Inspired is a company registered in England as Inspired Education Holdings Limited, company number 09268120 with its registered address as Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom. Inspired operate numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.
Inspired takes seriously data protection and our responsibilities to correctly and lawfully process personal data as a data controller. We are committed to complying with legal obligations and practicing industry standards when collecting, processing and storing personal data.
This privacy notice provides detailed information about how we process the personal information that you provide to us. Our Data Protection Officer can be contacted by email on firstname.lastname@example.org if you have any queries regarding the processing of your personal data.
2. TYPES OF PERSONAL DATA WE PROCESS
We process personal data about employees, suppliers, contractors, prospective customers and third parties interested in finding out more about our company and the schools within our group. All data related to students, parents and employees of the affiliated schools is processed within the systems controlled by each of those individual schools. You can read the associated privacy notice for each of our schools within the individual school website.
The personal data we collect, process and store will be personally identifiable information related to customers, prospective customers, previous and current employees, contractors, suppliers and supporters. The personal data processed include recorded information that is verified and correct and/or video and photographic images about an individual. The collected Information is the following:
- names, addresses, telephone numbers, e-mail addresses and other contact details;
- family details;
- education and employment data;
- images, audio and video recordings;
- financial information;
- education centres previously attended.
Other types of data we may collect, process and store are: information related to health, criminal record and other sensitive information related to an individual. Information such as;
- information about health status or provision of health care linked to a specific individual;
- information about criminal records linked to a specific individual;
- biometric information;
- race and/or ethnicity;
Information related to past and present parents and students is processed and stored by our affiliated schools within the systems controlled by those individual schools. You can read the associated privacy notice for each of our schools within the individual school website.
3. HOW WE COLLECT AND PROCESS PERSONAL DATA
Inspired collects information in several ways, including:
- personally and over the phone: from customers, prospective customers, staff, volunteers, visitors, job applicants and others;
- from electronic and paper documentation: including job applications, emails, invoices, letters to our organisation, consent forms, our company website or via social media;
- through online tools: such as apps and other software used by our staff;
- through any CCTV cameras located at our premises or sites;
- through third parties, such as referees, professionals or authorities working with the individual
- through publicly available resources
As an organisation, we may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with statutory obligation or where Inspired has received specific consent from the individual concerned. Our staff collect, process and store personal information only for the purposes for which it is intended for as long as those purposes remain valid.
All personal data which is collected by regional offices is stored within the European Economic Area on systems that are provided by our organisation, third parties and/or cloud storage providers. These systems include Enterprise Resource Systems, Human Resources Information systems, web servers and email systems.
We may collect personal data outside of the European Economic Area, however, regardless of location, we will impose the same data protection safeguards that we deploy inside the European Economic Area. We do not transfer personal data outside the European Economic Area unless we are satisfied that the personal data will be afforded an equivalent level of protection.
Our organisation has a Data Protection Standard in place to oversee the effective and secure processing of your personal data. We have policies around the use of technology and devices, and access to school systems. We try to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
4.1. Inspired processes personal data to lawfully and legitimately support the organisation’s operation. Our organisation collects information about customers, prospective customers, suppliers, contractors, employees and future employees when necessary to:
- send prospective parent information to our affiliated schools;
- provide references for current and past employees;
- support operational management of the organisation including invoice management , fees and accounts; management of the organisation’s property; management of security and safety arrangements (including the use of CCTV in accordance with our security policies and monitoring of the organisation’s IT and communications systems in accordance with our Data Protection Standard); management of planning and forecasting; research and statistical analysis; administration and implementation of the organisation policies for staff and other operational purposes;
- fulfil legal requirements;
- take reasonable steps to reduce the risk of reasonably foreseeable harm to clients, staff and visitors;
- make reasonable adjustments and support for staff with special needs;
- provide a safe and secure working environment;
- communicate with parents about our schools and philosophy and celebrate the efforts and achievements of students within our affiliated schools;
- maintain the good order and management of our organisation;
- promote our affiliated schools on our school’s website or social media and other publications and communications conducted by our organisation.
