Privacy Notice
2021 ELH Privacy Notice
WHO ARE WE?
English Language House is an EFL/ESOL/EAL tuition, training and examination centre for international students.
English Language House is a registered company, ELH Ltd registration number 3965199.
Our postal address is: English Language House, 300 Saxon Gate West
Central Milton Keynes, Milton Keynes, MK9 2ES. UK
You can phone us: Tel: +44 (0) 1908 108683 ext 800
Elh mobile: +44 (0) 794 671256 or email: [email protected]
This privacy policy tells you how English Language House uses and protects any information that you give us when you use this website or when you communicate with us in any other way.
English Language House is committed to protecting your privacy. If we ask you to provide certain information which can identify you, then you can be sure that we will only use this information in the way we describe in this privacy notice.
English Language House may change this policy from time to time by updating this notice on the website. You should check the website from time to time to make sure that you are happy with any changes. Where there are substantial changes that will affect your rights, they will be provided to you as far as is reasonably practicable. This notice is effective from February 2018.
WHAT IS THIS NOTICE FOR?
This policy notice is intended to provide information about how ELH will use, process, store and delete personal data about individuals including: its staff; its current and prospective students; agents who work with us, homestay providers, and parents, carers or guardians of students and especially those who are under 18 (referred to in this policy as "parents") and ELH alumnae.
This information is provided in accordance with the rights of individuals under General Data Protection Regulation (GDPR) to understand how their data is used. Staff, students, parents, agents, homestay providers and aluminae are all encouraged to read this Privacy Notice and understand ELH’s obligations to its entire community.
This Privacy Notice applies alongside any other information ELH may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to ELH's other relevant terms and conditions and policies, including:
RESPONSIBILITY FOR DATA PROTECTION
Everyone at ELH is responsible for ensuring English Language House adheres to good data protection policies and procedures in line with GDPR legislation. Our DOS or DOA will deal with all your requests and enquiries concerning ELH’s uses of your personal data (see section on Your Rights below) and will make sure that all personal data we process meets the requirements of this policy and Data Protection Law. They will work closely with all staff to ensure good practice and will be assisted by our DOS, Clare or DOA, Mihaela. In the event that the DOS and DOA are away, the Director ELH will deal with any request or enquiries during their absence.
WHY ELH NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, students, students, parents, agents, homestay providers and clients we work with ELH may process a wide range of personal data about individuals (including current, past and prospective staff, students, parents or alumnae) as part of its daily operation.
Some of this activity ELH will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its staff, students, agents, homestay providers or parents of its students.
Other uses of personal data will be made in accordance with ELH's legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
ELH expects that the following uses may fall within that category of its (or its community's) "legitimate interests":
TYPES OF PERSONAL DATA PROCESSED BY ELH
This will include by way of example:
HOW THE SCHOOL COLLECTS DATA
Generally, ELH receives personal data from the individual directly (including, in the case of students who are under 18, from their parents). This may be via a paper or online form, or simply in the ordinary course of interaction or communication (such as email or written assessments).
However, in some cases personal data may be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from third party or publicly available resources (for example, if you post something on the ELH LinkedIn page, Facebook page, Twitter or Facebook page, or if we find out about one of your achievements through a story in the local newspaper, or if someone else tells us). Please see further below (Keeping in Touch and Supporting ELH) for the ways Alumnae and ELH may do this.
WHO HAS ACCESS TO PERSONAL DATA AND WHO ELH SHARES IT WITH
Occasionally, ELH will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (The British Council, ISI oversight, HMRC, police or the local authority).
For the most part, personal data collected by ELH will remain within ELH, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a 'need to know' basis). Particularly strict rules of access apply in the context of:
Staff, students and parents are reminded that ELH is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This may include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as Social Services, the LADO or police. For further information about this, please view ELH's Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of ELH's processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with ELH's specific directions.
HOW LONG WE KEEP PERSONAL DATA
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason; this will be in accordance with ELH's Record Retention Policy. Typically, the legal recommendation for how long to keep ordinary staff and student personnel files is up to 7 years following departure from ELH. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements. If you have any specific queries about how this policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact our DOS, Clare or DOA, Mihaela. However, please bear in mind that ELH may have lawful and necessary reasons to hold on to some data.
English Language House has a Record Retention Policy which specifies how long we will keep different types of data.
