Data Protection Policy
Whether you are a student or parent; whether you work with us or for us, we are committed to keeping your data safe and respecting your privacy. On this page you will find privacy notices that show what data we process about you, why we process that data and what the legal bases are for processing that data.
Privacy notice for Students, Parents and Guardians
This privacy notice explains how Kennedy College collect, store and use personal data about students. Kennedy College is the data controller, and for the purposes of data protection law.
The table below shows the data that we process about students, the reasons for processing this data and the lawful bases for processing this data. Cells marked with an asterisk (*) indicate that parent or guardian data may also be processed in the same way, where a student requires parental consent.
| The data or type of data we process | The purpose of processing that data | The lawful bases for processing this data |
|---|---|---|
| Your name, date of birth, gender, addresses, email addresses and phone numbers. Your relationship to the student.* | To identify you to communicate with you | Fulfilment of a contract with you |
| For marketing purposes | Where you have given us consent | |
| Your nationality, ethnic background, any special educational needs, special requirements or disabilities | To provide appropriate information and assistance for you |
|
| Next of kin and emergency contact numbers | To contact your family or close friends in the event of an emergency | To protect your vital interests |
| Your passport, BRP and visa details | To meet government immigration regulations | Compliance with a legal obligation |
| Bank account details* | To manage payments and refunds | Fulfilment of a contract with you |
| Your educational records and test or exam results from previous schools | To offer you the most appropriate courses | Fulfilment of a contract with you |
| Your medical information, including medications you take, allergies and dietary requirements | To help you manage your health while you are with us |
|
| Your educational records and test or exam results from Kennedy College | To manage your progress while studying with us | Fulfilment of a contract with you |
| Your attendance records and booking in/out records for school and residence | To meet government immigration and safeguarding regulations |
|
| Details of any behaviour issues or exclusions | To manage discipline in the schools | Necessary for our legitimate interests (to manage school discipline) |
| Images | For maintaining security | Necessary for our legitimate interest (for keeping our students and staff safe) |
| For marketing our services |
|
Where we have obtained consent to use student data, this consent may be withdrawn at any time. We will make this clear when we ask for consent and explain how consent can be withdrawn.
When do we share Student, Parent or Guardian data?
When it is legally necessary, or allowed under data protection law, we may need to share information about you with the organisations listed in the table below, for the listed reasons.
| Organisation Name | The Reason for Sharing |
|---|---|
| The Department for Education | To provide data on international students |
| The Local Education Authority | To provide data on international students |
| Regulatory bodies, such as Ofsted or the British Council | To comply with regulatory inspections |
| Service providers | For running surveys, providing taxi or excursion services, providing security services |
| Financial organisations* | For processing payments |
| Our auditors | For carrying out legal audits of company accounts |
| Health and social welfare organisations | To manage student wellbeing |
| Professional advisers and consultants | To assist us in developing our business |
| Police forces, courts, tribunals* | For dealing with legal issues |
| Your family and representatives | To share details of your academic progress or to tell them about attendance or behaviour issues or for debt collection |
| Exam Boards | To enter you for exams |
| UCAS | To enable you to apply to universities in the UK |
| Marketing services, such as those offered by Facebook | To identify other students who may be interested in studying with KCO. No decisions will be taken about you based on this profiling. |
Transferring Student, Parent and Guardian data internationally
Your personal information may be stored and processed outside of the country where it is collected, including outside of the European Economic Area.
We will only transfer personal data to a country or territory outside the European Economic Area:
- where the transfer is to a place that is regarded by the European Commission as providing adequate protection for your Personal Information; or
- where we have put in place appropriate safeguards to ensure that your Personal Information is protected (for example where both parties involved in the transfer have signed standard data protection clauses adopted by the European Commission);or
- the above does not apply but we are still legally permitted to do so, for example if the transfer is necessary for the establishment, exercise or defence of legal claims.
You can request further detail about the safeguards that we have in place in respect of transfers of Personal Information outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place.
Storing Student, Parent and Guardian data
We will keep personal information about you while you are an active student. We create and maintain records for each individual student. The information contained in these records is kept secure and is only used for purposes directly relevant to your position as a student with Kennedy College. Once your time as a student with us has ended, we will retain these records and delete them in accordance with our Data Retention Policy.
Where we have obtained consent to use agent data, this consent can be withdrawn at any time. We will make this clear when we ask for consent and explain how consent can be withdrawn.
WHEN DO WE SHARE WEBSITE USER DATA
| Organisation Name | The Reason for Sharing |
|---|---|
| With Third Party Companies and Individuals, service providers who facilitate our website, host the website on our behalf and who assist us in analysing how our website is used. | To improve our website and the services provided for you |
| The Local Education Authority | To provide data on international students |
| Regulatory bodies, such as Ofsted or the British Council | To comply with regulatory inspections |
| Professional advisers and consultants | To assist us in developing our business |
| Police forces, courts, tribunals* | For dealing with legal issues |
| Marketing services, such as those offered by Facebook | To identify other students who may be interested in studying with KCO. No decisions will be taken about you based on this profiling |
Cookies
Where you use our websites, we will process your Personal Information collected by using cookies in accordance with our Cookie Notice.
SECURITY
Our websites are hosted on servers in the EEA. We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a locked and certified information centre and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our Websites.
STORING WEBSITE USER DATA
Please refer to our cookie policy for further information about how long cookie data is stored. Non anonymised website data is kept for 5 days. If you have made an enquiry with us via a form or have completed an application form via the website please also read the student/parent/guardian privacy policy or the agent/employee privacy policy.
Links to other sites
Our site contains links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to our Privacy Policy
We may update our Privacy Policy from time to time and we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page which will become effective immediately.
Your rights
Under certain circumstances, you may have certain rights regarding how your personal data is used and kept safe, including the right to:
- Right of Access: You have the right to a copy of the information we hold about you.
- Right to Object: You may object to the use of personal data if it would cause, or is causing, damage or distress. You have the right to object to any decisions taken using automated processes. You also you have the right to object to certain types of processing such as direct marketing.
- Right to be Forgotten: Under certain circumstances, you can ask for the data we hold about you to be deleted from our systems.
- Right to Rectification: If data we hold about you is inaccurate or incomplete, you have the right to correct or complete that data.
- Right to Restriction of Processing: Where certain conditions apply you have a right to restrict the processing of data.
- Right of Portability: You have the right to have the data we hold about you transferred to another organisation.
Some of these rights may not apply where we are legally obliged to keep or share your personal data. If you wish to exercise any of these rights, please contact our Data Protection Officer (see below).
Complaints
We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
Alternatively, you can make a complaint to the Information Commissioner's Office in the UK via the options listed below, although we would be grateful for the opportunity to address your concerns before you contact the ICO.
How to contact the ICO:- Report a concern online at https://ico.org.uk/make-a-complaint/
- Call +44 303 123 1113
- Or write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK