Introduction
Welcome to The Language Gallery (TLG) privacy notice. TLG takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.
The UK General Data Protection regulation 2016/679 (UK GDPR) and the Data Protection Act 2018, gives people the right to know what information is held about them, and requires TLG to ensure that personal information relating to living individuals is handled properly, held in confidence and is protected from inappropriate disclosure to third parties.
This privacy notice is provided in a layered format so you can click through to a specific privacy policy.
This website is not intended for children and we do not knowingly collect data relating to children on this website. However where TLG processes personal data of children in its business operations, we ensure that appropriate safeguards and consents are obtained from parents or caregivers as applicable [and that we follow relevant guidance from the Information Commissioner’s Office in relation to the processing of children’s data]. You may contact dpo@thelanguagegallery.com for further information about this.
It is important that you read the privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Data Controller
The Accent Language Ltd trading with the name The Language Gallery (“TLG“ also referred to in this notice as “we” or “us”) is registered as a data controller of your personal data with the Information Commissioner’s Office (our notification number is ZA190401), and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com.
TLG registered address in England and Wales is Belmont House, Station Way, Crawley, West Sussex, RH10 1JA, United Kingdom.
Our Data Protection Officer
If you have any questions about TLG’s privacy policies, please contact the Data Protection Officer at The Language Gallery 40 Tower Hill, Sceptre Court, EC3N 4DX. E-mail dpo@thelanguagegallery.com
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 (www.ico.org.uk). We consider that the ICO would also be the lead supervisory authority for TLG since the UK is the place of the majority of our operations. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.
We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to the ICO or other applicable supervisory authority, so please contact us in the first instance.
More information on how TLG collects and uses personal information can be found in the relevant privacy notices below:
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.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, .
Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO at dpo@thelanguagegallery.com.
Contractual necessity means processing your data where it is necessary for the performance of a contract to which you are a party or to take preliminary pre-contractual steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
To view relevant privacy policy click to expand below:
Types of personal information we collect
We collect, use and store different types of personal information about you, which we have grouped together as follows:
Types of personal information Description
Publicity Available Data Details about you that are publicly available, such as on Companies House or elsewhere on the internet
Marketing Data Details about your preferences in receiving marketing communications from us
Consents Data Any permissions, consents or preferences that you give us
Usage Data Information about how you use our website, products and services
How we use your information
Cookies
Our website https://www.thelanguagegallery.com/ uses cookies. For more information on our cookies use, please read our cookies statement on our website.
Generally
The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.
| What we use your information for | Our reasons | Our legitimate interests |
| To provide you with information you may ask for | Consent | To fulfil enquires you might make of us |
| Legitimate interests | ||
| To allow you to register for updates or for notifications of blog posts on our website | Consent | To provide you with information that you may request from us |
| Legitimate interests | ||
| To allow you to register for events that we may be hosting | Consent | To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services |
| Legitimate interests | ||
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Legitimate interests | To provide efficient client care and services |
| To ensure that our technology operates efficiently and without error | ||
| To assess which of our services may be of interest to you and to tell you about them | ||
| To develop new products and services and improve existing ones | ||
| To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions | Legitimate interests | To provide efficient client care and services |
| Contract performance | To keep you updated about changes in the legal terms that apply to the use of our website | |
| For record keeping and firm management | ||
| To manage the systems that contain our marketing database | Legitimate interests | For data management for marketing and business development purposes |
| To manage marketing preferences and keep our records up to date | To improve our systems and services | |
| To seek feedback | ||
| To seek your consent when we need it to contact you | ||
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Legitimate interests | To improve our marketing strategy and the services that we provide |
| Consent | ||
Where we collect your personal information from
We may collect personal information about you from the following sources:
- Directly from you
- Cookies – see our cookie statement which can be accessed from our website
- Analytics providers, such as Google Analytics
Who we share your information with
We may share your personal information with the following third parties:
- Our agents and service providers who we use to help us with marketing.
- Event organisers (if we are organising an external event which you are attending)
- The police and other law enforcement agencies
- Relevant regulators, including the Information Commissioner's Office in the event of a personal data breach
- The British Council, our accreditation body
- Other companies owned or jointly owned by Global University Systems
- Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.
How long we keep your personal information
Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).
Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again.
For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.
If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.
International transfers
As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards.
If you require more information or have any queries, please contact our Data Protection Officer at: dpo@thelanguagegallery.com
Applicants and Students Privacy Notice
The Language Gallery (TLG) takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.
