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Privacy Notice


PRIVACY NOTICE

Information for you about how we look after personal information about yourself and your child or children.

  1. Background

On 25th May 2018 a new law comes into place. It is known as the General Data Protection Regulation (GDPR). There is a lot of terminology used within the GDPR, but basically this is about how personal information is collected about you and your child or children’s study with us and how we use and look after it. This document sets out the detail about how the personal information provided will be used and looked after and explains your rights in relation to it.

  1. Our commitment to you

Our commitment is to:-

  • Keep personal information about you and your child or children safe and private;

  • Not use personal information for any purpose other than in connection with your children’s studies, keeping you informed of information about RCS Haven, to continue to develop RCS Haven business to deliver the most effective and rewarding student experience possible and in accordance with the other purposes set out in this notice;

  • Make it easy for you to approach us if you have any concerns or questions relating to the holding of personal information;

  • Not provide personal information to others save where legally required to do so or to assist us with our tasks.


  1. How information is collected from you

Information in relation to parents and students will be collected by the teachers or by his or her assistants on the Educational coordinators behalf and/or by RCS Haven. This might be achieved by providing information verbally, whether face to face or by telephone, completion of paper documents or by electronic means such as through email or interaction with our websites. Please ensure that all personal information is accurately provided as the information which is held is only as accurate as the information provided in the first place.

If any of the personal information provided changes, please notify the teachers as soon as possible in order that the personal information can be updated.

  1. What personal information will the Instructor collect from you?

RCS Haven will require the following information about the student:-

  • Name;

  • Address;

  • Contact details;

  • Date of birth;

  • Schooling related information;

  • Gender;

  • Health related information and other information relevant to being able to teach the student most effectively;

  • As the student’s studies progress the teachers will accumulate information in relation to the student’s work and its progression.

Information which will be required from parents/legal guardians: -

  • Name;

  • Contact details;

  • Relationship to student;

  • Details of others who are authorised points of contact if a primary contact is not available;

  • Any other information which may be provided and which is relevant to the education of your child or children.

The teachers may also ask for or receive contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and whether the student is a native Russian speaker.

The teachers will not seek any further personal information in relation to parents or students without gaining specific authority.

The teachers will not take or publish photographs of students or publish students’ names without your consent as the parent/legal guardian.

  1. Who will the teachers provide personal information to?

The teachers will provide the personal information referred to above to RCS Haven for it to use for the purposes set out below.

The teacher will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators.

  1. What about outsourcing by the Teacher?

It is possible that the Instructor will pass personal information to other organisations to assist him or her. This is not for other organisations to use on their behalf but rather to process information on the Teacher’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, training and printing.

  1. What will the Instructor use the personal information for?

  • To fulfil his or her contractual obligations and to respond to enquiries:-

    • to provide the course of study;

    • administer the course of study;

    • ensure the quality of the programmes

    • to respond to enquiries about the study offered;

    • to seek feedback about study experiences;

    • to address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;

    • to record and/or report upon the progress of the student;

    • to consider, record and communicate other issues which may be impacting upon or related to the progress of the student;

    • to respond to complaints.

  • To ensure vital interests:-

This relates to the health and safety of a student. For example, if there was a medical emergency the Teacher may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.

  • When it is the Teacher’s legal duty

The Teacher may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

  • When legitimate interests apply

It is possible that from time to time the Teacher may wish to communicate with parents concerning other matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:-

    • To inform parents of potential career opportunities with the Teacher;

    • Providing news updates about developments at RCS Haven. This might for example be in relation to changes to the RCS Haven programme, information relating to it, educational meetings

    • To communicate about particular study opportunities and useful information about RCS Haven

    • study, for example particular trials, promotions and campaigns.

Any communication under this heading will be of the nature referred to above. The Teacher will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.

If you do not wish to receive communications under this heading, please contact the Teacher and let him or her know which type of communications you would not wish to receive.

  • When you consent

There are certain uses to which the Teacher will not put personal information without your specific consent. Where such consent is requested it will be sought separately. It is likely to be in areas such as in photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies.

If consent is given it can be withdrawn at any time by providing notification to the Teacher in writing or by email.





  • Other

Instructors may also use personal information for management and statistical purposes to enable better running of our Study Centres.

  1. What personal information may RCS Haven collect from you directly?

We have already indicated what information the Teacher may collect from you and provide to RCS Haven


Sometimes early exchanges of information will be with RCS Haven rather than with the Teacher. This section deals with those and other circumstances.


In such circumstances RCS Haven

is likely to require the following information about the student:-

  • Name;

  • Address;

  • Contact details;

  • Date of birth;

  • Schooling related information;

  • Gender.



