Privacy Notice for Tuition360 Ltd
As a private tuition agency providing clients with a high standard of academic tuition, mentoring and education consultancy services, effective customer service is paramount to the way Tuition360 works. At the fore of our operation is the highest respect for your privacy, personal data, and any other information we require to provide the services you need. Tuition360 stores, manages, uses and disposes of your data in accordance with the laws in England and Wales, and EU directives that the UK is a signatory to, and your requests. The following privacy notice outlines how Tuition360 collects, uses, processes, shares and secures your personal information.
The privacy notice is important for data subjects to understand how Tuition360 values your privacy and how Tuition360 works in relation to this. In this privacy notice, a “data subject” refers to any individual Tuition360 obtains the personal data of. If you have any further questions, please feel to contact firstname.lastname@example.org.
What information do we collect?
The General Data Protection Regulation 2016/679 regulations enacted in May 2018 place a legal obligation on “controllers” of personal data. Tuition360 is a controller of data, in that Tuition360 determines the purposes and means of processing personal data. Tuition360 obtains personal data via the Tuition360 website (www.tuition360.co.uk), over the phone with Tuition360’s administration team, submissions for subscriptions, tutor recruitment, data collated for Tuition360 services for both tutors and clients, or in any other case where an individual provides information directly to Tuition360. Types of personal data obtained include (list is not exhaustive):
- Email address
- Postal address
- Telephone/mobile phone numbers
- Date of birth
- Payment information (bank account details)
- Educational information (institutions attended, educational preferences, qualifications)
- ID and proof of address
- Enhanced Disclosure & Barring Service certificate
How do we use personal information?
There are a number of service and business related purposes for which Tuition360 processes data. These include:
- Account set up and administration – Account set up for both clients and tutors requires personal data, as Tution360 may require your location, educational preferences, age, address, email address, as well as other types of data for tuition services, or other educational services to be delivered. Tuition360 uses TutorCruncher tutoring management software – https://tutorcruncher.com/gb/ – for account set-up for client, tutors, mentors, and consultants. All account information is stored on this software, and TutorCruncher is bound by its own data protection and privacy policies.
- Service delivery – When the client uses a Tuition360 service, the relevant data will be shared between clients and tutors or clients and consultants to enable an introduction to be made. For example, a client who has booked tutorials will require the phone number of a tutor to arrange lessons, similarly, the tutor will require the address of a client, if lessons are to be held in the client’s home.
- Legal obligations – Tutors working with children under the age of 16 or vulnerable adults are required to have an Enhanced DBS certificate before tuition takes place. In the case where Tuition360 applies for the Enhanced DBS certificate on behalf of the tutor, mentor, or consultant, aside from name and email address, the data subject provides personal information directly to a third party processing company for the purposes of obtaining an Enhanced DBS check. Tuition360 will in person verify proofs of ID and address to verify the individual on behalf of the third party. These documents are never saved on Tuition360 devices or systems. Once the certificate is issued, Tuition360 is notified about the status of the certificate by the third party company and Tuition360 will then verify the result of the tutor’s certificate in person and note the date of issue on the tutor’s Tuition360 account.
- Payment – banking information is required for clients to make payments for services via direct debit. With the exception of refunds, Tuition360 does not obtain bank account details from clients for other payment methods. For credit and debit card payments, Tuition360 uses the Stripe payment system – https://stripe.com/gb. Payment details processed on Stripe are not saved on Tuition360 devices or systems. For tutors to be paid, tutor information retained for payment is securely stored and password protected.
- Personalisation of content, business information or user experience – Delivering marketing and events communication if the data subject opts in to receiving them. Subscribers can un-subscribe at any time through a process detailed at the footer of each email campaign.
- For any other instance where information is given directly by client or tutor to Tuition360.
What legal basis do we have for processing your personal data?
Tuition360 processes the data of data subjects in line with processing conditions contained within the GDPR. The basis of this is that data is obtained for business purposes, in that Tuition360 is unable to provide its services without obtaining personal data.
