[This policy was last updated on 16/05/18]
1. Introduction
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there's a lot of information here but we want you to be fully informed about your rights, and how the Cambridge Russian School uses your data.
For example, we will explain things such as using Cambridge Russian School's website to enrol your child on a course and how we keep the collected information and personal details of you and your child.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Policy from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
When you are using Cambridge Russian School's website, Cambridge Russian School is the data controller.
2. What is Cambridge Russian School and who are its partners?
Cambridge Russian School – which we’ll refer to as ‘the School’ in this document – is a registered charity No 1121075 (more details can be found at the Charity Comission website: https://www.gov.uk/government/organisations/charity-commission)
The School provides supplementary education in Russian language and culture to children and adults, and runs associated activities for children and their families. The school acts in accordance with its Constitution:
http://camrusschool.org.uk/wp-content/uploads/2015/08/Constitution2015.pdf
The School may provide its educational services and organise cultural activities in partnership with other bodies. Currently, the School has the following partner(s):
- The Cambridge Russian-speaking Society
This Privacy Notice applies to School's activities performed within the UK.
For simplicity throughout this notice, ‘we’ and ‘us’ means the School and its brands, whereas 'partners' means the partners specified above.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which an organisation may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters from our partners.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
We'll never pass your personal data to our partners (as defined in Section 2 above) without your explicit consent. We'll never pass your personal data to any other third parties.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you enrol your child, yourself or someone else on a course provided by us, we’ll collect your name and address details to send you an invoice and additional information about the course you've chosen. Also, your name or the name of your child will be available to the teacher/instructor/lecturer of the course you or your child is enrolled on.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the School to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our activities and which does not materially impact your rights, freedom or interests.
For example, we will use your or your child's course attendance history to send you or make available personalised offers.
We also combine the learning and attendance history of many pupils to identify trends and ensure we can keep up with demand, or develop new courses and events.
We will also use your address and email details to send you direct announcements about school's activities, telling you about our courses and events that we think might interest you.
4. When do we collect your personal data?
- When you apply or are offered to become a member of staff/board of trustees or provide educational services or participate in an event at the School.
- When you visit our website and choose to use an online enrollment form.
- When you register for an event organised by us or make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you register for an event organised by us or purchase a product or service at the School, by phone or via email, but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a course, event or educational service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event, for example a class in calligraphy.
- When you choose to complete any surveys we send you.
- When you provide us with a feedback, comment on or review our courses. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the partner who provided that service, it may be passed on to them if requested.
- When you fill in any forms. For example, if an accident happens at the School and you or your child is involed, we may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- We may collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.
- When you use the car parks and premises hired by us which usually have CCTV systems operated for the security of both the School and its host, some information may be collected by third parties but not us. These systems may record your image during your visit. However, the School does not operate such CCTV systems or own information collected by them.
5. What sort of personal data do we collect?
- If you require a Disclosure and Barring Service (DBS) check in order to be able to teach at the School: any personal information that such check reveals.
- If you have enrolled yourself or your child on a course: your name, billing address, invoices and receipts, email and telephone number; your child's name, gender and date of birth.
- If you have booked to attend an event: your name, emai and telephone number.
- Details of your interactions with us via the administrative staff.
- For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of course enrolments you made, courses you show interest in, web pages you visit and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Information gathered by the use of cookies in your web browser (you can learn more about how we use cookies and similar technologies in our Website Cookies Note at https://camrusschool.org.uk/cookies/)
- Personal details which help us to recommend courses of interest.
- For example, you might tell us that your child wishes to learn more about robotics – this might prompt us to suggest you a course in programming whose contents include some elements of robotics.
- We’ll only ask for and use your personal data collected for recommending courses/events of interest. Of course, it’s always your choice whether you share such details with us.
- Your comments and course reviews.
- Your image and car number plate may be recorded on CCTV when you visit the car park of the venue hired by the Schoo and thus might be made obtained by third parties. However, the School does not operate such CCTV systems or own information collected by them.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
We want to give you the best possible experience when you and your child attend activities organised by the School.
The data privacy law allows us to collect and keep your personal data as part of our legitimate interest in understanding better the needs of our pupils/students and their parents and providing the highest levels of service.
If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to get in touch with you and offer you information about our events and activities.
For example, if you would like your child to continue attending the School and require information about the timetable, course details or fees, we can’t send you such information if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website or in person. If we don’t collect your personal data during checkout/registration, we won’t be able to process your bookings/order/registration and comply with our legal obligations.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best learning experience and understanding how we can improve our work based on your experience.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including special offers, discounts, promotions, events, competitions and so on. We’ll do this on the basis of our legitimate interest.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, changes in a course structure, and legally required information relating to your bookings/registration/orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
7. How we protect your personal data
We will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our website using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenized to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and we regularly review ways to further strengthen security.
8 How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and educational programme planning.
9 Who do we share your personal data with?
We sometimes share your data with our partners as defined in Section What is Cambridge Russian School and who are its partners? However, we would never do so without your explicit consent.
We do not share your data with any third parties other than our partners (as defined in Section What is Cambridge Russian School and who are its partners?).
For further information please contact our Data Protection Officer at admissions@camrusschool.org.uk
.
10 What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time as follows:
To ask for your information or ask for your information to be amended please contact The Data Protection Officer by using the following email: admissions@camrusschool.org.uk
.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking 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.
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.
11 Contacting the regulator
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).
12 Any questions?
We hope this Privacy Notice is helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered here, please contact our Data Protection Officer who will be pleased to help you:
Email us on admissions@camrusschool.org.uk
or speak to a member of admin staff.