The Edwin Group (‘the Company’) Data Protection Lead for the Company – Jo Betteley Data Protection November 2021
All services available are provided on behalf of the Company by The Edwin Group, First Floor (South), Cathedral Buildings, Dean Street, Newcastle upon Tyne NE1 1PG.
The Company includes our trading activities that are branded Vision for Education/ABC Teachers/Smart Teachers. Please read the following Privacy Policy which explains how we use and protect your personal information. This Privacy Policy applies to the use of all our services and websites (and web-based services) on which a link to this policy appears (the “Sites”).
For the purpose of the Data Protection Act 2018 and the EU General Data Protection Regulation (the “GDPR”) (together, the “Data Protection Legislation”), the Data Controller is the Company of First Floor (South), Cathedral Buildings, Dean Street, Newcastle upon Tyne NE1 1PG and all services are provided by the Company.
We take your privacy seriously and we are committed to keeping your information private. To the extent we are required by law, we have notified the United Kingdom’s Information Commissioner’s Office that we will process your personal information in accordance with the Data Protection Legislation (as defined above).
By providing us with any information about yourself (including via our websites and in branch), you understand that we will process your personal information in accordance with this Privacy Policy and our Cookies Policy.
This Privacy Policy covers:
The Company is a recruitment business which provides work-finding services for our clients and work-seekers. The Company must process personal data (including sensitive personal data) so that we can provide these services – in doing so, the Company acts as a Data Controller.
Information that you provide to us directly
We collect personal information whenever you contact us and provide us with information that we are able to identify you by, including when you contact us by phone, email or when you sign up to use any of our services. In particular, we collect information about you when you register and create an account, send your CV, and every time you email us directly.
During the registration process, we will collect information via our website, during face to face interview and via our registration forms including:
Data Protection Legislation mandates that any personal information can only be used where there is a lawful basis to do so. At the Company, we rely on one or more of the following grounds to legally collect and use your personal information:
We will use your personal information to enable us to provide our services to you and enable you to use the Sites, including, for the following purposes:
Performance of a contract
Legal obligation
We will use your personal information where we are legally obliged to do so, this includes:
in law) as per Article 9 of the GDPR, specifically relating to the safeguarding of children and of individuals at risk in accordance with Data Protection Act Schedule 1.
Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data, our legitimate interests is/are as follows:
National Tutoring Programme (NTP)
Pupils
The Company will collect data via the school for all pupils engaged in tutoring sessions via the NTP. The Company will collect specific data as instructed by the NTP. This data will be kept securely within our portal and will only be used for NTP purposes. This data will be transferred securely to the Evaluator via their secure portal for reporting purposes. All pupil data, alongside any associated tutoring session information, will be deleted as soon as practicable after the Company is informed by NTP that it has ceased to be appropriate to retain the NTP data. All NTP data will be erased from any computers, storage devises and storage media. The Company will take further action as may be necessary or desirable to ensure our compliance with data protection legislation. For further information please see NTP Privacy Notice for Parents and Carers of Pupils and NTP Privacy Notice for KS4 Pupils.
Schools
The Company will collect data for all schools engaged in tutoring sessions via the NTP. The Company will collect specific data as instructed by the NTP. This data will be kept securely within our portal and will only be used for NTP purposes. This data will be transferred securely to the Evaluator via their secure portal for reporting purposes. All pupil data, alongside any associated tutoring session information, will be deleted as soon as practicable after the Company is informed by NTP that it has ceased to be appropriate to retain the NTP data. All NTP data will be erased from any computers, storage devises and storage media. The Company will take further action as may be necessary or desirable to ensure our compliance with data protection legislation. For further information please see NTP Privacy Notice for Schools.
Tutors
In addition to the data the Company collects as part of the candidate registration process, the Company will also collect further information for all tutors engaged in tutoring sessions via the NTP. The Company will collect specific data as instructed by the NTP. This data will be kept securely within our portal and will only be used for NTP purposes. This data will be transferred securely to the Evaluator via their secure portal for reporting purposes. All pupil data, alongside any associated tutoring session information, will be deleted as soon as practicable after the Company is informed by NTP that it has ceased to be appropriate to retain the NTP data. All NTP data will be erased from any computers, storage devises and storage media. The Company will take further action as may be necessary or desirable to ensure our compliance with data protection legislation. For further information please see N TP Privacy Notice for Tutors.
