GDPR 2018 PRIVACY NOTICE
This document refers to personal data, which is defined as information concerning any living person, (a natural person, who hereafter shall be called the Data Subject), that is not already in the public domain.
The General Data Protection Regulation (GDPR), which is EU-wide and far more extensive than its predecessor, the Data Protection Act, along with the Privacy and Electronic Communications Regulation (PECR), seeks to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data, and the unrestricted movement of personal data within the EU, and its storage within the EEA.
1. Who We Are - NMS Tuition is a tuition business, that carries out online, and in-person, lessons in French, Spanish and English. NMS Tuition is based in Cobham, Surrey in the UK. The term 'NMS Tuition' hereby refers to the company as a whole, and Natasha Saed, the owner of said company, and current sole employee.
2. Personal Data
a) For the purposes of providing lessons, NMS Tuition may require personal information such as phone numbers, e-mail addresses and home addresses. We only collect what is relevant and necessary for the provision of lessons. This data is held securely, and is not shared with anyone or any third parties. To be able to process such data, it is necessary that you give your consent for NMS Tuition to document and process your personal data. Contact details provided may be used to contact you regarding future lessons, or to provide you with any information pertaining to your tuition.
b) For marketing purposes, NMS Tuition may also use the contact details you provide to respond to your enquiries, including making telephone contact and emailing information to you that NMS Tuition believes may be of interest to you.
c) In making initial contact with NMS Tuition, you consent to the company maintaining a marketing dialogue with you until you either opt out, (which you can do at any time), or we decide to desist in promoting our services. NMS Tuition does not share or broker your data, and you can ask to be removed from our database by emailing or phoning the company using the details provided at the end of this notice.
d) Some basic personal data may be collected by you from marketing forms or surveys you complete, from records or our correspondence and phone calls, and details of your visit to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses.
f) NMS Tuition will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
3 - Legal Basis for processing any personal data
Legitimate interest to respond to enquiries concerning the services provided, and there forward carry out tuition services required by the client.
4 - Legitimate interests pursued by NMS Tuition
To teach and share knowledge of French, Spanish and ESL with students learning as part of a school curriculum, for business purposes, or for personal gain.
5 - Consent
Through agreeing to this privacy notice, you are consenting to NMS Tuition processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, e-mail address or phone number provided at the end of this privacy notice.
6 - Disclosure
NMS Tuition will keep your personal information safe and secure. We will not disclose your personal information unless compelled to, in order to meet legal obligations, regulations, or valid governmental requests. NMS Tuition may also use data in order to prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property and safety of the company and its employees.
7 - Retention Policy
NMS Tuition will process personal data during the duration of any tuition of clients, and will continue to store only the personal data needed for 12 months after the tuition has expired to meet any legal obligations. After 12 months, all personal data will be deleted, unless basic information needs to be retained by NMS Tuition to meet our future legal obligations to you, such as erasure details.
8 - Data Storage
All data is held in the United Kingdom. NMS Tuition does not store personal data outside the EEA.
9 - Your rights as a data subject
At any point whilst NMS Tuition is in possession of, or processing your personal data, all data subjects have the following rights:
Right of access - you have the right to request a copy of the information that we hold about you
Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete
Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records
Right to restriction of processing - where certain conditions apply you have the right to restrict the processing
Right of portability - you have the right to have the data we hold about you transferred to another organisation
Right to object - toy have the right to object to certain types of processing, such as direct marketing
Right to object to automated processing, including profiling - you also have the right not to be subject to the legal effects or automated processing or profiling
In the event that NMS Tuition refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request, NMS Tuition can confirm what information we hold about you and how it is processed.
10 - You can request the following information:
Identity and contact details of the person or organisation that has determined how and why to process your data
The purpose of the processing, as well as the legal basis for processing
If the processing is based on the legitimate interests of the company, and the information about these interests
The categories of personal data collected, stored and processed
Recipient(s) or categories of recipients that the data is/will be disclosed to
How long the data will be stored
Details of your rights to correct, erase, restrict or object to such processing
Information about your right to withdraw consent at any time
How to lodge a complaint with the supervisory authority (ICO)
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data, and the possible consequences of failing to provide such data
The source of personal data, if it wasn't collected directly from you
Any details and information of automated decision-making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
11 - To access the personal data that is held, identification will be required:
NMS Tuition will accept the following forms of identification when information on your personal data is requested: a copy of your driving license, passport or birth certificate, and a utility bill not older than three months. A minimum of one piece of photographic identification listed above and a supporting document is required. If NMS Tuition is dissatisfied with the quality of the identification, further information may be sought before personal data can be released. All requests should be made to email@example.com, or by phoning +44 (0) 7595 178 139, or by writing to us at the address further below.
12 - Complaints
In the event that you wish to make a complaint about how your personal data is being processed by NMS Tuition, you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
NMS Tuition - 07595 178 139 or firstname.lastname@example.org
ICO - Wycliffe House, Water Lane, Wilmslow, SK9 5AF, +44 (0) 303 123 1113, or e-mail https://ico.org.uk/global/contact-us/email/