Privacy Notice
Purpose of this privacy notice
This privacy notice aims to give you clear and detailed information about:
- how we collect and process your personal data
- the legal grounds allowing us to do so
- how we look after your personal data
- your privacy rights
- how the law protects you.
Controller
Under data protection law the controller of your personal data decides how and why your personal data will be processed and takes responsibility for looking after your personal data. The controller of your personal data will be one or more of the CGS entities.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
Full name of legal entity: Bright Scholar (UK) Holdings Limited, trading as CATS Global Schools
Name or title of DPO: Data Protection Officer – Laura McDowell
Email address: DPO@catsglobalschools.com
Postal address: Suites 6-7 The Turvill Building, Old Swiss, 149 Cherry Hinton Road, Cambridge, CB1 7BX, UK
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
When we issue a new version of this privacy notice we will post a message on our websites advising of this.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. The websites of any of our subsidiary businesses are subject to this privacy policy.
Important information and who we are
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
Internal Third Parties
CGS companies acting as joint controllers or processors and who are based in the UK, the US, Canada and China and provide (i) application and admissions services, (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services.
External Third Parties
- Educational agents
- Parents or parental approved representatives
- The Chancery Partnership
- UK Visas and Immigration (UKVI)
- US Immigration and Customs Authorities
- Immigration Refugees and Citizenship Canada
- Government and Corporate Financial Sponsors and Embassies
- Taxi companies
- Accommodation providers
- Other university destinations
- Student insurance provider
- Approved test centres
- Exam boards
- Validating bodies for exam boards
- Medical or Public Health authorities (and where an emergency situation to any other organisations/individuals deemed necessary as assessed at the time)
- Providers of activities for students
- The British Council
- Local authorities
- Higher Education Statistics Agency (HESA)
A copy of the HESA Student Collection Notice can be accessed here. Updated versions can be found here.
- Independent Schools Inspectorate (ISI)
CGS is subject to review by ISI which is an independent, government-approved body which provides objective inspections to safeguard the quality and effectiveness of the education, care and welfare of children in schools. ISI is not an arm of the government, but an independent, not-for-profit inspectorate. ISI’s work is monitored on behalf of the Department for Education (DfE) and a public report is made annually to the Secretary of State. https://www.isi.net/about/what-we-do
- Office for Students (OfS)
The Office for Students is an official body that appoints designated quality bodies to enact educational oversight on its behalf. For more information see here.
- Quality Assurance Agency for Higher Education (QAA)
The OfS appoints QAA as a designated quality body. We are subject to review by QAA in respect of CSVPA for student loan purposes. See here for more information.
- Local councils
- Transport for London
- HM Revenue & Customs, regulators and other authorities acting as processors
- Service providers worldwide acting as processors
- Cloud-hosted VLE providers
- Professional advisers worldwide acting as processors or joint controllers.
- Local authorities
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, curriculum vitae (CV), covering letter, academic record, employment history and references and images captured by CCTV.
- Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data).
- Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
- Contact Data includes your home address, email address and telephone numbers, next of kin and emergency contact information.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when accessing our website www.catscolleges.com or any of the websites of our subsidiaries accessed from that website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our websites and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose. Where Aggregated Data can directly or indirectly identify you we will use it in accordance with this Privacy Notice.
If you do not provide us with personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with education services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data by filling in application forms, by sending us your CV, covering letter, teaching video submissions or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- create an account on our website;
- request marketing information is sent to you;
- apply for one of our courses;
- apply for a job;
- complete a survey; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as those set out below:
- Educational agents – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Parents or parental approved representatives – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Universities – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Named Referees – Identity Data and Contact Data
- Recruitment agencies – Identity Data and Contact Data
- Disclosure and Barring Service – Criminal Conviction Data
- Providers of technical, payment and delivery services – Contact, Financial and Transaction Data.
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.
