This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data and keep it safe.
1. Who we are and what we do
Mark Brooks Education is an educational consultancy-based company based at 3 Coniston Road, Longlevens, Gloucester, GL2 0NA. We are a specialist educational consultant, focusing on the placement of students into UK Boarding Schools and further consultancy work with schools both in the UK and abroad.
2. the first point of contact for data protection
If you have any concerns or queries about our data protection procedures, please contact Mark Brooks on 07905 332614 or email firstname.lastname@example.org.
3. Why we process data
As a company we process customer’s data including names, addresses and pieces of special category data in order to be able to support families and students in finding the right educational establishment for them and process basic information for purposes of sending our invoices and marketing to our existing and prospective customers. As well as customers data we also hold data about our suppliers and our employees in order to comply with necessary legislation and to maintain a good working relationship.
4. Legal bases for processing your data including any explanation of legitimate interests
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. Some of these reasons, set out below, are the bases we have for processing your personal data:
Consent – In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we always make clear to you which data is necessary in connection with a particular service.
Contractual obligations – In certain circumstances, we need your personal data to comply with our contractual obligations. We need to collect and retain your contact details so we can for example:
Legal obligations – If the law requires us to, we may need to collect and process your data.
For example we are obliged to retain certain information for HMRC reporting purposes or to comply with other legislative provisions including educational requirements.
Legitimate interest – In particular circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we retain customer, client and supplier information for 7 years in order maintain a good working relationship with these individuals unless we have a data processing agreement in place with companies in which case the terms of those take precedence.
5. When we collect data
6. What data we collect
7. How we use your personal data
We process data for a variety of reasons. Each of these relate to the running of the business and giving our customers or clients the best experience possible.
8. How long we keep your personal data
Whenever we collect or process your personal data, we only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely.
Some examples of our data retention periods:
Purchases and Services – When you place an order or buy one of our services we keep the personal data you give us for 5 years so we can comply with our legal, contractual obligations and retain a good relationship with you should you need any further services have any future queries. We are also obliged to retain certain transactional information for 7 years to satisfy accounting rules
Suppliers/contractors – For individuals who are supplying us with services we retain your personal information for a period of 5 years so that we can, if necessary, contact you again and continue our business relationship with you.
9. HOW WE KEEP YOUR DATA SAFE
We are aware of the need to maintain the correct and highest-level security when processing your personal information.
We take the following steps to maintain the security of your personal information:
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. Who we share your data with
We sometimes share your personal data with trusted third parties which act only on our instruction (known as “data processors”). Data processors might be, for example, our 3rd party accounting apps or subcontractors or those companies who store data for us:
Where we share information with these companies or individuals we make sure that they also keep your data secure and that they also protect your rights. To this end we make sure that:
Sharing your data with third parties for their own purposes (“joint controllers”) eg HMRC, accountants, legal advisors:
We will only do this in very specific circumstances, for example:
11. Where your data is processed
We do not transfer data outside of the EEA. Our servers are located in the UK
However, your personal data will remain in the EU or countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. Companies based in the USA that have certified with the EU-US Privacy Shield programme are also considered to be permitted destinations by the EU (this includes popular US products like Google, Dropbox, Microsoft)
12. Your rights and who to contact
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of those rights, please contact us by emailing email@example.com or call 07905 332614
Your right to withdraw consent – Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. You can do this by contacting Mark Brooks by emailing firstname.lastname@example.org
Where we rely on our legitimate interest – In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We will then stop processing your information unless we believe we have a legitimate overriding reason to continue processing.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request. To ask us to stop direct marketing please contact: email@example.com
Checking your identity – To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
For us to check your identity please:
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to contact the ICO – If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence
You also have the right to take to seek a judicial remedy
The policy was last modified on 21st May 2018