We know that these policies can be confusing, but do not worry, we have made sure to break it down for you, so you can see exactly how we take care of your personal information so that we can find the best school or camp (or both) for you.
The first thing to know is that although it might seem like just a long, boring legal document, this policy, made in line with the new EU General Protection Data Regulation is there to protect you and your rights. You have a right to know exactly what happens to your information, how you can access it yourself, how you can ask us to keep it and pass it on, and a lot more.
This policy will explain exactly how we guarantee these rights for you when you trust us with your personal information, or that of your child. It will also explain how we receive and process your information in order get you the best British boarding school experience during term time and the best English-speaking holiday.
- What are we talking about?
In this notice, we refer to personal data and personal information. Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
This means any information relating to a person (in this case yourself or your child). We only collect and process the strict minimum of your personal information. We will never ask you for anything that we do not need in order to fulfil the service you have asked of us. This information will always be collected lawfully, for a specific purpose and will not be kept for longer that it is needed to perform the service in question. We make sure to keep all this information confidential and update it constantly to guarantee its accuracy.
- So, what data do we collect and where do we collect it from?
We deal primarily with parents when it comes to sending a child to a school. We will not agree to send a child to a school or camp, even if they are legally of age to consent without their parent’s or parents’ (or guardian’s) approval. This is our policy for the purpose of certainty of payment and because education is a crucial part of a student’s life, so such decisions need to be discussed with all parties (including the child where relevant) to make the best decision for you.
If you are a child and are would like to know your rights, please note that when your information has been shared, you are protected by the same rights that are listed in this notice. Some parts are also specific to you, although you should try to read the whole policy if you can because it applies to you as well. To make them easier to find, they are in blue.
We collect your personal data for the most part from your subscription to our newsletter and from emails, phone calls and meetings that we will have in order to discuss the best options for you and your child
Newsletter – When you relay information to us in order to sign up to the newsletter, we will only ask you for your full name and email address so that we can send you the newsletters you are interested in.
Personal emails, calls and conversations – When you would like to attend a school or camp, or you would like your child or, in the case of a legal guardian, your ward or charge, (hereafter regrouped under the umbrella term ‘child’) to attend a school or camp, we will always have a personal conversation with you to determine exactly what you wish your child to get out of the experience. This helps us make the time spent at school or camp the best it possibly can be. Therefore, once you have enquired to us about a potential placement, the personal information obtained will come directly from you.
In order to do this, we will collect your email address, your telephone number, we might also meet you at your physical address to discuss your options face to face. Your personal data will always be collected directly from you and with your consent.
School reports and sensitive information (special category data) – When you would like your child to attend a boarding school, we may ask you for prior school reports, which will include their date of birth, their previous school, academic references, marks obtained and overall appraisal. It may also contain a picture of the child. We will only accept this information if it is directly sent to us by yourself with your explicit consent and the consent of the child where necessary (please refer to the section on the personal data of children).
We may also, if necessary and in special circumstances, collect data relating to ethnic origin, religious beliefs, health data, which includes vaccinations and learning difficulties that might require curricular support. These will only be collected directly from you with your explicit consent and your child’s if legally required.
If we do collect any further information relating to you or your child, we will only do so with your explicit consent and directly from you and for a specific and necessary reason that will be discussed on a case by case basis.
(Please refer to section 5 for exceptional circumstances where the school or camp might choose to impart information relating to the child while on placement).
- Personal data of children
Some of the data processed by School Britannia relates to children; it is therefore particularly important to note the rules of child consent. In France, the disclosure of personal data of a child under the age of 15 requires the consent of the parent or guardian. While all requests for placement will be discussed on a case by case basis with you and your child, we will always ask for the parent or legal guardian’s explicit consent before processing the child’s data. In the case of children over the age of 15, we will still discuss with the parent or guardian directly before processing your information because of the nature of the service we provide.
We also make sure to discuss the choice with the child before they are placed in any school or camp where possible or legally required.
While the EU suggests 16 as the age of consent, if you are residents of another European country, this might differ. Please get in touch if you have further queries.
- How and why do we process your personal data?
In this section, we will explain why we collect your personal data and how we use it, including our legal justifications to do so and legitimate interests.
We will never use your data for another purpose than the one you have agreed to share it with us for.
Data collected for the newsletter – The data collected for the newsletter will be used simply to send you the requested newsletter. We may also contact you if we need to obtain or provide additional information. We might also check that our records are right and will check every now and then that you’re happy and satisfied. Our legal justification for this is your consent to receiving the newsletter. We only expect adults to sign up to our newsletter. If you are a French child under 15 and would like to sign up to your newsletter, please ask your parents for help or speak to us using the details at the bottom of the page.
Personal emails calls and conversations – We hold these meetings with you should you or your child want to attend a boarding school or camp. All of the data collected during these meetings will be used solely to try to find the best school or camp for you or your child. Our legal justification for this is your consent and the fulfilment of a contractual obligation. Where possible, we meet the child face to face with you to assess their competency to provide consent to the service.
School reports and sensitive information (special category data) – We use your child’s school reports and additional sensitive information to be able to find the best school or camp for your child. These are collected to be passed on to potential schools or camps (only where strictly necessary) (see section 5 on Disclosure). This is done so that both you and the school can assess whether your child would be the right fit. Our legal justification for this is your consent and the fact that it is necessary to fulfil our contractual obligations to you. In order to process your sensitive data, under Article 9(2)(a), we rely on your explicit consent to process your or your child’s special category data for the purposes that will be specified on a case by case basis. These will likely be for transfer to the relevant schools or camps to ensure accurate placement of the student or holiday goer.
