All our trainers are teaching live online during the COVID-19 period.

1. Background

This Privacy Notice contains all the information you need to know about how and why we collect, use, store, transfer and keep secure personal data about you which relates to your work with us as a supplier, worker or self-employed consultant (‘Data’). It also explains your rights and obligations in relation to your Data.

We are committed to protecting the privacy and security of your Data in accordance with the General Data Protection Regulation (GDPR) and relevant UK law. This Privacy Notice should be read in conjunction with our Data Protection Policy and Data Retention Policy.

 

It is in your interest to read this privacy notice as it contains important information on how and why we are using your data and what we will do with it even after you have stopped working with us.

 

This Privacy Notice may be updated by us at any time.

 

2. GDPR Data Protection Principles

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any other way.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

 

 

We comply with UK data protection law and GDPR. This says that any Data we hold about you must be:

These principles apply to Data about you, from which you can be identified. It does not include data where your identity has been removed (anonymous data).

3. The different types of Data we hold and why we hold them

3.1 These are the types of Data we may hold about you:

 

Type of personal data

 

 

 

Details of personal data

 

DATA THAT MAY BE ENTERED INTO PROCESSOR SPECIFIC FIELDS

 

Recruitment Data • Job offers – not accepted

 

Contact / Personal Data • Personal home and work contact details

• Date of birth

• Gender

 

General Contract Data • Contract data including details of job location

• Bank Account details

 

DATA THAT MAY BE HELD BY THE COMPANY AS CONTROLLER IN DOCUMENTS / FILE NOTES, INCLUDING ON PAPER

 

Recruitment documents • CVs of rejected applicants

• CVs of applicants offered jobs but not accepted

• References provided by third parties for job offers whether accepted or not

 

General Contract documents • CVs of current freelance teachers

• Application forms of current freelance teachers

• Contracts for services

 

Immigration checks • Identification records

• Details of right to work in UK including any work permit

 

File Notes • Any Data included in File Notes

 

3.2 We have good reason for wanting to hold all this Data.

 

Type of employee personal data

 

 

Purpose for processing

Recruitment data and documents To enable us to make recruitment decisions

 

Contact / Personal data To enable us to contact you

 

General Contract data and documents To enable us to manage effectively your contract for services and to enable us to make accurate payments to you

 

Immigration checks To check that you have the right to work in the UK
File Notes To make general notes about situations related to your contract for services, and explain documents being stored

 

 

3.3 Under the GDPR, we need to have a legal basis for processing your Data.

There are six acceptable reasons why we are allowed to hold your Data.

Mostly we rely on three of these:

  • Where we need it to perform your contract for services
  • Where we need it to comply with a legal obligation (such as right to work in the UK)
  • Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests.

 

Occasionally we may need to rely on two further reasons:

  • Where we need it to protect your vital interests or someone else’s (such as when there are serious Health and Safety issues),
  • Where it is needed in the public interest.

And if none of these reasons apply, we will ask for your consent to hold Data. (see below under section 3.7)

 

Type of employee personal data Legal basis for processing
Recruitment data and documents Legitimate interests of a contractor for services
Contact / Personal data Performance of your contract for services,

compliance with legal obligations, legitimate interests of a contractor for services

General Contract data and documents Performance of your contract for services and compliance with legal obligations
Immigration checks Compliance with legal obligations
File Notes Performance of your contract for services, compliance with legal obligations and legitimate interests of a contractor for services

 

 

3.5 Special Category Data

A small amount of the Data we may collect from you can be classified as ‘Special Category Data’. Understandably, we have to be especially careful with this data, and we have to be satisfied that there are additional lawful reasons for holding it. This is Data that reveals:

  • Native Language
  • Nationality
  • Health data, or
  • Other information about your physical, mental health or disability status, to ensure your health and safety in the workplace, to assess your fitness to work, to provide appropriate adjustments, to monitor and manage sickness absence.

 

6 Reasons For Collecting This Data

  • In our recruitment process
  • As part of a DBS Checking process
  • Where you have notified us directly during your employment
  • You have voluntarily supplied it to us
  • You have consented to carrying out a DBS check (see section 3.7 below)
  • It is necessary to carry out employment rights and obligations, including, for example, where the employee is dealing with large amounts of sensitive data or is working with vulnerable individuals
  • You have made the Data public, or
  • It is necessary for us to establish or defend a legal claim

 

Within the categories of information we have listed above in section 3.1, we may collect the following Special Category Data, and have outlined the lawful reasons for processing it:

If we need to hold any other Special Category Data, we will ask for your explicit consent to hold it. (see below under section 3.7)

 

3.7 Criminal Convictions Data

We may hold Data about any criminal convictions you may have. We will only collect this Data if it is appropriate given the nature of your role and where we are legally able to do so.

