Privacy policy
This Privacy Notice sets out information about how we and our appointed tutors will collect and process personal data in connection with our tuition services. That personal data may relate to children being tutored, their parents or family. “We” are Beatrix Woodhead & Associates and if you have any questions about this Privacy Notice you can reach us at beatrix@beatrixwoodheadassociates.com or 71-75 Shelton Street, Covent Garden, London WC2H 9JQ. If you have any questions about the personal data held or used by a particular tutor you may contact them directly using the details they have provided. Further information on the UK’s data protection laws in general can be found at www.ico.org.uk.
1. PERSONAL DATA WE MAY RECEIVE
We, or our tutors, may receive:
● contact details for parents of children being tutored and any other individual whose details are provided to us by parents. These details might include names, job titles, postal addresses, email addresses and telephone numbers, which, together with any correspondence with those parents, we will call “Contact Data”;
● information in relation to children being tutored (which we will call “Tuition Data”). This may include the child’s name, date of birth, address and contact details, attendance and performance information, academic and general background;
● potentially but not always, special categories of data relating to a parent, guardian or child which is subject to specific protections under data protection law (“Special Category Data”). This might include information relating to physical or mental health (e.g. educational psychology reports), religion or sexuality (e.g. if for any reason a parent feels it important for us to know more about their private lives in briefing us on the environment in which a child resides).
2. USE OF PERSONAL DATA AND LEGAL BASIS FOR PROCESSING
We have set out below a description of the purposes for which we and our tutors handle personal data. We are also required by law to identify the legal basis on which we handle personal data (a “legal basis” being a specific justification for data handling set out in Article 6 of the UK GDPR). When we process personal data on the basis of our legitimate interests then we also need to identify those legitimate interests and have done so below.
Type of Data: Contact Data
Purpose/Activity: To communicate with you and others in connection with the provision of tuition and keep records in relation to the services we have provided.
Legal Basis for Processing: Performing a contract with you (Art 6.1(b) UKGDPR). Our legitimate interests (Art 6.1(f) GDPR), namely managing our working relationship with you and operating our business.
Type of Data: Tuition Data
Purpose/Activity: To provide tuition services and keep records in relation to the services we have provided.
Legal basis for Processing: Performing a contract with you, our legitimate interests in managing the delivery of tuition.
Type of Data: Special Category Data
Purpose/Activity: Solely as necessary to provide tuition.
Legal basis for Processing: Your consent (Art 6.1(a) GDPR).
Type of Data: Any personal data
Purpose/Activity: For the purposes of legal compliance (e.g. maintaining tax records, keeping a record of your consent to use special category data).
Legal basis for Processing: Compliance with our legal obligations.
Type of Data: Any personal data
Purpose/Activity: Bringing and defending legal claims.
Legal basis for Processing: Our legitimate interests, namely being able to conduct and defend legal claims to preserve our rights and those of others.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
We or our tutors may have to share your personal data:
● with our advisors such as our insurers and/or professional advisers to take professional advice and manage legal disputes;
● with our service providers (for example, hosting service providers such as Zoom or Microsoft who might host servers on which we store data, or email service providers such as Microsoft or Google who might host emails sent to and received by us);
● for safeguarding reasons if we become aware of any imminent risk to your child.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
Some of the third parties to whom we or our tutors may transfer your personal data, discussed above, may be located outside the UK or EEA or may transfer your personal data to their own service providers located outside the UK or EEA. If so, then we will ensure that transfers by our appointed data processors will only be made lawfully (e.g. to countries in respect of which the European Commission or UK ICO has made an “adequacy decision”, or with appropriate safeguards such as the use of standard clauses approved by the UK ICO or the EU-US data transfer framework).
5. RETAINING AND DELETING YOUR PERSONAL DATA
We and our tutors will not keep personal data for longer than is necessary for the relevant purposes (which might include any legal, accounting, or reporting requirements). You may contact us if you would like further information.
6. YOUR RIGHTS
In connection with your personal data, you have various rights, including:
● the right to access: you have the right to confirmation as to whether or not we process your personal data, and where we do, to access the personal data, together with certain additional information;
● the right to correction: you have the right to have any inaccurate or incomplete personal data about you corrected or completed;
● the right to erasure: in some circumstances you have the right to the erasure of your personal data;
● the right to object to processing: you have the right to object to our processing of your personal data on the basis of legitimate interests (discussed above) and if you do so we will stop processing your personal data except to the extent permitted by law;
● the right to complain to a supervisory authority: if you consider that our processing of your personal data is unlawful, you have a legal right to lodge a complaint with the ICO; and
● the right to withdraw consent at any time: in relation to our use of any special category data on the basis of your consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.