Our legal basis for using your personal data
- Check if the course is right for your age and level of learning
- Get in touch with you and your parent(s) or guardian(s) when we need to
- Check how you’re doing in exams and work out whether you need any extra help
- Track how well the school as a whole is performing
- Look after your wellbeing
- Improve the experience you receive
- Check if you are allergic to any foods or cannot eat certain foods due to your religious beliefs
- Help manage your accommodation or travel needs
- Improve the quality of education you receive
- Consult with you about different ideas and aspects of the education you receive
- Identify where an external agency might be needed to help support you
How we use your personal data
How we use your personal data
5.a PROSPECTIVE STUDENTS AND AGENTS
| Purpose/Activity | Type of Data | Legal Basis |
|---|---|---|
| To register you on our website and subscribe to our services | Identity | Contract |
| Contact | ||
| Marketing and Communications Data | Consent | |
| To process your application form and correspond with you including: | Identity | Contract |
| (i) Arranging visas | Contact | |
| (ii) Processing deposits and course fees | Financial | |
| (iii) Verifying exam and test results | Criminal Conviction | C ontractand Employment criminal convictions data) |
| Special Category | Explicit Consent (special category data) | |
| To assess students’ eligibility for scholarship or bursary | Contact | Contract |
| Identity | ||
| Financial |
5.b ACCOMMODATION PROVIDERS (INCLUDING HOMESTAY PROVIDERS)
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To process your application to become an approved accommodation provider (includes compulsory DBS check/background check in North America) | Identity | Contract |
| Contact | ||
| Financial | ||
| Transaction | ||
| Criminal Conviction | Legal Obligation |
5.bi PROVISION OF PERSONAL DATA TO THIRD PARTIES
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To educational agents where the agent has submitted an application on behalf of a prospective student | Identity | Contract |
| Contact | ||
| Financial | ||
| Criminal Conviction | Contract and Consent (criminal convictions data) | |
| Special Category | Explicit Consent (special category data) | |
| To parents/parental approved representatives where the parents or representatives have submitted an application on behalf of a prospective student who is under 18. | Identity | Contract |
| Contact | ||
| Financial | ||
| Criminal Conviction | ||
| Special Category | Explicit Consent (special category data) | |
| To third party online conversion service where an applicant has started the application process but does not complete it. | Identity | Legitimate interests (the company has a business interest in securing applications for its courses) |
| Contact | ||
| To Chancery Solutions Limited to process an application for a Tier 4 visa | Identity | Consent (provided by applicant to the company at the time of referral to Chancery) |
| Financial | ||
| Financial | ||
| Transaction | ||
| To UK Visas and Immigration (UKVI) to facilitate the application for a Tier 4 visa | Identity | Legal obligation |
| Contact | ||
| To US Immigration and Customs Enforcement | Identity | Legal obligation |
| Contact | ||
| To financial or government sponsors of a course | Identity | Legal obligation |
| Contact | ||
| Special Category | Explicit Consent (special category data) |
5.c ENROLLED STUDENTS
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To register you for our services as an enrolled student | Identity | Contract |
| Contact | ||
| Financial | ||
| Transaction | ||
| Special Category | Consent | |
| To provide you with ongoing services after enrolment including: | Identity | Contract |
| (i) provision of core teaching and learning services | Contact | |
| (ii) administration including maintaining student records, processing fees, managing accommodation | Financial | |
| (iii) providing services including library, IT and information services and other student support services (excluding welfare and medical) | ||
| To provide you with ongoing services after enrolment in respect of student welfare and medical services | Identity | Contract |
| Special Category | Explicit Consent (special category data) | |
| To provide you with reports on your progress | Identity | Contract |
| Contact | ||
| To provide you with information on progression to degree courses (where applicable) | Identity | Legitimate interests (It is in the interests of the student for the company to provide this information and has a business benefit with regard to promotion and marketing of its courses) |
| Contact | ||
| To process student complaints and grievances | Identity | Legitimate interests (It is in the interest of both parties for us to investigate and attempt to resolve complaints and grievances) |