When processing your Personal Data, The Language Gallery is obliged to fulfil individuals’ reasonable expectations of privacy by complying with the UK General Data Protection Regulation 2016/679 (the UK GDPR), the Data Protection Act 2018 (DPA), and other relevant legislation and regulations (collectively “Data Protection Law”).
Purpose of this Notice
This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.
The Language Gallery also referred to in this notice as “we” or “us”) is a data controller (which means we are responsible for deciding how we hold and use your personal information) of your data and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at https://www.globaluniversitysystems.com.
“Personal data” refers to information relating to a living, identifiable individual. It can also include "special categories of data", which is information about your racial or ethnic origin, religious or other beliefs, and physical or mental health, the processing of which is subject to strict requirements. Similarly, information about criminal convictions and offences is also subject to strict requirements.
“Processing” means any operation which we carry out on your personal data e.g. obtaining, storing, transferring and deleting.
Your personal information
We hold a range of personal data about you, some of which you provide to us direct and some of which we receive from third parties, where relevant. See below for further details of personal data we receive from third parties. Examples of categories of personal data which we hold are: your contact details, prior educational experience/attainment, immigration information (e.g. passport details, language proficiency), where relevant, health information (including any disabilities) and other equality-monitoring data you provide to us. In addition, if you come to study with us, we process data about your attendance and progression, and where relevant, breaches of our policies (e.g. academic or other misconduct concerning The Language Gallery -related activities).We also process contact and educational details after you have completed your course or your activities with us are otherwise terminated.
The purposes for which we process your personal data and the legal basis
When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place on one of our courses.
If you take up a place at The Language Gallery, we process your personal data for the purposes of providing our courses and related services.
If you are unsuccessful or do not take up a place at The Language Gallery, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.
We only process data for specified purposes and if it is justified in accordance with data protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us to process your application and if enrolled, to monitor your progress. Without that information, we would be unable to provide you with your chosen academic programme and related support services. Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your application for a Tier 4 visa.
| No | Purpose | Legal basis/ justification |
|
1 |
Assessing eligibility to undertake our courses |
Processing is necessary for the purposes of taking steps prior to entering into a contract with us |
|
2 |
Supporting applicants through the application process and providing further information on the services we can offer |
Necessary for negotiating to enter into a contract and legitimate interests in providing support to applicants |
|
3 |
Provision of courses and related services (including IT and library services) |
Necessary for performing a contract, i.e. to provide your chosen academic programme. This can be a contract with us or a contract between you and your home institution (“contractual necessity”) |
|
4 |
Identifying students and assisting them in trying to succeed in their learning via the dashboard system. |
Contractual necessity and legitimate interest in assisting our students to succeed in their studies |
|
5 |
Assessment of progress and performance (including attendance), and where necessary providing support |
Contractual necessity |
|
6 |
Administration of extenuating circumstances procedures |
Contractual necessity |
|
7 |
Administration of complaints |
Contractual necessity |
|
8 |
Immigration matters |
Necessary for us to comply with our legal obligations in relation to students |
|
9 |
Making reasonable adjustments for disabilities and providing relevant support to students with ill health and providing wellbeing support. This includes processing special category information. |
Explicit consent |
|
10 |
Employability Support |
Contractual necessity and our legitimate interest in assisting our students and alumni to progress in their careers. |
|
11 |
Obtaining payment of fees |
Contractual necessity and our legitimate interest in obtaining payment for the services we provide. |
|
12 |
Protecting our property and assets (e.g. by dealing with misconduct) |
Necessary for our legitimate interest in safeguarding our property and assets. |
|
13 |
Providing appropriate IT and other infrastructure facilities e.g. a virtual learning environment |
Contractual necessity; legitimate interest in providing a proper infrastructure to support the provision of academic or professional programmes and related student services. |
|
14 |
Communicating with students |
Contractual necessity and our legitimate interest in marketing The Language Gallery and promoting student welfare. |
There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.
Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, The Language Gallery may not be able to process your application or provide you with the course for which you have applied.
