Choices International Limited (“We”) are committed to protecting and respecting your (you, your) privacy. We take the privacy of all of our customers and other users seriously and take great care to protect your personal information.
This policy (together with our Terms of Website Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.choices-international.com you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Choices International Limited of 11 Portland Street, Manchester M1 3H1.
PRIVACY & GENERAL PRINCIPLES
Please read the following policy carefully to understand what information we may collect from you, how we may use it, and your rights in respect of our use.
We will be guided by the following principles when processing data:
We collect information on you:
LEGAL BASES FOR PROCESSING YOUR DATA
The General Data Protection Regulation (GDPR) establishes 6 legal bases on which we can process your data: these are Consent, Contract, Legal Obligation, Vital Interests, Public Task and Legitimate Interests. For further information about these legal bases and fuller definitions, please refer to the ICO website.
We use different legal bases for processing your data depending on the purpose for collecting your data in the first instance:
We will make it as easy as we can for you to opt out of unwanted processing under Consent, providing it does not restrict our ability to provide you with the primary service you have requested.
We collect data for a wide range of purposes. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or pseudonymised and/or minimised and retained.
We are co-processors of information relating to marketing and booking clients with partners overseas (for example ETOs, schools, government and national sponsors). As such, we may transfer some data outside of the EU, but this will be limited to data necessary for the performance of a contract made in the interests of the individual (which is an exemption to the 8th principle of the GDPR legislation). We remain responsible for the data held, processed or sent via our systems. We are not responsible for the security and processing of data which is held, processed or sent via our partners’ systems. However, we require all of our partners overseas to confirm that they will process data securely in line with the requirements of GDPR or the equivalent in their country. We do not sell your data at any time.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
We may disclose your personal information to third parties:
SPECIAL CATEGORY DATA/CRIMINAL RECORD DATA
We may request health data from potential students and employees. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee.
The school has safeguarding responsibilities and carries out DBS checks on all staff and other people who are likely to be have direct supervisory responsibility for or unsupervised contact with young people under the age of 18. We may process and record securely risk assessments of these DBS checks where the disclosure is not clear. These risk assessments will be disposed of securely when that person no longer has supervisory responsibility or unsupervised contact with young people under the age of 18 on behalf of the school.
CHILDREN UNDER 18
We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form. As part of this process, we request special category data relating to the health of the child, which we manage through Vital Interest.
We also gain consent from parents for the use of photos or video taken during their child’s stay at Choices International through the Parental Consent Form.
How we will use information collected by our website
We may use information held about you in the following ways:
Links from our website
PERSONAL INFORMATION AND YOUR RIGHTS
You have the right to rectify, erase or restrict the processing of your data subject to the exceptions outlined in this policy. You also have the right to withdraw consent to the processing of information for which you have previously given consent. You can contact us at any time to have these details removed from our database or to update this information, subject to satisfactory proof of your identity. You can read more about your individual rights on the ICO website.
You may also request access to the data we hold on you. Provision of such information will be subject to:
a) The payment of a fee (currently fixed at £10)
b) The supply of appropriate evidence of your identity.
We may withhold personal information that you request to the extent permitted by the law.
To make any of these requests relating to your personal data, please contact us at: [email protected]
LEGAL INFORMATION AND HOW TO CONTACT US
Any request for information (personal information, requesting a correction, or comments) should be addressed in the first place to: [email protected]