KEEPING IN TOUCH AND SUPPORTING ENGLISH LANGUAGE HOUSE
ELH and (in accordance with your preferences) any relevant other organisation named below, will use the contact details of students, parents, alumnae and other members of ELH community to keep them updated about the activities of ELH, or alumnae and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, ELH may also:
YOUR RIGHTS
Individuals have various rights under Data Protection Law to access and understand personal data about them held by ELH, and in some cases ask for it to be erased or amended or for ELH to stop processing it, but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to our DOS, Clare or DOA, Mihaela. You can contact them by email at [email protected]
ELH will always try to answer any such written requests as soon as is reasonably possible and always within statutory time-limits, eg one month in the case of requests for access to information. ELH will be better able to respond quickly to smaller, targeted requests for information. If the request is manifestly excessive or similar to previous requests, ELH may ask you to reconsider or charge a proportionate fee, but only where Data Protection Law allows it.
You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal professional privilege. ELH is also not required to disclose any student examination scripts (though examiners' comments may fail to be disclosed), nor any confidential reference given by ELH for the purposes of the education, training or employment of any individual.
Students and students under 18 can make subject access requests for their own personal data, provided that, in the reasonable opinion of ELH, they have sufficient maturity to understand the request they are making (see section Whose Rights below). Indeed, while a person with parental responsibility will generally be expected to make a subject access request on behalf of younger students, the information in question is always considered to be the child's at law. A student of any age may ask a parent or other representative to make a subject access request on his/her behalf, and moreover (if of sufficient age) their consent or authority may need to be sought by the parent. Pupils aged 13 are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Children younger than 13 may be sufficiently mature to have a say in this decision. All subject access requests from students will therefore be considered on a case by case basis.
Where ELH is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Please be aware however that ELH may have another lawful reason to process the personal data in question even without your consent.
That reason will usually have been asserted under this Privacy Notice or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation has been requested).
WHOSE RIGHTS
The rights under Data Protection Law belong to the individual to whom the data relates. However, ELH will often rely on parental consent to process personal data relating to students who are under 18 (if consent is required) unless, given the nature of the processing in question, and the pupil's age and understanding, it is more appropriate to rely on the pupil's consent.
Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents' rights at law or under their contract, and all the circumstances.
In general, ELH will assume that students' consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare, unless, in ELH's opinion, there is a good reason to do otherwise.
However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, ELH may be under an obligation to maintain confidentiality unless, in ELH's opinion, there is a good reason to do otherwise; for example where ELH believes disclosure will be in the best interests of the pupil or other students, or if required by law.
Pupils are required to respect the personal data and privacy of others, and to comply with ELH's IT Acceptable Use Policy and ELH rules. Staff are under professional duties to do the same covered under the relevant staff policy.
DATA ACCURACY AND SECURITY
ELH will always try to make sure that all the personal data we hold about an individual is as up to date and accurate as possible. Individuals must notify the DOA, Mihaela Dimitriu, at the ELH Office of any changes to information held about them so that we can change our records.
An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Act): please see above.
ELH will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and members of ELH will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to our DOS and DOA, using the following contact details [email protected] .
If an individual believes that ELH has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise ELH Complaints procedure and should also notify Mihaela Dimitriu. You can also make a referral to or lodge a complaint with the Information Commissioner's Office (ICO), although the ICO recommends that steps are taken to resolve the matter with ELH before involving the regulator.
WHO ARE WE?
English Language House is an EFL/ESOL/EAL tuition, training and examination centre for international students.
English Language House is a registered company, ELH Ltd registration number 3965199.
Our postal address is: English Language House, 300 Saxon Gate West
Central Milton Keynes, Milton Keynes, MK9 2ES. UK
You can phone us: Tel: +44 (0) 1908 108683 ext 800
Elh mobile: +44 (0) 794 671256 or email: [email protected]
This privacy policy tells you how English Language House uses and protects any information that you give us when you use this website or when you communicate with us in any other way.
English Language House is committed to protecting your privacy. If we ask you to provide certain information which can identify you, then you can be sure that we will only use this information in the way we describe in this privacy notice.
English Language House may change this policy from time to time by updating this notice on the website. You should check the website from time to time to make sure that you are happy with any changes. Where there are substantial changes that will affect your rights, they will be provided to you as far as is reasonably practicable. This notice is effective from February 2018.
WHAT IS THIS NOTICE FOR?
This policy notice is intended to provide information about how ELH will use, process, store and delete personal data about individuals including: its staff; its current and prospective students; agents who work with us, homestay providers, and parents, carers or guardians of students and especially those who are under 18 (referred to in this policy as "parents") and ELH alumnae.
This information is provided in accordance with the rights of individuals under General Data Protection Regulation (GDPR) to understand how their data is used. Staff, students, parents, agents, homestay providers and aluminae are all encouraged to read this Privacy Notice and understand ELH’s obligations to its entire community.