| No | Data | Source |
|
1 |
Contact details and attainment |
call agents |
|
2 |
Your immigration status |
Home Office (UKVI) |
|
3 |
Transcripts - details of programmes undertaken or being undertaken at another institution |
Another institution and/or secondary/high schools |
|
4 |
Medical, mental health, accessibility-related and similar information. This is special category personal data. We only obtain this information from third parties if you give us consent to do so or if it’s a matter of life and death. |
Another institution, medical practitioners and/or family members |
|
5 |
Information required to assess eligibility for courses i.e. from employers or sponsors |
Employers or sponsors |
|
6 |
Details as to how you are performing in your apprenticeship job |
Your employer if you are an apprentice |
|
7 |
Details as to how you are performing on placement |
Your placement provider |
|
8 |
Details of performance at a partner institution including attendance and disciplinary issues. |
International study abroad or exchange programme partner or collaboration partner. |
Recipients of personal data
On occasion we may need to share your data with third parties. The following table lists what information we may share with whom
| No | Recipients | Data which we may share with them |
|
1 |
Companies within the group |
Contact details, Course information where students and graduates are interested in entrepreneurship activities and relevant employability activities |
|
2 |
Placement providers |
Your CV as well as any accessibility and assistance requirements and related information. |
|
3 |
Co-curricular and/or extracurricular excursion providers |
Accessibility and assistance requirements and related information. |
|
4 |
Your employer if you are an apprentice. |
Details as to how you are performing in the academic part of your apprenticeship. |
|
5 |
Your employer or sponsor if you are a sponsored student. |
Details as to how you are performing and attendance in your course. |
|
6 |
External examiners. |
Identification details and exam papers. |
|
7 |
UK Home Office |
Passport details; contact details; programme details including attendance, placement details and work experience; fees and housing details |
|
8 |
Data processors i.e. third parties who process personal data on our behalf e.g. software providers |
Application details; attendance records |
|
9 |
Local Authority (including the electorate office) |
Contact details and course details where there’s a legal basis |
|
10 |
The Language Gallery’s insurers and internal and external auditors, Health and Safety Executive in respect of accidents or incidents connected with the company.
|
Student details and details in relation to any incident |
|
11 |
Regulatory bodies, such as the British Council |
Contact details, attendance and progression information |
|
12 |
Government agencies i.e. HMRC* |
Contact details and potentially other information if requested where there is a legal basis |
|
13 |
Police* |
Contact details and potentially other information if requested where there is a legal basis |
|
14 |
London Borough of Holborn or other members of the Channel Panel, a programme which provides support to individuals who are at risk of being drawn into terrorism as defined in Part 5, Chapter 2 of the Counter Terrorism and Security Act 2015 |
Contact details and other information that The Language Gallery could be required to supply in order to comply with the Counter Terrorism and Security Act 2015. |
|
15 |
Potential employers or other companies requesting a reference or confirmation of qualifications
|
Attendance, progression and performance details including disciplinary or academic misconduct issues or breaches of The Language Gallery’s regulations |
|
16 |
Close family, next of kin and emergency services where there is an emergency situation such as illness or serious injury |
Personal data including potentially special category data if necessary |
|
17 |
Other UK based and international educational institutions which The Language Gallery partners or collaborates with to deliver placements, study abroad programmes, dual awards, franchised or validated awards or any articulation or progression agreement. |
Contact details, attendance, progression and performance details and details of any disciplinary or academic misconduct issues or breaches of The Language Gallery’s policies |
|
18 |
External debt collection agencies, in relation to student debts where The Language Gallery’s own recovery attempts have proven unsuccessful |
Contact details and details of debt |
* This will only be shared on request and where there is a legal basis for doing so.
Overseas transfers of personal data (i.e. outside the UK)
Where possible, we aim to hold personal data relating to students within the UK. Where any of your personal data is transferred outside the UK it will be subject to a legally binding data sharing agreement and to an adequacy decision by the ICO (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the UK GDPR.
Retention of data
The length of time that we keep your personal data for is set out in the Student Records Retention Schedule, please contact dpo@thelanguagegallery.com for more information.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
- To gain access to your personal data;
- To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
- To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
- To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
- To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
- To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
- To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.
Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.
Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any of the above rights or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at The Language Gallery, 40 Tower Hill, Sceptre Court, EC3N 4DX
E-mail: dpo@thelanguagegallery.com
Complaints to the Information Commissioner
The Language Gallery maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. The Language Gallery registration number is ZA190401and sets out, in very general terms, the full range of purposes for which we use, students and all other personal information
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.
The Language Gallery (TLG) Privacy Notice - Alumni
Purpose of this Privacy Notice:
Our alumni are extremely important to us. This Privacy Notice explains how we, The Language Gallery (TLG), use the personal data our Alumni department collects.
We are the data controller for personal data relating to you and this Privacy Notice explains how we will process your personal data. This Privacy Notice will be kept under review and any changes will be updated on our website and communicated to you as appropriate.
This Privacy Notice was last updated on 17th November 2021
Due for Review by: 17th October 2022
Who does this privacy notice cover?
