GENERAL DATA PROTECTION REGULATION
Leanne Miltun & Associates, trading as The British School of Etiquette Poland (TBSoE Poland), Czterech Wiatrów 47, 02-860, Warszawa, is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with the data protection principles and the Data Protection Act May 10, 2018. https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20180001000
The purpose is of this policy is to help us achieve our data protection and data security aims by:
notifying our staff and candidates of the types of personal information that we may hold about them and what we do with that information;
ensuring staff understand our rules and the legal standards for handling personal information relating to staff and others: and
clarifying the responsibilities and duties of staff in respect of data protection and data security.
Changes to data protection legislation shall be monitored and implemented in order to remain compliant with all requirements.
The legal bases for processing data are as follows:
(a) Consent: the member of staff/candidate/enquirer has given clear consent for the school to process their personal data for a specific purpose in relation to their employment and/or enrolment on, undertaking and completion of training courses offered by TBSoE Poland.
(b) Contract: the processing is necessary for the member of staff’s employment contract or candidate contract to undertake training.
(c) Legal obligation: the processing is necessary for the school to comply with the law (not including contractual obligations).
The member of staff responsible for data protection is Leanne Miltun. However, all staff must treat all candidate information in a confidential manner and follow the guidelines as set out in this document. TBSoE Poland is also committed to ensuring that its staff are aware of data protection policies, legal requirements and adequate training is provided as required.
The requirements of this policy are mandatory for all staff employed by the school and any third party contracted to provide services for and on behalf of TBSoE Poland.
Breaches of personal or sensitive data shall be notified within 72 hours to the individual(s) concerned.
PERSONAL AND SENSITIVE DATA:
All data within TBSoE Poland’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.
The personal and sensitive data are any data which relates to a living individual who can be identified:
(a) from those data, or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The principles of the Data Protection Act shall be applied to all data processed and TBSoE Poland agree to:
ensure that data is fairly and lawfully processed
process data only for limited purposes
ensure that all data processed is adequate, relevant and not excessive
ensure that data processed is accurate
not keep data longer than is necessary
process the data in accordance with the data subject’s rights
ensure that data is secure
ensure that data is not transferred to other countries without adequate protection.
FAIR PROCESSING / PRIVACY NOTICE:
TBSoE Poland shall be transparent about the intended processing of data and communicate these intentions via notification to staff and candidates prior to the processing of individual’s data. There may be circumstances where TBSoE Poland is required either by law or in the best interests of our candidates or staff to pass information onto external authorities, for example local authorities, accreditation or inspection bodies or the department of health. These authorities are up to date with data protection law and have their own policies relating to the protection of any data that they receive or collect.
The intention to share data relating to individuals to an organisation outside of TBSoE Poland shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information. Any proposed change to the processing of individual’s data shall first be notified to them. Under no circumstances will TBSoE Poland disclose information or data:
that would cause serious harm to the candidate or anyone else’s physical or mental health or condition,
that would allow another person to be identified or identifies another person as the source, unless the person is an employee of the school or a local authority or has given consent, or it is reasonable in the circumstances to disclose the information without consent. The exemption from disclosure does not apply if the information can be edited so that the person’s name or identifying details are removed,
in the form of a reference given to another place of education and training, sponsor or potential employer.
In order to assure the protection of all data being processed and inform decisions on processing activities, we shall undertake an assessment of the associated risks of proposed processing and equally the impact on an individual’s privacy in holding data related to them.
Risk and data protection impact assessments (DPIA) shall be conducted in accordance with guidance given by theOffice of Personal Data Protection https://uodo.gov.pl/pl/138/605
Security of data shall be achieved through the implementation of proportionate physical and technical measures. Nominated staff shall be responsible for the effectiveness of the controls implemented and reporting of their performance.
The security arrangements of any organisation with which data is shared shall also be considered and where required these organisations shall provide evidence of the competence in the security of shared data.
