Privacy Policy – March 2020
This privacy policy sets out how “David Smith Education” uses and protects any personal data that you give “David Smith Education” when you use this website or interact with the company by e-mail, phone or written correspondence. The policy sets out how we store, manage and secure your data to ensure your privacy.
“David Smith Education” is committed to ensuring that your privacy is protected. Should you provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.
“David Smith Education” may change this policy from time to time by updating this page. You should check this page to ensure that you are happy with any changes. This policy is effective from 24 March 2020.
Who we are and what we do
“David Smith Education” is an educational consultancy supporting UK and international families in the selection of a school for their children. In addition, “David Smith Education” works in the UK and overseas organising recruitment fairs to introduce schools with agents.
Point of contact for all data protection issues
Please contact the company director, Dr David Mark Smith, regarding any data protection issue by e-mail via the company website at www.davidsmitheducation.com
Why we process data
“David Smith Education” collects data from clients to support a search for a school or college for their child. Data is also collected to enable the issuing of invoices for services provided. In addition, data is held regarding schools, colleges and service providers to enable quick communication of enquiries and completion of applications on behalf of clients.
Legal framework for collection and use of data
The Data Protection Act 2018 provides guidance on the circumstances and reasons that a company may legally collect, store and use your personal data to provide a service.
Your consent for data gathering
With your consent and understanding, “David Smith Education” collects and processes your personal data to enable the company to support you with your enquiry. “David Smith Education” will always advise you on which data is required and relevant for the level of service requested
Fulfilling contractual obligations
To assist the delivery of the company’s consultancy and support services, “David Smith Education” needs to collect and retain your personal details and those of your child. For example, personal data is required by all schools and colleges as part of their application procedures for interviews, assessments and enrolment.
Legal obligations
Personal data is required to enable “David Smith Education” to comply with its legal obligations with aspects of student recruitment, particularly with non UK applicants applying for visas. In addition, HMRC requires certain personal details for reporting purposes.
Legitimate interests
“David Smith Education” may need your personal data to pursue legitimate interests with respect to the nature of the business, student recruitment for UK schools and colleges. These areas of legitimate interest in your data does not impact on your rights, freedoms or interests.
All personal data gathered by “David Smith Education” is retained to facilitate ongoing communication with clients over the duration of their child’s studies in secondary education in the UK. In certain circumstances, “David Smith Education” might have individual data processing agreements with companies. In those circumstances, the terms of those agreements take precedent over this policy.
When data is collected
Enquiries via the company website at www.davidsmitheducation.com requires the completion of data fields that are relevant to provide the service requested.
When confirming contract with suppliers, “David Smith Education” will gather relevant data to ensure the company complies fully with its contractual obligations.
What information is collected by “David Smith Education”
To enable an educational consultancy, “David Smith Education” collects the following information:
- Contact information including: name, address for parents, phone numbers and e-mail.
- Financial details – account name, number and sort code to enable the payment and issuing of invoices.
- Student details (including date of birth, nationality & passport number)
- Demographic information such as post code, preferences and interests
- To enable guidance on school selection, sensitive data regarding educational needs, pastoral needs, dietary and medical information may also be required.
What “David Smith Education” does with the information gathered
This information is gathered to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- To improve products and services.
- To arrange assessments and appointments at selected schools.
- To comply with HMRC legal requirements.
- To facilitate ongoing company/customer relationships.
- No promotional material or market research communication will be made using your contact data without your express authorisation.
Security and retention of your personal data
“David Smith Education” is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information collected online.
All data is stored in password and encrypted protected systems.
Only those who have a legitimate need to access your personal data will be given access
Your personal data will only be stored by “David Smith Education” until the service requested by yourself has been completed. Following this completion, your personal data will be deleted.
Sharing your data with third parties
To support your enquiry, “David Smith Education” will need to share your data with trusted third parties such as potential schools and colleges. These third parties will only handle your personal data on our instructions.
“David Smith Education” will make sure that all third parties protect your data and rights. As such, “David Smith Education” will only share relevant data with third parties to facilitate the service that you have requested. The exact purpose for which data will be released will be set out in our contract with them.
On completion of the service requested and contracted, any of your data held be a third party will be deleted or rendered anonymous.
“David Smith Education” will only share your data with third parties for their own purposes when we have your consent, a data sharing agreement or where we are obliged to pass on data for legal reasons.
Links to other websites
The “David Smith Education” website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that “David Smith Education” does not have any control over that other website. Therefore, “David Smith Education” cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
“David Smith Education” will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. “David Smith Education” may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
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 |
Please contact “David Smith Education” if you wish to exercise your rights in respect of any of these areas via the company website at www.davidsmitheducation.com
Additional Rights
Under the 2018 Data Protection Act, you can:
Withdraw consent
You can withdraw your consent for us to use and process your data by contacting “David Smith Education” via the company website at www.davidsmitheducation.com
In cases where we are processing your personal data on the basis of our legitimate interest, you can withdraw your consent 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 withdraw your consent for 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 the company via the website at www.davidsmitheducation.com
Confirming 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 provide proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill) and which right you want to exercise and the information to which your request relates.
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.
Modifications
If we decide to change our privacy policy, we will update the Privacy Policy modification date below.
The policy was last modified on 24 March 2020.