Privacy notice

Effective: May 25, 2018

1. About this document

This privacy notice explains how and why OxBridge Centre UK Ltd. (herein referred to as we, our, us, the centre) collects, uses and shares personal data. In addition, this document aims to inform and explain the rights of students and their legal guardians in relation to the personal data we hold.

OxBridge Centre UK Ltd. is the data controller of the personal data of the students and their legal guardians and is subject to the General Data Protection Regulation (GDPR 2018).

2. Definitions

• Student
  A child who receives or those who completed an application form and in line to receive educational services from the centre. Students are data subject of this privacy notice.

• Legal guardian
  The person or persons who are legally responsible for the students and making payments for the services that students receive. Unless explicitly stated otherwise, legal guardians are usually the parents of students. Legal guardians are data subject of this privacy notice.

• Service
  What the centre offers to students and parents in the course of enrolment which includes but not limited to:

• Regular courses
• Intensive courses
• Mock tests
• 11+ Seminar

• Personal data
  Data from which a person can be identified, including data that, when combined with other readily available information, leads to a person being identified.

• Processing
  Obtaining, recording or holding data

• Data subject
  The person whose personal data is held or processed.

• Data controller
  A person or organisation that determines the purposes for which, and the manner in which, personal data is processed.

• Data processor
  A person, other than an employee of the data controller, who processes the data on behalf of the data controller.

3. How we collect your information

We may collect personal data of students and their legal guardians in a number of ways, for example:

• from the information provided by a legal guardian to us when interacting with the centre before joining. For example, when parents express their interest in enrolling the child to one of the services offered by us;
• when legal guardians complete an admission or application form for their child to receive educational services from the centre;
• when legal guardians communicate with the centre by telephone, email, or via text, for example to make enquiries or raise concerns;
• in various other ways as legal guardians or students interact with us during the time the student is enrolled onto a course or using the services provided by us;
• from third parties such as a doctor, a medical institution and a school.

4. The types of information we process

We collect a range of personal data including, but not limited to the followings:

For students:

• Personal information (such as name, date of birth, gender, current school, school year)
• Contact information (such as landline, mobile number, address of residence)
• Behaviour information (such as commentaries about a student’s behaviour and/or attitude in a class)
• Academic information (such as homework grades, admission test results, progress test results, mock test results, progress reports and commentaries about a student’s academic performance in a class)
• Attendance information (such as classes attended, number of absences, absence reasons)

For legal guardians:

• Personal information (such as title, name)
• Contact information (such as landline, mobile number, address of residence, email address)
• Financial information (such as invoice history, payment history, card and bank account details)

5. Why we process the information

The purpose for which we may use personal data we collect during a student’s association with us includes:

• Enrolment and Admissions
• Academic matters, including:

• the provision of our teaching and learning services (e.g. registration, assessment, class allocation, attendance, managing progress, academic misconduct investigation);
• maintaining student records;
• assessing a student’s eligibility in joining a course;
• publishing academic results of a student across the centres.

• Non-academic matters, including:

• monitoring equal opportunity;
• monitoring student behaviour;
• safeguarding and promoting the welfare of students;
• ensuring students’ safety and security.

• Administering finance (e.g. fees, discounts, recovering money owed to us)
• Other administrative purposes, including:

• carrying out research and statistical analysis;
• carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
• promoting our services (e.g. providing information about regular, half-term, summer intensive courses and mock tests, or other events happening on and off the centre.)

• Preventing and detecting crime
• Dealing with grievances and disciplinary actions
• Dealing with complaints and enquiries

6. The legal bases for processing the information and how we use it

Below show the legal bases that we rely on when handling the information about students and their legal guardians:

Legitimate interest

OxBridge centre has a legitimate interest in:

• providing a student with an education;
• encouraging students to be actively involved and engaged with learning through services provided by the centre;
• safeguarding and promoting the welfare and the welfare of other students;
• promoting services that are of interest and benefit for students and their legal guardians;
• facilitating the efficient operation of the centre;
• ensuring that all relevant legal obligations of the centre are complied with;
• maintaining and improving the academic, corporate, financial and human resource management of the centre;
• recovering money owed to us.

Furthermore, personal data of students and legal guardians may be processed for the legitimate interests of others. For example, we may use information about a student when investigating a complaint made by one of the fellow students about the student.

If you object to us using the information where we rely on our legitimate interests as explained above, please contact the Data Protection Officer at dpo@oxbridgeuk.com

Contract

In accordance to the agreements made by both parties: the centre and the legal guardian, we have contractual duty to provide an educational service (e.g. regular course, intensive course, Mock test) for the child of the legal guardian. The information processed is necessary for the performance of the contract with the legal guardian.

Vital interest

For example, to prevent someone from being seriously harmed or killed.

We may ask for the consent of the legal guardians in certain other ways. If we ask for your consent to use your information, you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please talk to one of our admin staff if you would like to withdraw any consent given.

7. Information sharing and disclosure

For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties:

• We share information with our employees, agents and contractors where there is a legitimate reason for receiving the information, including:

• third parties who work with us to provide students with education.
• third parties who work with us to mark students’ work which includes but not limited to homework or tests.
• third parties who work with us to offer courses or class options, track and monitor students’ academic progress, students’ behaviour, and attendance.
• Internal and external auditors.

• With next-of-kin (where there is a legitimate reason for disclosure);
• Government departments and agencies where we have a statutory obligation to provide information.

The centre does not sell or rent personal data of students and their legal guardians. Any personal information we hold is processed in accordance with the GDPR.

8. Sending information to other countries

We may send the information of students or legal guardians where:

• we store information on computer servers based overseas; or
• we communicate with legal guardians or students when they are overseas (for example, during the summer holidays if the parent or the student is in a different country).

9. Changes to your personal data

Please tell us promptly about any changes to the information we hold about you (i.e. student and legal guardian details). This is particularly important for your contact details. You can do this by contacting our Data Protection Officer at dpo@oxbridgeuk.com or by requesting for changes directly to the administrative staff. When requesting for changes directly to our administrative staff, you may be asked to provide a proof of your identity or proof of your relationship with the student.

10. How long your information is kept

Subject to any other notices that we may provide to the legal guardians or the students, we may retain their personal data until the student has finished his or her secondary school (until year 13), or for a period of six years after the student’s association with us has come to an end; whichever is longer will be applied.

If a student ended his/her association with us and the legal guardian has not cleared the invoice, then the personal data of both the student and the legal guardian will be retained indefinitely by us for the purpose of recovering money owed to us.

11. Your rights

Under the GDPR 2018, the students and the legal guardians have the following rights:

• to obtain access to, and copies of the personal data that we hold about you;
• to require that we cease processing your personal data if the processing is causing you damage or distress;
• to require us not to send you marketing communications;
• to require us to correct the personal data we hold about you if it is incorrect;
• to require us to erase your personal data;
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of your transmitting that personal data to another data controller;
• to object, on ground relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

12. Contact us

If you have any queries about this privacy notice or how we process your personal data, you can contact our Data Protection Officer by email: dpo@oxbridgeuk.com or by post:  Data Protection Office, OxBridge Centre UK Ltd. 118 Blagdon road, New Malden, Surrey, KT3 4AE

To request access to the personal data that we hold about you, you may contact our Data Protection Officer by email: dpo@oxbridgeuk.com or by post: Data Protection Office, OxBridge Centre UK Ltd. 118 Blagdon road, New Malden, Surrey, KT3 4AE

You can find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk