Transparency Policy

ELH Transparency Policy
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you know what we need, how it is collected, where it is kept, how it is used and why we need it. You may also be able to choose if you would like us to retain your information in certain instances.
When you contact ELH and make an enquiry or ask to work with us we will need to ask you for certain personal information in order to decide what details we need to send you and how best we can help. Usually there is a form you will need to fill in which will ask you for this information. You can see which forms we usually sent under “ Information we collect” where there is a table and a list of the forms.

Some forms you complete will ask you if you agree for ELH to store and process your information. If you agree we will keep your information safe and will only process it in the way you agree. If you do not agree we will delete your data from all our systems. If you agree and then change your mind you can tell us and we will remove your data after the time limit stated.

This document tells you what information we will need to collect from you (this will depend on your enquiry and the forms you may need to complete), what we will do with this information, where it will be stored, who will use this and why and how long we will keep this for. The document will also tell you what you can do if you do not want us to retain information that we store about you and what you can do if you change your mind. We promise to tell you this

Either at the time that the data is collected
Or no less than a month after the data has been collected
Or, if we have been given your data by someone else, when we contact you for the first time
Or, if we need to give your data to someone else (eg tell your homestay family about you) we will tell you before we give this information to someone else and we will make sure you give your consent

Information we collect
Key:

IE= initial enquiry
AF = Application form
SRF= Student registration form
TTF= teacher training form
AApf= Agent application form
EBf= exam booking form
HPAf=Homestay provider application form
HARf= homestay accommodation request form
Vf = Visa form

PT=placement test
LT = Level test
FCR= free class registration
GEf=group enquiry form
GRf=group registration form
JAf=Job application form
Other eg tmp = telephone message pad, nte = networking event, oicm = offsite initial corporate meeting

We need this data and we will store and process it because:

You have given your CONSENT. You have given us clear consent to process your personal data for a specific purpose eg so we can register you with the school, enter you for an exam, send you relevant information about our courses etc
We need to process your personal data so that we can enter into a CONTRACT with you eg to work with you as a homestay provider, or as a agent, to deliver a training course for your company, to conduct an exam, to offer you a teacher training course etc Processing is necessary for the contract we have with you, or because you have asked ELH to take specific steps before entering into a contract with us.
LEGAL OBLIGATION The processing is necessary for ELH to comply with the law eg the VISA regulations as set out by UKVI or the employment law regarding who is able to work in the UK or who can teach, supervise, accommodate or accompany under 18s etc
VITAL INTERESTS The processing is necessary to protect someone’s life eg for students who have asthma, we need to know who may suffer from an asthma attack so that ELH staff will know what to do, who to contact in the event of an asthma attack; for a lady who is pregnant we may need to know what to do who to contact and what information to provide a medical team if we need to call an ambulance
PUBLIC TASK The data processing is necessary so that ELH can perform a task in the public interest or for our official functions, and the task or function has a clear basis in law eg we may need to provide Accreditation UK information about our students, agents or we may need to allow access to records of students and especially visa students to inspectors from the UKVI or ISI oversight or the British Council.
LEGITIMATE INSTERESTS The data processing is necessary for ELH’s legitimate interests eg to assess percentage pass rate of exams or teacher training courses, to conduct market analysis and establish which courses are most popular or which nationalities prefer which courses etc. ELH will do this in order that we can continue to offer quality courses which are most often sought by our clients. Data may also be processed for the legitimate interests of a third party eg Accreditation UK, EnglishUK etc unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

How we use this information
ELH will use this information to find out what you need and to supply you with the most relevant and up to date details of how we can work with you, what we can do to help you and what courses might be appropriate based on your enquiry.

Information that we share
We do not share personal information with companies, organisations and individuals outside of ELH unless one of the following circumstances applies:

With your consent
- We will share personal information with companies, organisations or individuals outside ELH when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
  - Sensitive personal information - This is a particular category of personal information relating to confidential medical facts, racial or ethnic origins, political or religious beliefs or sexuality.
For external processing
- We may provide personal information to UKVI, the British Council, ISI oversight, EnglishUK or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
For legal reasons
- We will share personal information with companies, organisations or individuals outside ELH if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
  - Eg Like other Accredited language schools ELH regularly receives requests from the UKVI, the British Council, ISI oversight and EnglishUK to give them information about students who study with us, agents and companies that work with us and homestay providers. Respect for the privacy and security of data that is kept by ELH underpins our approach to complying with these legal requests. We will always review each and every request, regardless of type, and we may push back when a request appears to be overly broad or does not follow the correct process.

Information security
We work hard to protect information held by ELH from unauthorised access or unauthorised alteration, disclosure or destruction. In particular:

We use Class, infospeed which is an encrypted and password protected SMS system to store student information securely on a secure network drive which is password protected and can only be accessed by ELH admin staff and Class infospeed staff..
We store paper documents with information in a safe lockable location.
We store some student information such as names and nationalities of students on google drive as class lists and will share this with ELH teachers who teach these classes
We store additional student information such as names, nationalities, contact details of students on google drive and may share this with ELH teachers or BC, ISI, UKVI inspectors.
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
We restrict access to personal information to ELH employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.

When this Privacy Policy applies
Our Privacy Policy applies to all of the services offered by ELH

Compliance and cooperation with regulatory authorities
We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve directly.

Changes
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.