1. INTRODUCTION - THE POLICY
Policy key definitions:
"I", "our", "us", or "we" refer to the business, RK Tutors.
"you", "the user" refer to the person(s) using RK Tutors website and/or services.
GDPR means General Data Protection Act
PECR means Privacy and Electronics Communications Regulation.
ICO means Information Commisioner's Office.
Cookies mean small files stored on a users computer or device.
Key principles of GDPR:
(a) Lawfulness, fairness and transparency
(b) Purpose limitation
(c) Data minimisation
(e) Storage limitation
(f) Integrity and confidence
2. PROCESSING OF YOUR PERSONAL DATA
For the purpose of the Data Protection Act 2018 (the Act) and the EU General Data Protection Regulation (GDPR) we control and/or process information electronically using the following law bases.
We are registered with the ICO under the Data Protection Registrar, our number is ####
We process your information in the following ways:
Every parent/guardian/adult student will be asked to complete an opt-in form via e-mail. Students below the age of 18 will not be contacted directly but the form will be sent to a responsible parent/guardian. The opt-in form requires positive opting in. These are used to provide explicit consent for us to know how to use your data for day to operations (including but not limited to bookings, feedback, reviews, phone consultations); to deliver information we think may be of use to you (including but not limited to newsletters, tips) and for marketing and promotional purposes. Your consent through opt-in forms is necessary to ensure we deliver you the best service possible. Consent through the opt-in forms is not necessary to use the service, however, it does ensure a smoother customer experience. You are able to withdraw consent at any time by refilling the opt-in forms. We act on withdrawals of consent as soon as we can. No boxes on the opt-in form are pre-ticked or default consent. Information from the opt-in form including time and date of response, e-mail and responses are stored in a spreadsheet. Information from the opt-in form will be stored and retained during the period of tuition and up to three school years after unless otherwise requested. The answers from the opt-in form are at no point shared with third parties.
Every parent/guardian/adult student will be asked for personal details (including but not limited to mobile number, landline number, Skpe contact details, e-mail address, student name and (if necessary) parent/guardian name, age and year of student and student information which makes it easier to tutor the student, such as special educational needs) when signing to use RK Tutors services. These records will be stored along with type of tutoring, if the student requires homework and reports of daily sessions. A payment and communication record is also kept and stored on each student. Consent to use these details and store them are given through the opt-in form through the daily communication section. In addition student records may include additional files supplied by the student (such as homework or teacher reports). After every session a feedback form is created and stored on a student's progress. Students below the age of 18 will not be asked directly for personal details and consent through giving personal details must be given by a responsible parent/guardian. The information in these records enable RK Tutors to deliver the best possible service and to contact you as appropriate and as laid out by the Terms and Conditions and your requests by the opt-in form. Consent to using and recording information for day to day operations through the student record is not necessary to use the service, however, it does ensure a smoother customer experience. You are able to withdraw consent through the opt-in form at any time. We act on withdrawals of consent as soon as we can. The information in student records is not shared with third parties unless consent has been expressely given by the parent/guardian/adult learner. Information in student records will be stored and retained during the period of tuition and up to three school years after unless otherwise requested.
Upon your initial booking with RK Tutors you will be asked to give consent to be added to RK Tutors booking system through Simply Book Me. Through this you can be contacted via SMS and e-mail for booking reminders and to book or edit appointments. This ensures RK Tutors offers the best possible experience to students and ensures the smooth day to day operations of RK Tutors. Students below the age of 18 will not be asked directly for consent to this but a responsible parent/guardian must be asked. Consent is recorded in the student records. To withdraw from this service you can contact RK Tutors directly via the Contact page or through the opt-in form. Information used to book appointments will be stored and retained on the booking system and in student records during the period of tuition and up to three school years after unless otherwise requested. The information is shared with Simply Book Me but you should not receive contact via this from any other third parties.