We may collect Criminal Convictions Data in the following ways:

We are permitted to hold this Data for one of the following reasons:

 

3.8 Consent

Here’s what you need to know about the limited circumstances in which we may need your explicit, written consent to process specific elements of your Data:

  • a. Special Category Data and Criminal Convictions Data

 

In the limited circumstances where we are relying on your consent to provide us with either additional health or other Special Category Data, or to provide us with additional Criminal Convictions Data not covered by the reasons explained in sections 3.5 and 3.6 above, we will provide you with full details of the information we wish to collect and the reason we need it so that you can carefully consider whether you wish to consent. It is not a condition of your contract for services with us that you will agree to such a request. We will alert you where consent is needed before you disclose the information there.

You have the right to withdraw your consent in relation to processing under (a) above at any time. To withdraw your consent, please contact your Account Manager. Once we have received your withdrawal of consent, we will no longer process your information for the purposes you originally agreed to, unless we have another legal basis for doing so which we will advise you of at the time.

4. Data Sharing

We will only share your personal information with third parties where required by law, where it is necessary to carry out our working relationship with you (such as book suppliers) or where we have another legitimate interest in doing so.

Third parties will only process your Data on our instructions and where they have agreed to treat the Data confidentially and to keep it secure. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Data Security

We have put in place measures to limit access to your Data through our policies. In addition, we limit access to your Data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place appropriate security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Further details about the security of your Data can be found in the Privacy Policy on our website.

All our third-party service providers are required to take appropriate security measures to protect your Data in line with our policies.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

6. Data Retention

We also don’t want to keep your data for any longer than is necessary. We do have legal obligations to keep your Data even after you have left, for example, under legal requirements from HMRC. We have created a Data Retention Policy, using the same categories of Data that are used in this Privacy Notice, and defined a retention period for each category. In situations where we are able to anonymise your Data, we may continue to process the anonymised data without reference to the Data Retention Policy.

Please refer to the Data Retention Policy for full details of our retention periods and how Data will be deleted at the end of that time.

 

7. Your rights in relation to your Data

It is important that you know what rights you have in relation to your Data.

 

7.1 Right to Request Access

You have the right to request – through a Subject Access Request – that we provide you with a copy of the Data we hold about you and to check that we are lawfully processing it. The only Data that is not accessible to you immediately is either any fields or Documents or File Notes where your Account Manager, or a senior person within the company has decided, for legitimate business reasons, that it is not appropriate for you to have access, or some historic Data.

 

7.2 Right to Request Correction

You have the right to request that inaccurate or incomplete Data be corrected. We rely on you to ensure that you provide us with details of any changes in your personal circumstances. We may also be sending you occasional reminders for you to update your details on our systems.

 

7.3 Right to Object to Processing

Where we are processing Data only on the basis that it is necessary for our legitimate interests (or those of a third party) (see above section 3.4), you have the right to object to that processing and it is then for us to establish whether your interests and fundamental rights override those interests.

7.4 Right of Erasure (the ‘right to be forgotten’)

 

You have the right to request that we delete your Data where there is no good reason for us continuing to process it. You will appreciate that much of your Data is essential for you and us to be able to work effectively. For instance, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers). This right mainly applies when you have objected to processing (see section 7.3 above) or you are withdrawing your consent.

 

7.5 Right to Restrict Processing

You have the right to ask us to suspend processing your Data whilst its accuracy or reason for processing is established. However, there may be certain circumstances where we cannot suspend processing if it prevents us complying with a legal obligation, or without impacting our ability to continue to employ you. If this situation occurs, we will advise you at the time the reason why we cannot suspend processing.

 

7.6 Right of Data Portability

You have the right to request that we transfer your Data to another organisation when you leave our contract for services.

To exercise any of these rights, please put a request in writing to your Account Manager. You will not have to pay a fee to access your Data or to exercise any of these rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

8. Automated Processing (including Profiling) and Automated Decision-Making

Some of your data, such as basic contact information may be subject to managed Automated Decision-Making. For example, if you have signed up on our database as a teacher, our system will tailor the communication with you so that you only receive relevant information, like teaching opportunities.

Our ADM process is checked at regular intervals to ensure that everything is running smoothly and that you are not being sent irrelevant information.

9.We need to check that you have read and understood this Privacy Notice

We realise this is a lot to take in in one go! If you have any questions on this Privacy Notice, please direct them firstly to your Account Manager. We also have a Data Protection Officer, who has overall responsibility for data protection and your Account Manager will be able to provide their contact details.

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Lessons will likely start online before transitioning to face to face, based on government guidance during COVID-19.
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