Also, RCS Haven is likely to require the following information from parents/legal guardians:


  • Name;

  • Contact details;

  • Relationship to student;

  • Details of others who are authorised points of contact if primary contact is not available;

  • Any other information which may be provided and which is relevant to the education of your children.

When undertaking visits to RCS Haven may also require or obtain contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and whether the student is a native English speaker.

  1. Who will RCS Haven provide personal information to?

RCS Haven will provide the personal information referred to in the preceding paragraph

to the Teacher for him or her to use for the purposes set out above.

to Pearson Institute as a part of registration procedure of students who would like to register for GCE or GCSE Examinations.

to SQA as a part of registration procedure of students who would like to register for Russian for life and Russian for work Examinations

Pearson Institute and SQA have their own Data protection policies and regulations

We will ensure that appropriate technical and organisation measures are in place such that this data is shared with partner organisations (Pearson and SQA) in a secure way and that it is stored in a secure way.

RCS Haven will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, or otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators.

  1. What about outsourcing by RCS haven?

It is possible that RCS Haven will pass personal information to other organisations to assist it. This is not for the other organisations to use on their behalf but rather to process information on RCS Haven’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, printing and training. This might include the transfer of personal information outside of the European Union and if this is the case security measures will be taken to protect the integrity and security of the data.

  1. What will RCS Haven use personal information for?

The Teacher has day-to-day responsibility for the operation of the Study Centre and interaction with parents and students. However, there will be times when for one reason or another a Teacher is not able to undertake a task when RCS Haven may step in to aid and in so doing will make use of the personal information. RCS Haven will also use personal information to seek to refine and improve the effectiveness of the study programme and the student experience.

RCS Haven may therefore use personal information for the following purposes:-

  • To help the Teacher fulfil contractual obligations and to respond to enquiries:-

    • to provide the course of study;

    • administer the course of study;

    • ensure the quality of the programmes;

    • to provide support to Teachers;

    • to respond to enquiries about the study offered;

    • to seek feedback about study experiences;

    • to address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;

    • to record and/or report upon the progress of the student;

    • to record and communicate other issues which may be impacting upon the progress of the student;

    • to notify of changes to the Centre, for example a change in Teacher;

    • providing continuity in the Study Centre, for example in the event of the Teacher no longer being available for one reason or another and whether on a temporary or permanent basis;

    • to respond to complaints.

  • To ensure vital interests:-

This relates to the health and safety of a student. For example, if there was a medical emergency RCS Haven may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.

  • To comply with Legal Duties

RCS Haven may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

  • When legitimate interests apply

This falls into two broad categories:-

  1. Work undertaken in refining and improving the effectiveness of the study programme and improving the student experience; and

  1. Communicating news including news in relation to RCS Haven’s operation, study and franchise opportunities.

The first category includes:-

    • Research and development purposes;

    • Market research for establishing new educational programs

    • Training of new and experienced Teachers and employees;

    • Performance analysis;

    • Support for students who wish to transfer between Centres.

Any processing of personal information under this category will be of the nature referred to above. RCS Haven will not process personal information under this category where there is any perceived detriment to you or your children in undertaking the processing.

RCS haven may need to process some personal information of this nature for measurement and statistical purposes as referred to under the ‘Other’ heading but if you do not wish RCS Haven to process personal information for the above purposes please contact RCS Haven using the contact details set out in the contact lists.

The second category:-

It is possible that from time to time RCS Haven may wish to communicate with parents concerning matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:-

  • To inform parents of potential career opportunities with the Teacher;

  • Providing news updates about developments at RCS Haven;

  • To communicate about particular study opportunities and useful information about RCS Haven study, for example particular trials, promotions and campaigns;

  • In relation to franchise or other career opportunities;

  • Provision of information and consultation in relation to Study Centres which may be of relevance to your child or children.

Any communication under this category will be of the nature referred to above. RCS Haven will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.

If you do not wish RCS Haven to process personal information for the above purposes please contact RCS Haven using the contact details set out in the contact list/

  • When you consent

There are certain uses to which RCS Haven will not put personal information without your specific consent. Where such consent is requested it will be sought separately. It is likely to be in areas such as in photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies and using your children in case studies for training purposes.

If consent is given it can be withdrawn at any time by providing notification to RCS Haven in writing or by email.

  • Other

We may also use personal information for measurement and statistical purposes.