DATA ACCESS REQUESTS (SUBJECT ACCESS REQUESTS):
All individuals whose data is held by us, have a legal right to request access to such data or information about what is held. TBSoE Poland shall respond to such requests within one month and these should be made in writing to the Principal. No charge will be applied to process the request. Personal data about candidates or staff will not be disclosed to third parties without the consent of the individual, unless it is obliged by law or in their best interest.
This may be for registration purposes, to allow candidates to sit examinations set by external exam bodies or receive external accreditation or award.
As obliged under health legislation, the school may pass on information regarding the health well-being of those enrolled to comply with regulations regarding the spread of contagious diseases in the interest of public health.
POLICE AND COURTS
If a situation arises where a criminal investigation is being carried out TBSoE Poland may have to forward information on to the police to aid their investigation. TBSoE Poland will pass information onto courts as and when it is ordered.
In order to protect or maintain the welfare of our candidates, and in cases of suspected abuse or radicalisation, it may be necessary to pass personal data on to support agencies.
RIGHT TO BE FORGOTTEN:
Where any personal data is no longer required for its original purpose, an individual can demand that the processing is stopped and all their personal data is erased by TBSoE Poland including any data held by contracted processors.
PHOTOGRAPHS AND VIDEO:
Images of staff and candidates may be captured at appropriate times and as part of training activities for use in school only. Unless prior consent from candidates/staff has been given, the school shall not utilise such images for publication or communication to external sources. It is the school’s policy that external parties (including candidates) may not capture images of staff or pupils during such activities without prior consent.
LOCATION OF INFORMATION AND DATA:
Hard copy data, records, and personal information are stored out of sight and in a locked cupboard. Sensitive or personal information and data should not be removed from the school site, however TBSoE Poland acknowledges that some staff may need to transport data between the registered office/training venue and their home in order to plan or write up feedback in relation to courses being delivered. This may also apply in cases where staff have offsite meetings or are on TBSoE Poland organised visits with candidates.
The following guidelines are in place for staff to reduce the risk of personal data being compromised:
Paper copies of data or personal information should not be taken off the school site. If these are misplaced they are easily accessed. If there is no way to avoid taking a paper copy of data off the school site, the information should not be on view in public places, or left unattended under any circumstances.
Unwanted paper copies of data, sensitive information or candidate files should be shredded. This also applies to handwritten notes if the notes reference any other staff member or candidate by name.
Care must be taken to ensure that printouts of any personal or sensitive information are not left in printer trays or photocopiers.
If information is being viewed on a PC, staff must ensure that the window and documents are properly shut down before leaving the computer unattended. Sensitive information should not be viewed on public computers.
If it is necessary to transport data away from the school, it should be downloaded onto a USB stick. The data should not be transferred from this stick onto any home or public computers. Work should be edited from the USB, and saved onto the USB only.
USB sticks that staff use must be password protected.
These guidelines are clearly communicated to all TBSoE Poland staff, and any person who is found to be intentionally breaching this conduct will be disciplined in line with the seriousness of their misconduct.
TBSoE Poland recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk. All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner, where required, with demonstrable competence in providing secure disposal services.
All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process.
TBSoE Poland has identified a qualified source for disposal of IT assets and collections. TBSoE Poland also uses a shredder to dispose of paper based sensitive data that is no longer required.
Unit 5, Lakeside Business units
DATA SUBJECTS’ RIGHTS.
In relation to the processing of personal data by TBSoE, data subjects have the following rights:
the right to request access to their personal data, rectification, erasure or restriction of processing,
the right to object to the processing,
the right to data portability,
the right to withdraw consent to the processing of personal data for a specific purpose, if you have previously given such consent,
right to lodge a complaint with a supervisory authority in relation to the processing of personal data.
The above rights can be exercised in accordance with the principles described in Articles 16 – 21 of the RODO.
