PRIVACY NOTICE FOR PUPILS
Cognita Tutoring is part of Cognita. Cognita is responsible for how we look after your personal information. When we say “we” in this notice, this means Cognita Tutoring and Cognita. We are required by law to look after the information we hold about you; this notice tells you how we do this.
Personal information is any information which is about you, from which you can be identified.
Please make sure you read this privacy notice carefully. This notice is a short form version of the full notice for parents. If you would like more information, please speak to your tutor, you can also look at the privacy notice for your parents. This is available on our website.
WHAT PERSONAL INFORMATION MIGHT THE SCHOOL HOLD ABOUT YOU?
· Your full name, date of birth and grade;
· Your home address, home telephone number and mobile number;
· Your photograph or recordings of sessions;
· Your academic records and test results; and
· Your medical records (including special education needs).
Information we receive FROM, AND SHARE WITH, other PEOPLE OR COMPANIES
We will share your information with your parents.
We may work with other institutions such as local authorities, social services, police (where there are concerns with your safety, business partners and professional advisors. We might receive or share information about you from them or give information to them. We will only do so as set out in this notice.
CONTACT US IF YOU HAVE FURTHER QUESTIONS
If you have any questions about this notice then please speak to your tutor. Our Data Protection Officer has overall responsibility for your information: DPO@Cognita.com.
HOW WE USE YOUR information
We will use the information you and your parents give us as is necessary to provide you with the information and services that your parents request from us (to look after you, tutor you and to deal with any queries they may have).
We also use your information to promote the objects and interest of our company, ensuring the most efficient management of the company and ensuring that the company’s legal obligations are adhered to. These are known as “legitimate interests”.
Help from third parties. We rely on software applications and other technology provided by other people to handle your information. These include virtual learning environments (including the setting of tasks and homework), revision tools, email messaging communications, assessments of your progress. The companies we use to deliver these applications are carefully chosen by us to ensure that your information is kept secure. Some of our key systems include Confirmit, Century Tech, Squid, Netsuite and Microsoft Teams. For further information on the kind of technology we use, please speak to your tutor.
When we hold details about your health and wellbeing, this information is called “sensitive personal data” which means we treat this information even more carefully. We will need to hold sensitive personal data about you (a) for carrying out our obligations in the field of social security or social protection law, (b) to protect your vital interests. To achieve this, we may also use software applications and other technology.
WHERE WE NEED YOUR CONSENT
We will seek your or your parent’s permission (and your permission, if you are 12 or older) if we would like to post any photographs of you on any of our marketing materials (including our website); you and your parents may withdraw your permission should you wish.
TRANSfer OF PERSONAL INFORMATION OUTSIDE THE COUNTRY
Sometimes your information will need to be sent to, and stored outside the UK. We try to limit this, but it may be necessary where, e.g. one of our suppliers stores your information outside of the UK. We take all steps reasonably and legally necessary to ensure that your information is safe.
· Right to request access to your personal information (a "subject access request" or “SAR”).
· Right to request correction of the personal information that we hold about you.
· Right to request deletion of your personal information.
· Right to object to processing of your personal information.
· Right to request the restriction of processing of your personal information.
· Right to request the transfer of your personal information to another organisation.
· Right to complain to the Information Commissioners Office about what we are doing with your information: https://ico.org.uk/concerns/.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will not keep any personal information about you for any longer than is necessary. We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information, please speak to your tutor.
CHANGES TO THIS PRIVACY Notice
We may change this notice, we will let you know if we do.
PRIVACY NOTICE FOR PARENTS
1.1 We are committed to protecting and respecting your and your child’s privacy. Cognita is a group of independent schools and includes Cognita Tutoring. In this privacy notice, references to “we”, “us”, “our”, or “Cognita” is a reference to Cognita Schools Limited.
1.3 Please read the following carefully to understand our views and practices regarding your and your child’s personal data and how we will treat it.
1.4 We comply with all applicable data protection laws and regulations (“Data Protection Legislation”), which may include the General Data Protection Regulation 2016/679 and the Data Protection Act 2018. The Data Protection Legislation continues to change in the UK, following the UK’s exit from the European Union and we continue to update our practices in light of these changes. For the purposes of the Data Protection Legislation, we are the data controller and our office is at 41-42 Eastcastle Street, London, W1W 8DU, United Kingdom. Our ICO registration number is Z9688459.
1.5 If you are reading this privacy notice online, we recommend that you print and retain a copy for future reference.
2 INFORMATION WE COLLECT ABOUT YOU AND YOUR CHILD
Information you give us
2.1 You may give us personal data about you or your child, in a number of ways; these include:
2.1.1 using, visiting or interacting with our website and platform;
2.1.2 signing up to a Cognita Tutoring account;
2.1.3 corresponding with us by phone, e-mail or post; and
2.1.4 sending information directly to us, for example when booking sessions, completing an enquiry form or our Student Insight survey or providing information as requested by us and/or which is necessary from time to time.