| Contact | ||
| Special Category | Explicit Consent (special category data) | |
| To carry out internal research and statistical analysis | Identity | Legitimate interests (to monitor and evaluate the performance and effectiveness of our courses) |
| To capture images on CCTV used by our educational centres and campuses. | Identity | Legitimate interests (CGS has an organisational requirement to maintain the security of its premises and for the prevention and investigation of crime) |
| To monitor attendance and compliance with attendance regulations and to identify any support needs | Identity | Legal obligation |
| Contact | ||
| To conduct lesson observations using sound and video recording software | Identity | Legitimate interests (It is appropriate for CGS to monitor teaching quality and to share examples of good practice as an internal training resource.) |
| To take photographs and videos of students for marketing purposes (including for use in brochures, on our website and in promotional videos) | Identity | Consent |
| To use examples of students’ work in class for the improvement of teaching and learning practice. | Identity | Legitimate interests (It is appropriate for us to share examples of good practice during lessons. Some items may be named.) |
5.ci PROVISION OF PERSONAL DATA TO THIRD PARTIES (INTERNAL AND EXTERNAL)
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| Internal | ||
| To enable our companies to provide : | Identity | Legitimate interests (The transfer is necessary to enable us to provide our services. All our subsidiaries are subject to this privacy policy and other relevant policies and procedures.) |
| (i) application and admissions services | Contact | |
| (ii) core teaching and learning services | Financial | |
| (iii) student administration services and | Transaction | |
| (iv) student welfare services | Special Category | Explicit Consent (special category data) |
| External | ||
| To provide your parents/parental approved representatives and educational agents with reports on your progress | Identity | Legitimate interests (It is appropriate for us to share this information with these interested parties.) |
| To UK Visas and Immigration (UKVI) | Identity | Legal obligation |
| Contact | ||
| To US Immigration and Customs Enforcement | Identity | Legal obligation |
| Contact | ||
| To financial or government sponsors of a course | Identity | Legal obligation |
| Contact | ||
| Special Category | Explicit Consent (special category data) | |
| To taxi companies who provide transfers from airport to accommodation providers | Identity | Legitimate interests (We have a valid business requirement to outsource this service. The company has contracts with all its approved taxi companies and all employees have current DBS checks) |
| Contact | ||
| Accommodation providers (including Homestay providers) | Identity | Legitimate interests (We have a valid business requirement to outsource this service. The company has contracts with all its approved accommodation providers and all Homestay providers (including others living in the property) have current DBS checks) |
| Contact | ||
| Special Category | Explicit Consent (special category data) | |
| Other university destinations | Identity | Legitimate interests (Where we receive a request to refer a student to a non-partner university due to the student’s particular circumstances. Request will be from student or agent.) |
| Contact | ||
| Financial | ||
| Transaction | ||
| Special Category | Explicit Consent (special category data) | |
| To insurance companies worldwide who provide student insurance policies | Identity | Legitimate interests (The company cannot provide insurance policies itself and therefore needs to recommend a third party provider) |
| Contact | ||
| To approved test centres | Identity | Legitimate interests (We have a business requirement to use the services of test centres) |
| Contact | ||
| To exam boards | Identity | Legitimate interests (We need to share candidate information with the relevant exam boards) |
| Contact | ||
| To validating bodies for exam boards | Identity | Legitimate interests (We need to share candidate information with the validating bodies) |
| Contact | ||
| To a membership organisation to assess eligibility for scholarship or bursary (e.g. Royal Photographic Society) | Identity | Legitimate interests (We need to verify that a student is a current member of any organisation that attracts a scholarship or bursary) |
| To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency where you are incapable of giving consent | Identity | Vital Interests |
| Contact | ||
| Special Category | Vital Interests | |
| To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency and where we are legally obliged to comply with a request for disclosure | Identity | Legal obligation |
| Contact | ||
| Special Category | Legal Obligation & Public Interest (in the area of public health) | |
| To providers of activities for students | Identity | Legitimate interests (The company offers various activities as part of its courses and cannot provide these activities itself) |
| Contact | ||
| Special Category | Explicit Consent (special category data) | |
| To providers of incentive schemes for students | Identity | Legitimate interests (The company offers incentive schemes as part of its courses and cannot provide these schemes itself) |
| Contact | ||
| To accreditation bodies worldwide for inspections in respect of course accreditations | Identity | Legitimate interests (We have a business interest in obtaining British Council accreditation for our Stafford House summer courses) |
| Contact | ||
| Financial | ||
| Transaction | ||
| Special Category | Consent | |
| To provide statistical information to the Higher Education Statistics Agency (HESA) who are the official agency for the collection analysis and dissemination of quantitative information about higher education (HE) in the UK. (CSVPA) | Identity | Legal obligation |
| Special Category | Legal obligation and necessary for statistical purposes | |
| To provide information to the Quality Assurance Agency for Higher Education (QAA) during Higher Education Review (Alternative Providers) inspection visits (UK) | Identity | Legal obligation |
| Contact | If a student provides a confidential student submission to QAA as part of its review, then this will be on the basis of the student providing consent at the time of submission | |
| To provide information to Independent Schools Inspectorate (ISI) during inspection visits (UK) | Identity | Legal obligation |
| Contact | If a student provides a confidential student questionnaire to ISI as part of its review then this will be on the basis of the student providing consent at the time of submission | |
| To provide information to the Office for Students for the purposes of the National Student Survey and Leavers Survey (Office for Students then shares the information with its approved survey agents). Published results do not disclose any personal data (UK). | Identity | Legal obligation |
| Contact | Legal obligation and necessary for statistical purposes | |
| Special Category | ||
| To local councils to enable them to assess council tax obligations (UK). | Identity | Legitimate interests (To enable CGS to notify councils that certain accommodation is exempt from council tax) |
| Contact | ||
| To Transport for London to enable bulk purchase of Oyster cards for students (UK) | Identity | Legitimate interests (To enable us to obtain discounted travel for students studying in London) |
| Contact | ||
| To HM Revenue & Customs for reporting of financial processing activities (UK) | Identity | Legal obligation |
| Contact | ||
| Financial | ||
| Transaction | ||
| To service providers worldwide who provide IT and system administration services (including secure online software for student health records in the US) | Identity | Legitimate interests (We have a business requirement to use third party providers for specialist services) |
| Contact | ||
| Special Category | Explicit Consent (special category data) | |
| To cloud hosted virtual learning environment (VLE) services (e.g. Moodle & Canvas) | Identity | Legitimate interests (We have a business requirement to use VLEs in order to provide some teaching and learning services |
| Contact | ||
| Professional advisors subject to a duty of confidentiality (e.g. lawyers, bankers, insurers, auditors) | Identity | Legitimate interest (We have a business requirement to seek specialist professional advice that cannot be provided internally) |
| Contact | ||
| Financial | ||
| Special Category | Explicit Consent (special category data) | |
| To local authorities regarding a safeguarding concern in relation to Keeping Children Safe in Education or the Prevent Duty (UK). | Identity | Legal obligation |
| Contact | ||
| Financial | ||
| Special Category | Legal obligation | |
| To local authorities regarding withdrawal of compulsory school age children (UK) | Identity | |
| Contact | ||
| Financial | ||
| Special Category | Legal obligation | |
| To the Police regarding a safeguarding concern or in connection with the prevention or reporting of a crime. | Identity | Legal obligation or Vital interests (depending on the circumstances) |
| Contact | ||
| Special Category | Legal obligation or Vital interests (depending on the circumstances) |
5.d EMPLOYMENT CANDIDATES
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To assess your skills, qualifications and suitability for the role | Identity | Contract |
| Contact | ||
| To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment process | Special Category | Explicit Consent (special category data) |
| Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record) | Identity | Contract |
| Contact | ||
| Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied for | Identity | Contract |
| Criminal Conviction | Legal obligation | |
| To communicate with you about the recruitment process | Contact | Contract |
| To comply with equal opportunities monitoring and reporting requirements | Identity | Legal obligation |
| Special Category | Legal obligation and necessary for statistical purposes |
5.e EDUCATIONAL STAFF APPLICANTS
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To assess your application for a teaching position | Identity | Contract |
5.f ALL VISITORS TO THE WEBSITE
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity | Legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy) |
| Contact | ||
| Profile | ||
| Usage | ||
| Technical | ||
| Marketing and Communications | Consent | |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical | Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| Usage | ||
| To make suggestions and recommendations to you about services that may be of interest to you | Identity | Legitimate interests (to develop our services and grow our business) |
| Contact | ||
| Profile | ||
| Usage | ||
| Technical | ||
5.fi PROVISIONS OF PERSONAL DATA TO THIRD PARTIES (EXTERNAL)
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To service providers worldwide acting as processors who provide IT and system administration services | Identity | Legitimate interests (We have a business requirement to use specialist IT and system administration providers that cannot be provided internally) |
| Contact | ||
| Technical | ||
| Usage | ||
| Profile | ||
| To third parties to whom we may choose to sell, transfer or merge parts of our business as our assets. | Identity | Legitimate interests (We may wish to do this as part of our business strategy) |
| Contact |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will ask for your consent before we share your personal data with any company outside the CGS subsidiaries for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
Your parent(s), guardian(s), or agency will have given us some of your personal information before you arrive. We may get information about you from other schools, the local council, and the government. You might also tell us about some other personal information whilst you are studying with us.
While in most cases you, or your parent(s) or guardian(s), must provide the personal information we need to collect, there are some occasions when you can choose whether or not to provide the information.
We will always tell you if it’s optional. If you must provide the information, we will explain what might happen if you don’t.
International transfers
We share your personal data within CGS. This may involve in some cases transferring your data outside the UK or European Economic Area (EEA).
Some of our external third parties are based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us for more information.
Data security
The personal data that we collect from you will be stored:
- in our own secure data centres in the UK; and
- in the secure data centre of our IT and system administration service provider in the US (in respect of the health data of students studying at one of our US centres)
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data are set out in the tables below:
Student Records
1. Student Recruitment
| Type of data | Retention timescale |
|---|---|
| Enquiries from prospective students (Stafford House School of English Limited and Stafford House Study Holidays Limited) | 1 year from last sales activity |
| Enquiries from prospective students (CATS, CSVPA and ONCAMPUS) | 1 year from creation of record |
| Records of campaigns and events (Stafford House School of English Limited and Stafford House Study Holidays) | 1 year from last sales activity |
| Records of campaigns and events (CATS, CSVPA) | 1 year from creation of record |
2. Applications – Not Progressed (Closed)
| Type of data | Retention timescale |
|---|---|
| Application form (incl scholarship applications) | 2 Years after date of closure |
| Offer of place and related correspondence | 2 Years after date of closure |
| Acceptance of place and related correspondence | N/A |
| Details of criminal convictions | 1 Year after date of closure |
| Passport Documentation/Previous Visas | 1 Year after date of closure |
| Academic and English Documents | 1 Year after date of closure |
| Centre-related Application and Registration Forms | 1 Year after date of closure |
3a. Applications – Registered Paid (Without a CAS, Not Arrived/Enrolled, where applicable)
| Type of data | Retention timescale |
|---|---|
| Application form (incl scholarship applications) | 2 Years after date of Withdrawal |
| Offer of place and related correspondence | 2 Years after date of Withdrawal |