DURATION OF PROCESSING OF PERSONAL DATA
TBSoE shall process data only for as long as they are necessary for the performance of the contract and the termination of claims arising therefrom;
TBSoE shall process personal data for the duration of archiving accounting documents in accordance with applicable laws, including tax and accounting obligations, the assertion of claims in connection with the performance of the contract and the prevention of fraud and abuse;
TBSoE processes personal data for time-limited statistical purposes;
TBSoE shall process personal data for a maximum period of 10 years from the date of completion of the contract;
TBSoE processes personal data for marketing purposes until an objection to such processing is raised.
If the person whose data is being processed requests the erasure of his/her data, the Administrator shall do so immediately, provided that this does not contradict current requirements for data storage, e.g. for tax and fiscal purposes.
This website uses, in whole or in part, SSL or TLS encryption for security reasons and to protect the transmission of sensitive content, such as requests sent to us as the website operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http: //” to “https: //” and a padlock icon is displayed in the browser address bar.
If SSL or TLS encryption is activated, the data that is processed cannot be read by third parties.
When contacting the Administrator by e-mail, the e-mail address is naturally transmitted as the address of the sender of the message. Moreover, other personal data may be included in the content of the message.
The legal basis for the processing of personal data in such a case is the consent resulting from the initiation of contact.
Personal data provided within the scope of e-mail contact are processed exclusively for the purpose of handling the inquiry. The content of the correspondence may be subject to archiving.
If you have given your marketing consent, we would like to inform you that your data may be passed on to marketing agencies and advertising companies cooperating with TBSoE.
The legal basis for processing personal data in this case is the consent, which can be revoked at any time.
When sending questions via the contact form, TBSoE collects the data entered in the form, including contact details, provided to answer the question asked and any further questions. This information is not shared without the consent of the data subject.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small text information stored on a terminal device (e.g. computer, tablet, smartphone) that can be read by an ICT system.
ensure proper functioning of the site,
improve the speed and safety of use of the site,
improve functions available on the site,
use analytical tools,
Use marketing tools,
Show YouTube videos on the site,
provide social features.
Own cookies. Cookies can be divided into own and third party cookies. As far as own cookies are concerned, TBSoE uses them in order to make the website work properly.
Analysis and statistics. Cookies are used to track site statistics such as number of visitors, type of operating system and browser used to view the site, time spent on the site, pages visited, etc. We use the Google Analytics tool for this purpose. The information collected in this regard is completely anonymous and does not allow you to be identified. Cookies from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, are used for this purpose regarding the Google Analytics service.
The use of Google Analytics services involves the implementation of a tracking code provided by Google in the code of our website. This code is based on cookies, but may also use other tracking technologies.
Google Analytics cookies are stored on the basis of Article 6 (1) (f) RODO. The website operator has a legitimate interest in analysing user behaviour in order to optimise both the website and advertising.
Social features and marketing. TBSoE uses marketing tools such as Facebook, Instagram, to target individuals with advertisements on these sites. For this purpose, tools from these entities are implemented in the code of the website.
Facebook and Instagram plug-ins
Website contains plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. You can recognise Facebook plug-ins by the Facebook logo or the Like button on our website. For an overview of Facebook plug-ins, see https://developers.facebook.com/docs/plugins/.
The website uses plugins from YouTube operated by Google. The website operator is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
Youtube is used to make the website attractive. This constitutes a legitimate interest according to Article 6 (1) (f) RODO.
For more information on the processing of your data, please see the YouTube data protection declaration at https://www.google.de/intl/de/policies/privacy
Our website uses a plug-in called Calendly to enable video chats. When using the plugin, please be aware that an image of the person participating in the meeting may be captured.
When you make a payment on the site, a third-party plug-in called Stripe is used to process billing data from your payment card.
The use of the website involves sending requests to the server on which the website is stored. Each request made to the server is recorded in server logs.
The logs include the IP address, date and time of the server, information about the web browser and operating system you are using. Logs are saved and stored on the server.
The data stored in the server logs are not associated with specific persons using the service and are not used by us to identify you.
The server logs constitute only the auxiliary material used to administer the website and their content is not disclosed to anyone except persons authorised to administer the server.