The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR).
Who are we?
Persephone Burleton, PhD is the data controller for SA Tutors. firstname.lastname@example.org This means we decide how your personal data is processed and for what purposes.
- students and parents;
- prospective students;
- former students;
- people who subscribe to our newsletters;
- visitors to our website.
What is Personal Data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
How do we process your Personal Data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
Sections 1 – 2 apply to our students, student’s parents and former and prospective students.
- We use your name, address, telephone number and email address, (and sometimes academic achievements) only if we have your explicit consent, for us to determine the best course of tuition for our service and to send you information emails. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
Sections 3 – 5 apply to our website users.
- When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
- We use website cookies to improve user experience of our website by enabling our website to 'remember' users, either for the duration of their visit – using a 'session cookie' – or for repeat visits - using a 'persistent cookie'.
- We use a third party service (UK2.net) to host our website and to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website. No user-specific data is collected by us or any third party.
Sharing your Personal Data
Your personal data will be treated as strictly confidential, and will be shared:
- with named third parties with your explicit consent;
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
- with your doctor or the police if necessary to protect yours or another person’s life;
- with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
- with a solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info
How long do we keep your Personal Data?
We keep your personal data for no longer than reasonably necessary where a right to be forgotten request or newsletter unsubscribe notice has not be received (no more than two years for dormant newsletter subscriber accounts).
We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
The Information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.
We will keep up to date with all legislation and changes regarding the collecting, processing, storing, sharing and destruction of your personal data. This notice and our Data protection policies and procedures will be reviewed every 12 months to ensure we are complying with all legislation and regulations regarding Data Protection, and to improve the way in which we handle your data, unless changes in legislation and regulations are made/come into force before the next review date (see end of privacy notice).
Processing your Data
In most cases where we process sensitive personal data we will require the data subject's explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If we believe that information is inaccurate we will record the fact that the accuracy of the information is disputed.
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform Persephone Burleton, PhD at email@example.com so that she can update your records. At any time you may request that changes are made to your contact details.
Storing your Data
- In cases when data is stored on printed paper, it is kept in a secure place where unauthorised personnel cannot access it (a secure locked cabinet to which only Persephone Burleton, PhD has access).
- Printed data will be shredded and incinerated when it is no longer needed.
- Data stored on a computer is protected by strong passwords that are changed regularly.
- In the event of serious illness or death of the Data Controller (Persephone Burleton, PhD) a nominated trusted person will be given access to passwords and keys that secure data held about you and will only process / share data in line with this privacy notice, current legislation and the data protection policies and procedures of Persephone Burleton, PhD.
Your rights and your Personal Data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
- The right to request a copy of your 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 for us to retain such data.
- The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
- 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) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing 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) [This right only applies 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].
- The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
- The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly
If we wish to use your personal data for a new purpose, not covered by this 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. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at: firstname.lastname@example.org
You can contact the Information Commissioners Office on 0303 123 1113 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.
Updating this Policy
We may update this Policy at any time. When we do, we will revise the updated date below.
This policy was last updated on 28 August 2018.