A. Personal Data
2.2.1 full name;
2.2.2 date of birth and year group;
2.2.3 contact details (including home address, e-mail address, and mobile, home and/or work phone number);
2.2.4 parent login information (i.e. username and password) for the website;
2.2.5 financial and credit card information;
B. Sensitive Personal Data
2.2.7 health records (including special education needs, medical or physical conditions and/or accidents);
2.2.8 (where appropriate) family circumstances (including your relation to the child and your marital status); and
Technical information we collect about you when you visit our website
2.3 With regard to each of your visits to our website we may automatically collect the following information:
2.3.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.3.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
2.4 Our website may contain links to and from the websites of our partner networks, advertisers,suppliers and affiliates. If you follow a link to any of these websites,please note that these websites have their own privacy policies and that we donot accept any responsibility or liability for these policies. Pleasecheck these policies before you submit any personal data to these websites.
Information we receive from othersources
2.5 We may be working closely with third parties (including, for example, suppliers and payment anddelivery services) and may receive information about you from them.
Information you give to us
3.1.2 to protect the welfare of your child, and ensure that our legal obligations are adhered to;
3.1.4 to manage any queries or disputes you or your child may have with us or that we have with youor your child;
3.1.5 to enforce our termsand conditions with you or any other contract we may have with you;
3.1.7 to comply with government and regulatory guidance.
3.2 In order to pursue the legitimate interests referred to in paragraphs 3.1.1, 3.1.3 and 3.1.6, We also rely on software applications and other technology to process personal data about you and your children. These include our management information system, virtual learning environments (including the setting of tasks and homework), revision tools, email messaging communications, assessments of pupils’ progress and our group-wide billing system. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your and your child’s personal data is kept secure. Some of our key systems include Confirmit, Century Tech, Squid, Netsuite and Microsoft Teams. For further information on the kind of technology we use, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 9).
3.3 We will also use the information you give to us as is necessary to carry out our obligations arising from the terms and conditions between you and us and to provide you with the information and services that you request from us. For example, we will provide tutoring services to your child and will use personal data where necessary to deliver these services. We will also use your personal information to charge you for our services pursuant to the terms and conditions between you and us. We will also require a certain amount of personal information about you and your child at the pre-booking stage.
3.4 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to distinguish these as set out above. If you have any questions about these please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 9).
3.5 When we hold sensitive personal data (see paragraph 2.2B), this means we must adopt higher standards of care to make sure this kind of data is safe and doesn’t fall into the wrong hands. We may process sensitive personal data in the following circumstances:
3.5.1 in limited circumstances, with your explicit written consent;
3.5.2 where we need to carry out our legal obligations;
3.5.3 where it is needed in the public interest;
3.5.4 for safeguarding;
3.5.5 about your child’s physical or mental health, or disability status, to provide appropriate adjustments; and
Information we collect about you from our website
3.6 We will use this information for the following legitimate interests:
3.6.1 to contact you if you have made a booking enquiry;
3.6.2 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.6.3 to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer;
3.6.4 to allow you and your child to participate in interactive features of our service, for example virtual learning environments; and
3.6.5 as part of our efforts to keep our website and platform safe and secure.
Information we receive from other sources
3.7 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive).
When we disclose information
3.8 In order to pursue one of the legitimate interests set out above, we may share your and your child’s personal information with:
3.8.1 Cognita Tutoring Support Centre in the UK;
3.8.2 a member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
3.8.3 local authorities, social services or the police where we have reason to believe there are safeguarding concerns in respect of your child; and
3.8.4 business partners, professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
3.9 We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we need to get your consent
3.10 We will not market services to you without your consent and you have the right to ask us not to use your contact details for marketing.
Where you have given consent to the above, you can withdraw marketing consent at any time by unsubscribing here, , or by contacting the Data Protection Coordinator (see paragraph 9).
4 TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE UK OR THE EEA
4.1 The data that we process about you and your child may be transferred to, and stored at, a destination outside the UK or 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 UK or 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 standard data protection clauses, or the country we are transferring the data to is deemed by the UK Government as adequate.
5 YOUR RIGHTS
5.1 Under the Data Protection Legislation, you and your child have the following rights:
5.1.1 Right to correction. You have the right to have inaccurate personal data about you or your child rectified.
5.1.2 The right to erasure. You have the right to request that we delete your and your child’s personal d ta where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 5.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.
5.1.3 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 5.1.5 for more details).
5.1.4 Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organisation.
5.1.5 Right to object. You have the right to raise an objection to any of our processing in paragraphs 3.1 and 3.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
5.1.6 Right to object to marketing. If you do not want us to process your personal data for direct marketing, please tell us and we will ensure that we no longer do this.
5.1.7 Right to complain to the ICO. Whilst we would always prefer it if you approached us first about any complaints or queries you may have; you always have the right to lodge a complaint with the Information Commissioner’s Office.
5.1.8 Right to request access. You have the right to access personal data we hold about you. We encourage you to contact the Data Protection Officer and request our standard SAR form for you to complete in order to help us process your request.
6 HOW LONG WE KEEP PERSONAL INFORMATION
6.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed.
6.2 We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer or Data Protection Co-ordinator (see paragraph 9).
8 USE OF OUR WEBSITE
8.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at DPO@Cognita.com or 3rd Floor, 41-42 Eastcastle Street, London, W1W 8DY.
10 Changes to our privacy NOTICE
10.1 Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Dated 21th May 2021