This Privacy Notice applies alongside any other information ELH may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to ELH's other relevant terms and conditions and policies, including:
- any contract between ELH and its staff, students, parents of students, agents, homestay providers;
- ELH's policy on taking, storing and using images of students;
- ELH's retention of records policy;
- ELH's safeguarding, health and safety policies, including as to how concerns or incidents are recorded; and
- ELH's IT policies, including its Acceptable Use policy, Remote Working policy and Bring Your Own Device policy.
RESPONSIBILITY FOR DATA PROTECTION
Everyone at ELH is responsible for ensuring English Language House adheres to good data protection policies and procedures in line with GDPR legislation. Our DOS or DOA will deal with all your requests and enquiries concerning ELH’s uses of your personal data (see section on Your Rights below) and will make sure that all personal data we process meets the requirements of this policy and Data Protection Law. They will work closely with all staff to ensure good practice and will be assisted by our DOS, Clare or DOA, Mihaela. In the event that the DOS and DOA are away, the Director ELH will deal with any request or enquiries during their absence.
WHY ELH NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, students, students, parents, agents, homestay providers and clients we work with ELH may process a wide range of personal data about individuals (including current, past and prospective staff, students, parents or alumnae) as part of its daily operation.
Some of this activity ELH will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its staff, students, agents, homestay providers or parents of its students.
Other uses of personal data will be made in accordance with ELH's legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
ELH expects that the following uses may fall within that category of its (or its community's) "legitimate interests":
- For the purposes of student assessment and registration (and to confirm the identity of prospective students and their parents);
- To provide education services, including advice about exams, and extra-curricular activities to students and monitoring students' progress and English Language development;
- Maintaining relationships with Alumnae and the ELH community, including direct marketing or promoting social activities; eg trips and excursions organised for students and their friends and/or families
- For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as diversity or gender pay gap analysis and taxation records);
- To enable relevant authorities to monitor ELH's performance and to intervene or assist with incidents as appropriate;
- To give and receive information and references about Alumnae, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students;
- To enable students to take part in national, international or other assessments, and to publish the results of examinations or other achievements of ELH students;
- To safeguard students' welfare and provide appropriate care;
- To monitor (as appropriate) use of ELH's IT and communications systems in accordance with ELH's IT: Acceptable Use Policy for ELH students; Acceptable Use Policy for ELH under 18 students;
- To make use of photographic images of students in ELH publications, on the ELH website and (where appropriate) on ELH's social media channels in accordance with ELH's policy on taking, storing and using images of students and of under 18s;
- Where otherwise reasonably necessary for ELH's purposes, including to obtain appropriate professional advice and insurance for ELH.
- To safeguard students' welfare and provide appropriate care (and where necessary, medical care), and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition where it is in the individual's interests to do so: for example for medical advice, social services, insurance purposes or to organisers of school trips and activities;
- To provide educational services in the context of any special educational needs of a student;
- In connection with employment of its staff, for example DBS checks, welfare or pension plans;
- For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.
TYPES OF PERSONAL DATA PROCESSED BY ELH
This will include by way of example:
- names, addresses, telephone numbers, email addresses and other contact details;
- bank details and other financial information, e.g. about students or parents who pay fees to ELH;
- past, present and prospective students' academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
- where appropriate, information about individuals' health, and contact details for their next of kin;
- references given or received by ELH about students, and information provided by previous educational establishments and/or other professionals or organisations working with students; and
- images of students (and occasionally other individuals) engaging in school activities, (in accordance with ELH's policy on taking, storing and using images of students and of under 18s).
HOW THE SCHOOL COLLECTS DATA
Generally, ELH receives personal data from the individual directly (including, in the case of students who are under 18, from their parents). This may be via a paper or online form, or simply in the ordinary course of interaction or communication (such as email or written assessments).
However, in some cases personal data may be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from third party or publicly available resources (for example, if you post something on the ELH LinkedIn page, Facebook page, Twitter or Facebook page, or if we find out about one of your achievements through a story in the local newspaper, or if someone else tells us). Please see further below (Keeping in Touch and Supporting ELH) for the ways Alumnae and ELH may do this.
WHO HAS ACCESS TO PERSONAL DATA AND WHO ELH SHARES IT WITH
Occasionally, ELH will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (The British Council, ISI oversight, HMRC, police or the local authority).
For the most part, personal data collected by ELH will remain within ELH, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a 'need to know' basis). Particularly strict rules of access apply in the context of:
- medical information (held and accessed only by the DOA or DOS and appropriate ELH staff under his/her supervision, or otherwise in accordance with express consent); and
- Homestay files;
- Safeguarding files held by the DSL (designated safeguarding lead)
Staff, students and parents are reminded that ELH is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This may include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as Social Services, the LADO or police. For further information about this, please view ELH's Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of ELH's processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with ELH's specific directions.
