PRIVACY POLICY
Information for you about how we look after personal information about yourself and your child or children.
1. Statement
Bloom Education is committed to ensuring the privacy rights of its employees, customers, suppliers and all other associates who may provide personal information to the company, in accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
Our commitment is to:
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Keep personal information about our service users and supply chain partners private;
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Not use personal information for any purpose other than in connection with our business activities in accordance with this policy;
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Make it easy for our service users and supply chain partners to approach us if they have any concerns or questions relating to the retention of personal information;
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Not provide personal information to others save where legally required to do so or in the legitimate course of business.
2. Data Protection Principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
3. Data Subject Rights
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it
b) the right of access to the data we hold on you.
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’
e) the right to restrict the processing of the data
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’
g) the right to object to the inclusion of any information
h) the right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent for us to store your data, you may also withdraw this consent at any time, withdrawal of data which would impact our ability to provide our service will be clearly communicated.
4. Who we are and how we operate
Bloom Education provides children with a nurturing, safe and caring environment in which to learn. Bloom Education is run by Joanna Clemo and Julia Beckett both fully qualified teachers. To operate effectively Bloom Education require personal information concerning parents, legal guardians (parents), students and supply chain partners. We set out in this document what personal information is collected and how it is used. The term Data Controller is applied to a business which determines how personal information is used. Bloom Education (directed by Joanna Clemo and Julia Beckett) is known as a Data Controller.
5. How information is collected
Information in relation to parents, students and teachers will be collected by Bloom Education. This might be achieved by providing information verbally, whether face to face or by telephone, completion of paper documents or by electronic means such as through email or interaction with our websites. We ask that any personal information is accurately provided as the information which is held is only as accurate as the information initially provided. If any of the personal information provided changes, we ask that Bloom Education is notified as soon as possible in order that the personal information can be updated.
6. What personal information will Bloom Education collect?
Bloom Education will require the following information about the student:
· Name;
· Address;
· Contact details;
· Date of birth;
· Schooling related information;
· Gender;
· Health related information and other information relevant to being able to teach the student most effectively;
· As the student’s studies progress the Instructor will accumulate information in relation to the student’s work and its progression.
Information which will be required from parents/legal guardians:
· Name;
· Contact details;
· Relationship to student;
· Details of others who are authorised points of contact if a primary contact is not available;
· Any other information which may be provided, and which is relevant to the education of your child or children.
Bloom Education will require the following information about teachers:
· Name;
· Address;
· Contact details;
· Qualification certificates
· DBS certificates.
Bloom Education may also ask for or receive contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and whether the student is a native English speaker. Bloom Education will not seek any further personal information in relation to parents or students without gaining specific authority. Bloom Education will not take or publish photographs of students or publish students’ names without your consent as the parent/legal guardian.
7. What will Bloom Education use the personal information for?
To fulfil contractual obligations and to respond to enquiries to:
· Ensure legal compliance
· Administer lessons;
· Ensure the quality of the lessons
· Respond to enquiries about the study offered;
· Seek feedback about study experiences;
· Address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;
· to record and/or report upon the progress of the student;
· to consider, record and communicate other issues which may be impacting upon or related to the progress of the student;
· to respond to complaints.
To ensure vital interests: This relates to the health and safety of a student. For example, if there was a medical emergency Bloom Education may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise. When it is Bloom Education’s legal duty Bloom Education may in very rare circumstances be required under safeguarding and child protection issues to provide information to local or public authorities including the police. When legitimate interests apply It is possible that from time to time that Bloom Education may wish to communicate with parents concerning other matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:
· Providing news updates about developments at Bloom Education, this might, for example be in relation to changes to the teaching program, information relating to it, and educational meetings.
· To communicate about particular study opportunities and useful information about Bloom Education, for example particular trials, promotions and campaigns.
Any communication under this heading will be of the nature referred to above. Bloom Education will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication. If you do not wish to receive communications under this heading please contact Bloom Education and let them know which type of communications you would not wish to receive.
When you consent There are certain uses to which Bloom Education will use personal information without your specific consent. Where such consent is required it will be sought separately. It is likely to be in areas such as in photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies. If consent is given it can be withdrawn at any time by providing notification to Bloom Education in writing or by email. Other Bloom Education may also use personal information for data management to enable the efficient running of the business.