Tuition360’s legal basis for obtaining personal data is the legitimate interest basis outlined in the GDPR. Legitimate interest is identified as the use of Tuition360’s services. To act upon this, data must be processed by Tuition 360. This basis applies because Tuition360 requires data, such as the examples listed in “what information do we collect?” to enable tuition, mentoring or consultancy services to take place. For example, the personal data of a client requesting tuition sessions from a tutor registered with Tuition360 is required for the introduction to be made. Alternatively, Tuition360 would require the banking information of a Tutor to ensure payment is made to them.
When do we share personal data?
Tuition360 treats personal data confidentially and is not shared with third parties without active consent being sought from the data subject for mutually agreed business purposes or the purposes outlined above. Consent is obtained from the data subject prior to services commencing in the form of a Service Agreement. This is the case with clients, tutors, mentors and consultants. The Service Agreement requires consent upon first service delivery. Data subjects are made aware in the Service Agreement that they reserve the right to withdraw consent, with requests made in writing to Tuition360 at any time.
The circumstances when Tuition360 might share your information are in the cases of:
- Client-Tutor details exchange: central to Tuition360 introducing clients to tutors/mentors/consultants is the exchange of data between clients and tutors, clients and mentors, or clients and consultants. Data is shared via email, which contains a disclaimer about those who are not intended recipients. This safeguard instructs unintended recipients to delete the email if received.
- Processing Enhanced DBS checks on behalf of tutors and consultants.
How do we secure personal data?
To protect personal information Tuition360 employ data security practices in relation to the technologies used. Data protection is carried out to:
- Protect data against accidental loss
- Prevent unauthorised access, use, destruction or disclosure
- Ensure business continuity and disaster recovery
- Restrict access to personal information
- Conduct privacy impact assessments in accordance with the law and our business policies
- Train staff and contractors on data security
Any further questions on data security, please email email@example.com.
How long do we keep your personal data for?
Tuition360 will retain personal data for each processing purpose for three years after communications are ceased with the data subject, unless the data subject has requested deletion of their personal data in writing to Tuition360. This, based on the nature of services provided, is considered a reasonable time frame. This will be the case for each account processed, and the case every time Tuition360 obtains personal data. Data deletion is thorough and is done from all Tuition360 password-protected devices.
Your rights in relation to personal data
Under the GDPR, Tuition360 must respect the right of data subjects to access and control their personal data. Data subjects have rights in respect of:
- Access to personal information -data subjects have the right to request to see the personal information tuition360 holds about them. To obtain this information, the data subjects must send a written request to Tuition360, and proof of identity will be requested in any case where personal data is requested by the data subject. Such requests must be sent to firstname.lastname@example.org.
- Correction and deletion of their personal information – data subjects have the right to request corrections to personal information, and to request the deletion of personal information by Tuition360. If any information Tuition360 holds about the Client is incorrect, Tuition360 will update this information if requested by the Client. The Client reserves the right to request Tuition360 delete their personal information from all systems. Such requests must be sent to email@example.com.
- Withdrawal of consent: If consent is sought by Tuition360 about the use of personal data for certain services or subscriptions, then this consent can be withdrawn by data subjects.
- Restriction of processing and objection – data subjects can restrict the processing of their personal data. In respect of website use and cookies, a separate policy is in place: https://tuition360.co.uk/cookies-policy/
- Lodging a complaint with the Information Commissioner’s Office – data subjects have the right to do this.
- A separate policy is in place regarding the Website and cookies.
Data subjects should contact Tuition360 on firstname.lastname@example.org with any questions about the rights listed above, or for any requests in relation to these rights.
How to contact us?
The data subject can get in touch with Tuition360 if they have questions or concerns about this privacy notice and practices outlined, or if they wish to file a complaint. This can be done by:
- Email: email@example.com
- Website: www.tuition360.oc.uk
- Postal address: Tuition360, 78 York Street, London, W1H 1DP
- Phone: 020 7078 7202
Tuition360 Ltd is registered in England and Wales under registration number 10818811, and our registered office is at 16 Exhibition House, Addison Bridge Place, London, W14 8XP.