| Acceptance of place and related correspondence | 2 Years after date of Withdrawal |
| Details of criminal convictions | 2 Years after date of Withdrawal |
| Passport Documentation/Previous Visas | 2 Years after date of Withdrawal |
| Academic and English Documents | 2 Years after date of Withdrawal |
| Centre-related Application and Registration Forms | 2 Years after date of Withdrawal |
| Copies of invoices | 7 Years after date of Withdrawal |
3b. Applications – Registered Paid (With a CAS, Not Arrived/Enrolled, where applicable)
| Type of data | Retention timescale |
|---|---|
| Application form (incl scholarship applications) | Original course end date (as per most recent CAS) + 2 Years |
| Offer of place and related correspondence | Original course end date (as per most recent CAS) + 2 Years |
| Acceptance of place and related correspondence | Original course end date (as per most recent CAS) + 2 Years |
| Details of criminal convictions | Original course end date (as per most recent CAS) + 2 Years |
| Passport Documentation/Previous Visas | Original course end date (as per most recent CAS) + 2 Years |
| Academic and English Documents | Original course end date (as per most recent CAS) + 2 Years |
| Centre-related Application and Registration Forms | Original course end date (as per most recent CAS) + 2 Years |
| Copies of invoices | 7 Years after date of Withdrawal |
4. Arrived/Enrolled Students – Withdrawn
| Type of data | Retention timescale |
|---|---|
| Application form (incl scholarship applications) | Original course end date + 3 years |
| Offer of place and related correspondence | Original course end date + 3 years |
| Acceptance of place and related correspondence | Original course end date + 3 years |
| Details of criminal convictions | Original course end date + 3 years |
| Passport Documentation/Previous Visas | Original course end date + 3 years |
| Academic and English Documents; Reports | Original course end date + 3 years |
| Offer/offer pack Forms | Original course end date + 3 years |
| Copies of invoices | 7 Years after date of Withdrawal |
5. Arrived/Enrolled Students – Completed
| Type of data | Retention timescale |
|---|---|
| Application form (incl scholarship applications) | Completion of course + 3 years |
| Offer of place and related correspondence | Completion of course + 3 years |
| Acceptance of place and related correspondence | Completion of course + 3 years |
| Details of criminal convictions | Completion of course + 3 years |
| Passport Documentation/Previous Visas | Completion of course + 3 years |
| Academic and English Documents; Reports | Completion of course + 3 years |
| Copies of invoices | 7 Years after date of Withdrawal |
| Basic student record comprising student name, enrolment date, end date, institution and transcript data | Permanently |
| Accident/incident records of students | 3 years from the date of accident/incident. 40 years in the event of exposure to asbestos |
| Copies of filmed lesson observations | Completion of academic year + 1 term |
Candidate Records
| Type of data | Retention timescale |
|---|---|
| Application forms, CVs and interview notes (unsuccessful candidates) | Last communication to candidate + 6 months |
| Application forms, CVs and interview notes (successful candidates) | Part of personnel file. 6 years after employment ceases. |
Teaching Applicant Records
5. Teaching Applicants| Type of data | Retention timescale |
|---|---|
| Records of CV’s, covering letters and teaching video submissions | 6 months from communication of employment decision. |
(Please note that our stated data retention periods may be affected by the terms of reference of the Independent Inquiry into Child Sexual Abuse (IICSA). We are obliged to retain all documentation regarding a safeguarding concern for the duration of the IICSA. For more information please visit www.iicsa.org.uk).
In some circumstances you can ask us to delete your data: see Request erasure in Section 10 Your legal rights for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data – (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data – (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this basis as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate interests to process your information which override your rights and freedoms.
- Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate interests to use it.
- Request transfer of your personal data – (also known as the “right to data portability”) We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer in writing with full details of your request. You can send an email to dpo@catsglobalschools.com or you can write to us at:
Data Protection Officer, CATS Global Schools, Suites 6-7 The Turvill Building, Old Swiss, 149 Cherry Hinton Road, Cambridge, CB1 7BX, UK
No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