Upon your initial paid booking with RK Tutors you will be asked to give consent for RK Tutors to input your e-mail address via PayPal so that you can be invoiced for lessons. Invoicing and charging is necessary in order for lessons to take place. At no point will children below the age of 18 be asked to give out payment details or be contacted via PayPal. Contact details and payment information may be stored and requested by PayPal to process payments. You can withdraw consent at any time for RK Tutors to invoice you in this way and you do not have to pay through PayPal as your chosen method. Information for PayPal will be stored and retained during the period of tuition and up to three school years after unless otherwise requested. The information is shared with PayPal but you should not receive contact via this from any other third parties.
After completing tuition services with RK Tutors you will be asked to give feedback on the service you have had. From time to time parents/guardians/adult students will be asked for consent for their testimonials to be pinned to the website for other customers information. The consent must be obtained from the parent/guardian of students below 18. This is to improve and to promote our service. This information will be stored and shared as long as is deemed fit by RK Tutors on the website or until the parent/guardian/adult student who wrote the testimonial no longer wishes it to be published. You must contact RK Tutors to organise this. This information will be shared via the website and available to visitors of the site.
We process personal information that is stored in students records (see above) for the day to day running including but not limited to delivering opt-in forms, recording for student records, booking on the booking system and invoicing via PayPal as under the Terms and Conditions which the parent/guardian/adult student have agreed to. This is to ensure a smooth service to ensure lessons are delivered effectively and in a timely manner. Personal information is never asked for by students under 18 without parent/guardian consent. Information that is needed for day to day operations will be stored and retained during the period of tuition and up to three school years after unless otherwise requested. The Personal Information is shared in the ways previously expressed under the Consent section.
2C. LEGAL OBLIGATIONS
Keeping Your Data Secure
RK Tutors takes securing and processing your data seriously and takes steps to protect your information from unauthorised access, accidental loss, destruction and damage. Security measures included in securing data, but are not limited to, the use of firewalls, virus and spyware scanning and removal, intrusion prevention and browsing data security. Data is backed up securely through One Drive to ensure data is not lost. Personal Data is held during the duration of tuition and three school years after unless otherwise specified.
Not passing on Your Data Without Permission
Only tutors employed by RK Tutors and relevant parties (as discussed above) delivering tutoring to students designated to them or need certain information to perform a specific task (e.g. accounting, maketing) are granted access to your information. This is necessary to ensure effective communication and to ensure the smooth delivery and running of RK Tutors. To limit how long your personal data is retained, it is held for a duration of tuition and a maximum of three school years after unless otherwise specified.
RK Tutors uses reasonable efforts to safeguard your personal information. However, you should be aware that the use of e-mail/the Internet is not entirely secure and for this reason RK Tutors cannot guarantee the security or integretity of any personal information which is transferred from you or to you via e-mail/the Site/the Internet.
If you share a device with others we recommend that you do not select the "remember my details" function when that option is offered.
From time to time RK Tutors may feel that they have a legal obligation to report to authorities their concerns about a person's safety or wellbeing to ensure the student is protected. In this case it may be necessary to share personal information on the student/parent/guardian with third parties (e.g. NSPCC). This data and any acquired will be stored with the students records for teh forceeable future.
2D. VITAL INTERESTS
In certain situations it may be necessary to safeguard a student if it is felt they are at risk. Please see Legal Obligations for more information.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you aout the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
YOUR INDIVIDUAL RIGHTS
Under the GDPR your rights are as follows. You can read more about your rights in detail here;
the right to be informed;
the right of access;
the right of rectification;
the right of erasure;
the right to restrict processing;
the right to data portability;
the right to object; and
the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO (ico.org.uk). If you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
DATA SECURITY AND PROTECTION
We ensure the security of any personal information we hold by using secure data technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement. Please see above for further details.
FAIR AND TRANSPARENT PRIVACY EXPLAINED
SPONSORED LINKS, AFFILIATE TRACKING AND COMMISSIONS
EMAIL MARKETING MESSAGES
Under GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing material. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Any e-mail marketing messages we send are done so through RK Tutors e-mail account to your e-mail supplied.
Any e-mail marketing messages we send are in accordance with the GDPR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences/information we hold about you at any time. Please go to your opt-in form to do this.