE. However, if you do not provide the information, we will not be able to enrol you because the school depends on the processing of your information to function safely and effectively and to fulfil its own obligations. Changes to this Privacy Notice Kent School of English reserves the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions at all about this privacy policy please contact our admissions team: admissions@kentschool.co.uk