Our organisation collects information about staff, prospective staff, customers and prospective customers, suppliers and contractors when necessary for:
- the administration of staff records;
- the recruitment of staff;
- the engagement of contractors;
- administration of payroll, pensions and sick leave;
- staff appraisal;
- disciplinary procedures;
- administration of human resources records;
- providing references
The personal data object of processing may only be communicated to other schools within the Inspired group with the prior written consent of the data subject and the mentioned personal data will be processed with the same legitimate purposes mentioned herein.
4.2. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
In the context of the purposes as listed above, we may share your personal data with third parties, such as the service providers we use (e.g. IT service providers, marketing agencies, etc.). Your personal data can also be disclosed to our affiliated companies and professional contacts.
We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data).
The parties to whom we may disclose your personal data as referred to above may be located in countries outside the European Economic Area (EEA), including in countries which may offer a lower level of data protection than in the EEA.
In such case, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation. More specifically, when no specific derogation applies, we will only send your personal data to recipients located in the US who have subscribed to the EU-US Privacy Shield, or we will enter into the European Commission’s Standard Contractual Clauses when necessary.
Your personal data shall be neither rented nor sold to third parties.
5. HOW LONG DO WE KEEP PERSONAL DATA
We retain personal data only for a legitimate and lawful reason and only for so long as necessary or required by law. Our Data Protection Officer can be contacted by email on email@example.com if you have any queries regarding the retention of your personal data.
6. YOUR RIGHTS
Under Data Protection Law you have rights regarding the collection, processing and storage of your personal data. These rights are, however, subject to certain exemptions and limitations.
You have the right to:
- be informed, at the time when personal data is obtained, about the personal data that we hold and its processing.
- access to the information we process and how we process it as well as to obtain a copy of the personal data undergoing processing if it doesn’t affect the rights and freedoms of others ;
- ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
- obtain the rectification of your personal data providing a supplementary statement;
- obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
- obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
- object to processing for direct marketing purposes;
- withdraw consent at any time and freely to the processing of your personal data (this is with limitations and exceptions as we may have lawful reason to process such data regardless of consent)
Therefore, in accordance with the provisions of GDPR, data subjects will be able to exercise their rights by sending a written specific request, along with a copy of their ID card, to the following email address: firstname.lastname@example.org.
7. SUBJECT ACCESS REQUESTS (SAR)
The Subject Access Request (SAR) procedure regulates the right of the subjects to access their personal data verbally or in writing and at no charge. We have processes in place to ensure that we respond to a subject access request without undue delay and within one month of receipt although we can extend the time limit to respond to a request if necessary. We are aware of the information we must provide in response to a subject access request and the need to provide it in clear and plain language.
Any data access request is subject to certain exemptions, limitations or contractual obligations. Data belonging to or identifying other individuals is exempt from right of access and will be subject to legal privilege. We cannot disclose any confidential information related to the purpose of providing education within our group of schools, examinations or supplying examination scripts to external bodies. We cannot disclose confidential information on any of our staff.
According to the GDPR, we are required to obtain consent to process an individual’s personal data under legal limitations and exceptions as we may have lawful and legitimate reasons to process such data to support the organisation’s operation or fulfil contractual or legal obligations, regardless of consent. When our organisation collects information about you, we take reasonable steps to advise you of certain matters. This includes the purpose of the collection, and how to access, update and correct information held about you. For information relating to students and their families, a consent form is provided to parents (or mature students) via our affiliated schools directly. In some cases, we may send out separate consent requests using:
- paper based consent forms;
- electronic consent forms;
- digital applications to obtain consent
Inspired has adopted all necessary technical and organizational means in order to guarantee the confidentiality, security and integrity of personal data that is concerned, as well as to avoid the loss, alteration, destruction and/or access of unauthorised third parties.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) http://www.ico.org.uk/ . We recommend that you contact our Data Protection Officer by email on email@example.com to take necessary steps to resolve the matter before contacting the ICO.
11. PRIVACY NOTICE UPDATES
Inspired will update this Privacy Notice from time to time. Any substantial changes that affect how we process your personal data will be notified on our website. If required, we will also notify you directly. This Privacy Notice should be read in conjunction with other organisation policies and any contract terms and conditions.
This policy was last updated in April 2020