8. What happens if I don’t wish to provide personal information to Bloom Education
Bloom Education require the personal information set out in this privacy notice in order to ensure that the lessons can be safely and effectively delivered to your children and continually developed and improved for the benefit of children. Without this information it will not be possible to deliver the services for the benefit of the children or at least not as well as we would like. We have though set out above some purposes for which either Bloom Education wish to use personal information under the heading of “Legitimate interests”. If we receive an objection to use any personal information being used under this heading this must be received in writing by the person/organisation objecting. If Bloom Education wish to gather personal information for which consent is required, they will obtain that specific consent before gathering that information and individuals/organisations have the right not to provide such information.
9. How long will you keep personal information for?
Bloom Education will only retain personal information:
· For as long as necessary to fulfil the purposes it was collected for as set out in this Privacy Notice;
· In relation to those that enquire about the services which we can provide we would not normally keep that information for longer than 12 months after the last communication from the enquirer;
· Whilst children are studying with Bloom Education, it is necessary for us to retain the personal information. Thereafter we will not normally keep it for longer than 24 months after children have ceased to attend a Bloom Education lesson unless we have legitimate reasons, including child protection reasons for doing otherwise;
· In some circumstances individuals/organisations have the right to request erasure of personal information held. This will be addressed below.
10. Data Subject Access Request (SAR)
Access – You have a right to request copies of all personal data Bloom Education holds about you or your child/children. In the event you make a DSAR, Bloom Education will respond to you within one month of receipt of the request. Bloom Education may extend this period for a further two months, where necessary. Bloom Education shall notify you of any such extension. Where we receive your request in electronic form, your data shall be provided in electronic form (where possible), unless otherwise requested.
Correction – it is important that you keep Bloom Education up to date with any changes to the personal information provided. Subject to that you have the right to ask the Bloom Education, as appropriate, to correct or complete any inaccurate or incomplete data held about you or your children. It is possible that evidence will be required of the new information provided.
Erasure – you are entitled to ask Bloom Education to delete or remove personal information held where there is no good reason for Bloom Education to continue to hold it. It may not always be possible to comply with your request due to ongoing regulatory or legal obligations in relation to the personal information. However, where this is the case you will be informed and be told of the reasons why it is not possible to comply with the request.
Object to processing – you may object to Bloom Education processing personal information. There are some circumstances in which it will not be possible to comply with your request, for example if it is necessary to process the information in connection with obligations which Bloom Education have and which have been explained to you in this document. If you object to Bloom Education processing information which has been processed under the legitimate interest head, we will stop processing it.
Restriction of processing – you may ask Bloom Education to suspend processing of personal information in the following situations:
· If you want the data accuracy to be established;
· Where the use of the personal information is unlawful, but you do not want it to be erased;
· You need the data to be held even though Bloom Education no longer require it as you need it to establish, exercise, or defend legal claims; or
· You have objected to the use of the data by Bloom Education but Bloom Education need time to determine whether they have overriding legitimate grounds to process it.
Request the transfer of information – sometimes rights apply to request a transfer of personal information held to other organisations. This right only applies to personal information that is processed by automated means and is held because it was necessary for the performance of the contract with you or personal information which is processed based on consent.
11. Keeping personal information safe
Bloom Education have put in place appropriate security measures to prevent the personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal information is limited to those employees who have a business need to know the personal information and will only be processed upon instructions from the partners. Procedures have been put in place to deal with any suspected breach of the requirements under the GDPRs and you and/or the Regulator referred to below will be notified of any potentially significant breach.
12. What happens if you want to complain?
It is hoped that you will not have cause to complain. If you do, complaints relating to Bloom Education should be referred to either Jo Clemo or Julia Beckett via the contact details below. If it is not possible or appropriate to refer a complaint to Bloom Education, it may be referred to the Regulator.
For the UK the contact details are:- Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF For more information contact www.ico.org.uk.
13. Miscellaneous
Bloom Education anticipate using automated decision making in relation to the personal information provided. This Privacy Notice may be updated from time to time. The latest Privacy Notice will be displayed on the Bloom Education website
Contact information
Bloom Education
Unit 2
The Red Barn
Easton Lane
Easton
Winchester
SO21 1DQ
07591998272