If you are a child, please note that we will be holding and passing on your school reports to British schools so that we can find the best one for you. We only pass the reports on to three schools that you and your parents will have specially selected. Because we provide such a personal tailored service, it is necessary for us to know a little about you to do so, otherwise you could end up in a very different school or camp to the one that would have suited you best. If you are not happy with this, that is okay. Please email us using the details at the bottom of this page so we can talk about it.
In the event of an issue during the stay at a school or camp, the establishment may send us information about such issue to be relayed on to the parent. We will relay this information directly onto you and will advise should you need help with emergency procedures. We will discuss these emergency procedures on a case by case basis and insure that you are happy for us to receive this information directly from the schools for your benefit.
- Disclosure of your personal data (who we share it with).
Newsletter – We use the hosting service AWeber to host your email information to provide you the newsletter in an accurate and timely fashion. We have made sure to choose this platform because it is one of the leading providers in this industry. As with the other third parties we transfer data to, we require that they treat your data in accordance with the law.
Schools and Camps – We will pass on your data to schools and camps so that they can decide on whether or not your child is a good fit for the placement. These factors are mainly based on academic achievement and personal interests. To do this, we will first of all give you a few suggestions from which you will be able to choose. Because we are an agency and have a large pool of partner schools, we will withhold the name of the schools to avoid clients going directly to the school itself and bypassing our service. Once you are sure that the school or camp’s characteristics are right for you and your child, we will give you further information and only then, with your explicit consent (and your child’s where possible or necessary) will we pass on your child’s data. This may include sensitive information such as school reports.
Before sending your school reports and other data on to our partners, we will always speak with your parents directly and record their explicit consent. We will speak with you as well where we can and are legally required to do so, as you should know exactly what is happening to your information. We never give your information to people who are not allowed to see it and you will always be able to ask us exactly who as access to your data at any time. If you would like to ask more about this process, please contact us using the details at the bottom of the page.
Transferring outside of the European Economic Area – In some cases, parents and children prefer to go to English speaking schools and camps in English speaking countries that are not England, for example the United States or New Zealand. These schools are outside of the European Economic Area. When we do so, it is, again only with your explicit consent.
While these countries are not subject to the same rules as in the EU, they have a high standard of privacy protection. Where we are not convinced of the country’s protection guidelines, we will strongly discourage you from allowing us to send your information to them. These procedures will be discussed with you on a case by case basis.
- How long do we keep your personal data for?
We only hold on to your personal data for as long as we need it to provide the service you have asked of us, unless we must keep it a little longer for our own legitimate purposes. Under GDPR, you have a right to be forgotten. This means you can ask us to delete your data at any time. In some cases, we will have to keep some facets of your data if they must be kept by law or we have a legitimate reason to do so. If this is the case, we will explain to you exactly why we cannot fulfil your request.
Newsletter – We will hold on to the personal information that you have shared with us in order to send you our newsletters for as long as we keep sending newsletters. We do this to continue to provide you with the service that you have asked of us. At the bottom of each newsletter, you will find an unsubscribe button. You can unsubscribe from the newsletter at any time. If you wish to unsubscribe, please do so using this function. Alternatively, you can email us directly using the details at the bottom of the page.
Information relating to schools and camps – We always keep the information given to us in relation to a placement in a school or a camp until the formalities of the agreement between the school or camp and the client are finalised. This is because clients and the schools prefer to keep us in the loop in the case of translation problems, logistical issues and the fact that some parents prefer to speak directly to us in the case of a question or issue, rather than go directly to the school or camp. In these cases, it is necessary for us to hold on to this information to be able to assist you swiftly, accurately and to the best of our ability. (If you choose to cancel your placement request, we will delete your data within a reasonable delay.)
We sometimes will hold the data for a longer time. This is mostly because some parents and children will choose to undergo a second stay in another school or camp. We therefore would use our existing database to avoid the time-consuming and unproductive process of asking for all the information a second time. However, this will be dealt with on a case by case basis. Once you have given us the explicit consent to hold the information for longer, you will always have the ability to revoke this consent at any time, at which point we will delete your information, allowing for a reasonable delay depending on our workload.
If you have made a payment to us, we are required to keep your basic personal information for six years for taxation purposes.
If any legal claims are brought, we reserve the right to keep appropriate data for additional time in accordance to the appropriate time of the duration of the claim.
As a child, you have the same right to demand that we delete your information, either with parental consent if you are under the age of 15 and in France, or directly to us if you are 15 or older. If you would like to hear more about this, please read the section above or speak to us using the contact details at the bottom of the page.
- Who has access to your personal data?
Your personal data will only be processed by our authorised agents on a case by case basis, depending on what service you have asked of us. Your data will never be seen by or shared with any person or body that is not necessary to the performance of the required service.
- Keeping your data safe
We make sure to keep your data completely private. We have put in place the relevant security measures to avoid breach, loss or misuse of your personal data. School Britannia operates on a high standard of confidentiality and will treat your information with care to the best of our ability.
- Knowing your rights
Please find below a list of your rights that are guaranteed to you by the GDPR. These apply both to children and adults alike.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that School Britannia refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain to a governing body if this is the case.
If you have any questions about these rights or would like to exercise them, or have identified a potential issue, we ask that you get in touch with us first so that we can attempt to resolve the issue internally if we can. Please see the details below.
- Who are we? (contact details)
‘School Britannia Ltd’ is are a British agency primarily for French children who would like to spend time either at school or in at a camp to learn English.
Name: School Britannia
Postal address: 48 Rothschild Drive, Sarisbury Green, Southampton, SO31 7NS
Thank you for reading this notice.
We hope that you will have a wonderful stay in your new British school or camp.