Data Protection Policy for Parents
The Tutoring Barcelona Academy is committed to respecting and protecting the privacy of both our students and their families. This policy outlines how any personal data collected by our center will be used and handled.
For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”), we are the data controller and our address is Tutoring Barcelona, Diagonal 646bis, Barcelona 08017. If you wish to retain this policy for future reference, please save and print a copy.
Information we Collect on you and your Family
Information that we receive from you:
You may give us personal data about you or your family, in multiple ways, including:
- using, visiting or interacting with our website (such as filling out forms or registering
on our website);
- visiting our learning centre;
- Contacting us via phone, email or post; and
- Directly sending us personal information. This might include when you pay school
fees, medical or health records, completing enrollment or center administration forms
or when we request necessary information from you
The information you provide us with concerning your child and/orr your family:
- Full name of your child/children and their parents and/or guardians;
- Date of birth of the child/children;
- Education records, such as the previous schools attended by the child/children;
- Contact details of members of your family (email addresses, home
address/es, mobile, work phone);
- Financial land credit card information;
- Photo identification of the child/children and the parents and/or guardians;
- Passport details, nationality and other information relating to immigration status of
the parents and the child/children;
- Health records of the child/children;
- Necessary information for the centre to be aware of regarding family circumstances
- Race, religion and ethnicity (should you chose to share this information)
InfInformation we receive from other sources:
Where appropriate, we may be working closely with third parties (for example, previous schools attended by the child/children, health professionals, photographers, local authorities, education authorities, business partner, lawyers, debt collectors and credit reference agencies) and may receive information about you from them.
Comments and concerns regarding this policy notice, should be directed to firstname.lastname@example.org
A Data Protection Coordinator has been appointed who will oversee all data protection matters.
Uses Made of the Information
Information that we receive from you:
The information you provide to us will be used for the following
We will use the information you give to us to pursue the following lawful interests:
- to promote the objects and interest of our centre, and ensure the most efficient management of our programmes;
- to store this information on the centre’s chosen management information system;
- to use your child’s photograph as part of a manual ID system on the school management information system;
- to contract with other companies and organisations for the purposes of fraud protection and credit risk reduction;
- To provide you with information related to other programmes that we offer within the centre, for example after school tuition, A Level Programme and holiday camps.
- If your child unenrolls temporarily from any of our programmes or leaves the centre, to keep you up to date with news in our centre and upcoming events (you can choose to opt out of emails at any point); and
- Send out parents email surveys or campaigns
We require a certain amount of personal information from families at the time of enrollment. We use this information to carry out necessary obligations arising from the contract between our center and your family. In the education services we provide to your family, we use personal data where needed to deliver these services.
In addition, we may be required by corresponding applicable law to do the following (which is not an exhaustive list):
- keep an admissions and attendance register;
- keep student files (including, where relevant, special education needs and child
- keep a behaviour record detailing any incidences
- Provide written reports on student progress and attainment
Information we collect about you from our website:
The information we collect about you from our website is lawfully used:
- To make initial contact with you, either by phone or email;
- to inform you about enrollment processes;
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you and your child to participate in interactive features of our service, for example virtual learning environments, when you opt in; and
- as part of our efforts to keep our website safe and secure for all users.
Information we receive from other sources:
It may be necessary for us to combine this information with the information we collect about your chill and your family.
Also, social services or health practitioners may provide us with information (particularly sensitive personal data) about your child which may need to be added to the school’s child protection or special educational needs file. This kind of processing of sensitive personal data may be necessary (a) for the purposes of carrying out our obligations in the field of social security or social protection law, (b) for medical diagnosis or provision of health care and/or (c) to protect the vital interests of your child or another person taking into account the
mental and physical capacity of your child.
Our centre may do the following:
- Keep a list of allergy and/or medical requirements so that it can be easily accessed
by staff to keep our students safe;
- Rely on software applications and other technology to store and process information (including information related to medical conditions, allergies and accidents/ injuries within the center).
Disclosure of Personal Information
We may share your and your child’s personal information with:
- Local authorities, education authorities (for example, Ministry of Education or SEN co-ordinators, social services or the police where we have reason to believe there are safeguarding concerns in respect of your child;
- Exam boards (Pearson Edexcel);
- Immigatiion authorities, if requested and where appropriate;
- Financial agencies, such as debt collectors orr professional advisors
If we are legally obligated to disclose personal information to third parties, we may need to share your personal information.
When your Consent is required
- We will ask you for permission to use your child/childrens photos and/or appearance in videos for centre marketing purposes. Consent is based on age/maturity: if a child is under 14 years of age, or doesn’t demonstrate a sufficient degree of maturity, the centre will require parent permission. Where a pupil is over 14 years of age and demonstrates a sufficient degree of maturity, the centre requires constant exclusively from the student, rather than the family.
- It is up to the family and the child/children if they wish to disclose information related to race, religion and ethnicity.
Sensitive Personal Data
Sensitive data pertains to the collection of data that includes information related to health and medical conditions, race, religion or ethnicity or anything else that needs to be protected on a higher level. We require your permission to collect and store this information.
It is our obligation to ensure that this information is protection and safe from unnecessary viewing. This information is necessary in order to a) for carrying out our obligations in the field of social security or social protection law b) health and medical reasons c) to protect the vital interests of the child d) dietary requirements e) providing certain facilities such as prayer rooms f) excusing children from certain activities/classes during, for example, certain
Transmission of Personal Information Outside the EEA
The data that we process about you and your child may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary where, for example, one of our suppliers, has a data centre outside the EEA. We will take all steps reasonably necessary to ensure that your and your child’s data is treated securely and in accordance with this privacy notice and that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or the country we are transferring the data to is deemed by the EU Commission a country with adequate protection.
Under the GDPR, you and your child have the following rights:
- Right to correction. Once notified, our centre will ensure inaccurate personal data about you or your child is amended.
- The right to be forgotten. You have the right to request that we delete yours and your child’s personal data where: the data is no longer necessary for the purpose in which it was collected, you withdraw you consent where it was otherwise provided, the personal data has been unlawfully used or we are required by law to delete the data.
- Right to restriction. You have the right to obtain from us the restriction of processingwhere: (a) you disagree with the legitimacy of the personal data we hold about you; (b) the personal data has been used illegally or unethically; (c) we no longer require the personal data and are not legally bound to keep it (d) you object to the processing and we agree to delete the data.
- Right to object. You have the right to raise an objection to how we process our personal data. Please email the Data Protection Coordinator to address your concerns.
- Right to object to marketing. Please email info@tutoringbarcelona to communicate our right to not receive marketing material.
- Right to complain to relevant authorities. In the case that we are unable to solve your grievances to a satisfactory level, or if you choose to go directly to relevant authorities, you can contact the AEPD (Spanish Agency for Data Protection).
- Right to request access. You have the right to access personal data we hold about you. Please contact the Data Protection Coordinator at the centre.
How Long we Store and Keep Personal Information
- We keep personal data on students and their families for the time that they remain at the centre and for six years thereafter. At this point, files will be deleted.
- We only keep personal information that is necessary and for the time period in which we are required to do so. The type of data determines how long we are required to keep the information.
Changes to this policy will be made via our website and, where appropriate, our community
will be notified via email.
Completed by: Hannah Grech
Date Completed: September 2020
Date for Review: September 2021