  1. What happens if I don’t wish to provide personal information to the Teacher and RCS Haven?

The Teacher and RCS Haven require the personal information set out in this privacy notice in order to ensure that RCS Haven programme can be safely and effectively delivered to your children and continually developed and improved for the benefit of your children. Without this information it will not be possible to deliver the services for the benefit of your children or at least not as well as we would like. We have though set out above some purposes for which either the Teacher or RCS Haven wish
to use personal information under the heading of “Legitimate interests”. If you do have an objection to any personal information being used under this heading you may object to either the Teacher, RCS Haven or both. If either the Teacher or RCS Haven wish to gather personal information for which consent is required they will obtain that specific consent before gathering that information and you have the right not to provide such information.

  1. How long will you keep personal information for?

The Teacher and RCS Haven will only retain personal information:-

  • For as long as necessary to fulfil the purposes it was collected for as set out in this Privacy Notice;

  • In relation to those that enquire about the services which we can provide we would not normally keep that information for longer than 12 months after the last communication from the enquirer;

  • Whilst your children are studying at RCS Haven it is necessary for us to retain the personal information. Thereafter we will not normally keep it for longer than 24 months after your children have ceased to attend RCS Haven unless we have legitimate reasons, including child protection reasons for doing otherwise;

  • In some circumstances you have the right to request erasure of personal information held. This will be addressed below.

  1. Your rights in relation to the information held in relation to you or your children

  • Access - the right to make what is known as a Subject Access Request to either a copy of the personal information which we hold about you or your children. If you make such a request we are required, in most circumstances, to provide a copy of the personal information without charge and within 30 days. You may also seek confirmation of the personal information that either the Teacher or RCS Haven hold about either you or your children.

  • Correction it is important that you keep the Teacher up to date with any changes to the personal information provided. Subject to that you have the right to ask the Teacher or RCS Haven, as appropriate, to correct or complete any inaccurate or incomplete data held about you or your children. It is possible that evidence will be required of the new information provided.

  • Erasure – you are entitled to ask either the Teacher or RCS Haven to delete or remove personal information held where there is no good reason for the Teacher or RCS Haven to continue to hold it. It may not always be possible to comply with your request due to ongoing obligations in relation to the personal information. However, where this is the case you will be informed and be told of the reasons why it is not possible to comply with the request.

  • Object to processing – you may object to either the Teacher or RCS Haven processing personal information. There are some circumstances in which it will not be possible to comply with your request, for example if it is necessary to process the information in connection with obligations which the Teacher or RCS Haven (as appropriate) have and which have been explained to you in this document. If you object to either the Teacher or RCS Haven processing information which has been processed under the legitimate interest head, we will stop processing it.

  • Restriction of processing – you may ask the Teacher or RCS Haven to suspend processing of personal information in the following situations:-

    • If you want the data accuracy to be established;

    • Where the use of the personal information is unlawful but you do not want it to be erased;

    • You need the data to be held even though the Teacher or RCS Haven (as appropriate) no longer require it as you need it to establish, exercise, or defend legal claims; or

    • You have objected to the use of the data by the Teacher or RCS Haven but the Teacher or RCS Haven (as appropriate) need time to determine whether they have overriding legitimate grounds to process it.

  • Request the transfer of information – sometimes rights apply to request a transfer of personal information held to other organisations. This right only applies to personal information that is processed by automated means and is held because it was necessary for the performance of the contract with you or personal information which is processed based on consent.

  1. Keeping personal information safe

The Teacher and RCS Haven have put in place appropriate security measures to prevent the personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal information is limited to those employees and contractors who have a business need to know the personal information and will only be processed upon instructions from either the Teacher or RCS Haven (as appropriate) and procedures had been put in place to deal with any suspected breach of the requirements under the GDPRs and you and/or the Regulator referred to below will be notified of any potentially significant breach.

  1. What happens if you want to complain?

It is hoped that you will not have cause to complain. If you do complaints relating to the Teacher should be referred to the Teacher where possible and any complaints in relation to RCS Haven should be referred to the person named in the Schedule where possible. If it is not possible or appropriate to refer a complaint to the Teacher or RCS Haven it may be referred to the Regulator.



  1. Miscellaneous

    • It is not anticipated that any personal information will be transferred outside of the European Union save where specifically set out in this Notice. We will notify you if this position changes.

  • Neither the Teacher nor RCS Haven anticipate using automated decision making in relation to the personal information provided.

  • This Privacy Notice may be updated from time to time. The latest Privacy Notice will be displayed on Teacher and RCS Haven websites.

  1. If I have any questions who do I ask?

Please ask your Teacher or contact RCS Haven using the details in the contact list/

Dated 16th May 2018



Schedule

Contact information


Head of RCS Haven school

Mrs Elena Sedounov

[email protected]

0141 55 22 144


Chair person RCS Haven:

Mr Roman Moroz

[email protected]

0141 55 22 144