Consent
We will use your personal information where we have your consent to do so to:
It is your responsibility to ensure that any information submitted as part of the registration process is accurate and up-to-date. Should you wish to withdraw your consent at any time, please contact dpo@ visionforeducation.co.uk, dpo@abc-teachers.co.uk or dpo@smartteachers.co.uk.
In order to provide the services offered, we sometimes need to share your personal information with third parties. However, we will continue to be responsible for the usage and security of your personal information when this happens.
The Company will process your personal data and/or sensitive personal data with the following third party recipients:
Other circumstances where we share or use your personal information
In certain circumstances, we may be required by law to disclose your personal information to third parties such as government bodies, law enforcement agencies and data protection regulators.
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time. Specific details of our retention can be found here or on our website.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep work- seeker’s records for at least one year from:
We must also keep your payroll records, holiday pay, sick pay and pension’s auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
We retain personal information for as long as we reasonably require it for legal or business purposes. The Company and group offer work-finding services including permanent placements for senior leadership positions where the length of service is significantly longer, so our data retention period is greater. With this in mind, your information will not be kept for longer than 7 years after your last day of work, or from the date you were cleared to work, whichever is longer. Please note that we may be required, in certain circumstances, to retain your information indefinitely (for example under child protection legislation).
We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
Overseas transfer
The Company may only transfer the information you provide to us to countries outside the European Economic Area (EEA) for the purposes of providing you with work-finding opportunities abroad. The EEA comprise of the EU member states plus Norway, Iceland and Liechtenstein.
We take steps to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and for the activities we have detailed above. This means we will retain personal information for the duration of any contract we have with you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal information, we cannot guarantee the security of your data transmitted via email and/or our website - any transmission is at your own risk.
The personal information that we collect from you will, where possible, be stored and processed within the EEA. In certain circumstances, we may require third parties that are based outside of the EEA to process, host or store your personal information and by submitting your personal information to us, you are acknowledging this transfer, storing or processing. Please note that countries outside the EEA may not have the same standard of data protection legislation as countries within the EEA.
In the event your personal information is transferred, stored or processed outside of the EEA, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and the Data Protection Legislation. This means that we will only allow third parties to access your personal information where those third parties (a) are in countries that have been confirmed by the European Commission to provide adequate protection to personal information; or (b) have agreed to provide all protections to your personal information as set out in the Data Protection Legislation (such as by entering into the European Commission’s Model Clauses).
Should you have any queries or complaints in relation to how we use your information, please contact us via the details set out in section 9 below. You have the right to access the personal information we hold about you and to ask us to:
If you have elected to receive information about our products or services or the products or services offered jointly with or on behalf of other organisations and/or “alerts” from us via email (for example, by creating an email alert for a job) and would like at any time to unsubscribe from this service, please email us at dpo@visionforeducation.co.uk,dpo@abc-teachers.co.uk, dpo@smartteachers.co.uk or click on the “unsubscribe” link at the bottom of an email.
The Company may amend this Privacy Policy at any time and where we make material changes to it, we will provide notice on our website. By continuing to use our services and/or our Sites, you agree to the updated Privacy Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) our services and/or our Sites.
The registered office of the Company is:
The Edwin Group, First Floor (South), Cathedral Buildings, Dean Street, Newcastle upon Tyne NE1 1PG
We will use all reasonable efforts to answer any questions or resolve any concerns regarding your privacy promptly.
All comments, queries and requests relating to our use of your personal information are welcomed (including in relation to transfers of personal information outside the EEA). If you would like to contact us, queries should be addressed to The Data Protection Team at the above address; or by email at dpo@visionforeducation.co.uk, dpo@abc-teachers.co.uk or dpo@smartteachers.co.uk.