HOW LONG WE KEEP PERSONAL DATA
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason; this will be in accordance with ELH's Record Retention Policy. Typically, the legal recommendation for how long to keep ordinary staff and student personnel files is up to 7 years following departure from ELH. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements. If you have any specific queries about how this policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact our DOS, Clare or DOA, Mihaela. However, please bear in mind that ELH may have lawful and necessary reasons to hold on to some data.
English Language House has a Record Retention Policy which specifies how long we will keep different types of data.
KEEPING IN TOUCH AND SUPPORTING ENGLISH LANGUAGE HOUSE
ELH and (in accordance with your preferences) any relevant other organisation named below, will use the contact details of students, parents, alumnae and other members of ELH community to keep them updated about the activities of ELH, or alumnae and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, ELH may also:
- Share personal data about students, parents and/or alumnae, as appropriate, with organisations set up to help establish and maintain relationships with ELH community, such as the ELH, twitter, instagram, facebook pages
- Contact students, parents and/or alumnae (including via the organisations above) by post and email in order to promote ELH;
- Collect information from publicly available sources about students’, parents' and alumnae occupations and activities, in order to maximise interest in ELH: this may include social media (e.g. LinkedIn, Facebook), websites (including news media sites, Companies House etc.) and publications (e.g. national / local newspapers or magazines and trade press).
YOUR RIGHTS
Individuals have various rights under Data Protection Law to access and understand personal data about them held by ELH, and in some cases ask for it to be erased or amended or for ELH to stop processing it, but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to our DOS, Clare or DOA, Mihaela. You can contact them by email at [email protected]
ELH will always try to answer any such written requests as soon as is reasonably possible and always within statutory time-limits, eg one month in the case of requests for access to information. ELH will be better able to respond quickly to smaller, targeted requests for information. If the request is manifestly excessive or similar to previous requests, ELH may ask you to reconsider or charge a proportionate fee, but only where Data Protection Law allows it.
You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal professional privilege. ELH is also not required to disclose any student examination scripts (though examiners' comments may fail to be disclosed), nor any confidential reference given by ELH for the purposes of the education, training or employment of any individual.
Students and students under 18 can make subject access requests for their own personal data, provided that, in the reasonable opinion of ELH, they have sufficient maturity to understand the request they are making (see section Whose Rights below). Indeed, while a person with parental responsibility will generally be expected to make a subject access request on behalf of younger students, the information in question is always considered to be the child's at law. A student of any age may ask a parent or other representative to make a subject access request on his/her behalf, and moreover (if of sufficient age) their consent or authority may need to be sought by the parent. Pupils aged 13 are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Children younger than 13 may be sufficiently mature to have a say in this decision. All subject access requests from students will therefore be considered on a case by case basis.
Where ELH is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Please be aware however that ELH may have another lawful reason to process the personal data in question even without your consent.
That reason will usually have been asserted under this Privacy Notice or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation has been requested).
WHOSE RIGHTS
The rights under Data Protection Law belong to the individual to whom the data relates. However, ELH will often rely on parental consent to process personal data relating to students who are under 18 (if consent is required) unless, given the nature of the processing in question, and the pupil's age and understanding, it is more appropriate to rely on the pupil's consent.
Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents' rights at law or under their contract, and all the circumstances.
In general, ELH will assume that students' consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare, unless, in ELH's opinion, there is a good reason to do otherwise.
However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, ELH may be under an obligation to maintain confidentiality unless, in ELH's opinion, there is a good reason to do otherwise; for example where ELH believes disclosure will be in the best interests of the pupil or other students, or if required by law.
Pupils are required to respect the personal data and privacy of others, and to comply with ELH's IT Acceptable Use Policy and ELH rules. Staff are under professional duties to do the same covered under the relevant staff policy.
DATA ACCURACY AND SECURITY
ELH will always try to make sure that all the personal data we hold about an individual is as up to date and accurate as possible. Individuals must notify the DOA, Mihaela Dimitriu, at the ELH Office of any changes to information held about them so that we can change our records.
An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Act): please see above.
ELH will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and members of ELH will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to our DOS and DOA, using the following contact details [email protected] .
If an individual believes that ELH has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise ELH Complaints procedure and should also notify Mihaela Dimitriu. You can also make a referral to or lodge a complaint with the Information Commissioner's Office (ICO), although the ICO recommends that steps are taken to resolve the matter with ELH before involving the regulator.
