At Accent Communication Coaching, we understand our responsibilities with regards to the types of personal information we collect and use throughout our business in order to deliver our English Language Learning services. We’d like to tell you as clearly and simply as possible how we look after this information.
Who is responsible for your data?
For students booking a course directly with Accent Communication Coaching (via the website or over the phone) – The school is responsible for your data. Our registered address is 15 St Marychurch Road, Torquay, TQ1 3HY. We are registered as a company in England and Wales under company number 13775877. We are the data controller of the data which we collect from you, and as such we determine how your personal data is collected and the purposes for which your personal data is used.
Our EU GDPR Representative is: Rickert Rechtsanwaltsgesellschaft mbH. Address: Colmantstraße 15, 53115 Bonn, Germany. firstname.lastname@example.org
For students booking a course through an ETO – the ETO is the controller and is primarily responsible for how your information is collected and used. In this instance the school acts as an independent controller which means that we receive the information about you from the ETO in order to deliver the services they or you have requested and we keep this data, adding to it where necessary, until the course has come to an end. When the course is finished, Accent Communication Coaching becomes the processor and follows the instructions of the ETO as to what we do with your data.
ETO – Educational Tour Operator (commonly known as an agent).
Personal data we collect about you
- Your full name, date of birth and contact details (email address, mobile number)
- Gender and nationality
- Next of kin and emergency contact details
- Proof of identity and visa (if applicable)
- Sensitive information about you and about your health (see information below about ‘sensitive personal data’)
- Information about any allergies or medical conditions
- Communication we have with you (emails, letters, messages sent to us through our social media platforms, feedback)
- Information about you, your location and how you use our website
Sensitive personal data
Certain kinds of personal data, such as data about your racial or ethnic origin, your physical or mental health or your religious beliefs are special categories of personal data which by law require additional protection. We try to limit the circumstances in which we collect sensitive personal data of this kind, but we do collect and process it when for example:
- You have requested special assistance
• You have requested a special meal type which implies or suggests your religion (e.g. a halal diet) or a health issue (e.g. a gluten-free meal).
If we ask you for this kind of information we will specify what we need it for at the time we ask for it. We need your explicit consent to collect and process this data, but in the case of health information, it will be very difficult for us to safeguard your wellbeing if you do not permit us to do so.
How we use your personal data
We can only use your personal data if we have a legal basis for doing so. According to the law, we can only use your data for one or more of these reasons:
- To fulfil a contract we have with you, or
• If we have a legal duty to use your data for a particular reason, or
• When you consent to it, or
• When there is a legitimate business interest.
Another way of describing legitimate interest is fair and balanced reasons for processing data. We would use this reason for processing your personal data if we have a necessary business activity or if we believe that you would benefit from us processing the data in this way.
What we use your personal data for
Legal grounds for using it
- To provide services to you
- Communicating with you and to send you information about your booking
- Fulfilling our contract to deliver the service you have requested
- With your consent (in the case of sensitive data)
- To meet our health and safety responsibilities
- To support the relevant public bodies and authorities responsible for immigration, customs control, policing and security
- To protect your vital interests
- To fulfil our legal obligations
- To respond to complaints and to seek to resolve them
- To obey laws and regulations which apply to us and the way we deliver our services
- Under Legitimate interest
- To fulfil our legal obligations
- To run our business in an efficient way
- To fulfil our administrative purposes including accounting, billing and audit
- To improve our services
- Under Legitimate Interests
- To fulfil our legal obligations
Marketing: how to manage the marketing messages you receive
We may send you marketing communications by email if you have indicated that you are happy to receive such emails.
You can always opt out of receiving marketing emails by clicking on the unsubscribe link which we include in all our marketing materials.
Please note that if you ask us to stop sending marketing emails, we will keep the smallest possible amount of your personal information and your request so that we can make sure you are excluded from any future emails.
How long we keep your data
We keep your data only for as long as we need it. How long we need data depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests (described above) or so that we can comply with the law.
We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or anonymise it.
How we protect your data
We protect your personal data against unauthorised access, accidental loss, corruption or destruction.
We use technical measures such as secure servers and password protection to protect your data and the systems they are held in.
Sharing your data
We share some of your data with the following categories of third parties, but only where strictly necessary, and we ensure that we only share the minimum amount. We communicate clearly with the following parties the need for them to take as much care with your information as we do:
- Homestay providers or other accommodation providers
- Transfer and transport providers
- Teachers and activity leaders
- Medical professionals
- Government authorities
- Data analytics companies
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you;
- 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’;
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
To raise any objections or to exercise any of your rights, you can email the School Director on Georgian@accentcoaching.uk or write to us at FAO GDPR LEAD, Accent Communication Coaching, 15 St Marychurch Road, Torquay, TQ1 3HY.
When you get in touch, we respond promptly without undue delay. We may ask you to verify your identity before we provide any information to you.
Transfer outside the European Economic Area
If we need to send any information outside of the EEA, it will only be done with the proper legal protections or permissions being in place.
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Who we are
Accent Communication Coaching is a company registered in England with the number 13775877. Our address is 15 St Marychurch Road, Torquay, TQ1 3HY. The telephone number is 01803 295576. We are registered as a data controller with the Information Commissioner’s office – our registration number is ZA321601.
Your right to complain
If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority – details of which are given below:
Information Commissioner’s Office
Telephone: +44 303 123 1113
Changes to this policy by date