This privacy notice covers TLG alumni who have completed a course of over 12 months’ duration and have consented to be contacted for one of the purposes set out below. This notice only covers processing of personal data for Alumni purposes as set out below. For other personal data processing related to former-students see the Student Privacy Notice.
What personal information do we collect?
We may hold a range of personal data about you from a number of sources.
The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of TLG, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to TLG’s alumni database when you complete a course of over 12 months’ duration. We may also add information provided by you during interactions with you.
Examples of categories of personal data which we may hold are:
- Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;
- Contact details – e.g. your postal/ email address, telephone number and contact preferences;
- Information about your time at TLG – e.g. the courses you completed
Career details – e.g. job role; - Communications between the Alumni Department and you;
- Information about your interactions with TLG – e.g. records relating to volunteering activities on behalf of the College, online interactions with us on social media, information about your use of College resources or facilities (e.g. the library), information on your engagement with College meetings, events, groups or networks;
We may also hold information collected from publicly available sources, such as social network posts, internet searches and websites, and may augment this information with the personal data you provide to us.
Why are we collecting your personal data/what are we doing with it (purposes)?
We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at TLG, alumni communications and related activities by the Alumni Department. More specifically, these activities may include:
- sending you publications (e.g. alumni magazines and email newsletters about TLG activities);
- inviting you to alumni reunions and events;
- informing you of benefits available to alumni
- internal record-keeping and administration (e.g. administer an event which you are attending).
There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter. Use of our websites, including our use of cookies, is covered by our website privacy notice: https://www.thelanguagegallery.com/privacy-policy
Do we use any automated decision making or profiling?
Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communications which are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting TLG and to avoid approaching you with opportunities which are not of interest.
What legal bases do we rely on for processing your personal data?
Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.
- UK GDPR Article 6(1) (a) – Consent of the data subject
Unless mentioned below, we will only process your personal data in relation to alumni purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post, unless you have asked us not to. We will also only contact you about TLG news, events if we have your express consent to do so. - UK GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests.
Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in the Student Privacy Notice.
Who do we share your personal data with? What data do we share?
On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.
|
Recipients |
Data which we may share with them |
|
Our staff in the Alumni Department |
Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information. |
|
Our administrative/ IT staff associated with alumni activities |
Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information. |
|
Volunteer partners associated with alumni activities |
Contact details and course information |
|
Event providers |
Registration details, accessibility and assistance requirements and related information including dietary requirements. |
|
Data processors i.e. third parties who process personal data on our behalf e.g. software providers, event booking providers etc. (e.g. Eventbrite) |
Contact details and course information |
How are we protecting your personal data?
Your personal data is held securely on TLG’s alumni database, which is accessible by a limited number of staff and is secured.
If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract that provides adequate safeguards. We ensure we have appropriate data sharing agreements in place before sharing your personal data. We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them. TLG is committed to working in a transparent, ethical, responsible and honest way.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
- to gain access to your personal data;
- to rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
- to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
- to object to the processing of your personal data for marketing purposes;
- to object to the processing of your personal data when such processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing;
- to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period; and
- to ask for the transfer of your data electronically to a third party.
How long is your personal data kept?
Personal data in support of your alumni relationship with TLG will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.
If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.
How can you maintain your personal data?
You can update, amend or correct the data we hold about you by contacting the Alumni Department by email, phone or post. You can also change your communication preferences at any time to restrict how we process your data or opt out of some or all communication. We will also review your consent and preferences at least every two years.
Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer:
Data Protection Officer
Address: 40 Tower Hill, Sceptre Court, EC3N 4DX
Email: dpo@thelanguagegallery.com
Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.
Staff Privacy Notice
The Language Gallery ("we", "our", "us") are committed to protecting and respecting your privacy.
This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.
What is Personal Data?
'Personal data' means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.
This Statement and TLG data protection obligations
In accordance with the General Data Protection Regulation 2016/679 (the “UK GDPR”) and the Data Protection Act 2018 (the “DPA”), together, the “Data Protection Laws”, we are a Data Controller as we determine the purposes for which, and the manner in which, any personal data is, or is likely to be, processed.
This means that we are legally responsible for the personal data we collect and hold about you. It also means that we must comply with the data protection principles (see below). One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect (and our legal basis for doing so), why we collect it, where we collect it from and whether (and with whom) we will share it. We also need to tell you about your rights in relation to the information. This notice provides further details about all of these issues.
In order to comply with our contractual, statutory, and management obligations and responsibilities, we need to process personal data relating to our employees, including ‘sensitive’ or special categories’ of personal data, as defined in the Data Protection Laws which includes information relating to health, racial or ethnic origin, and criminal convictions.
All personal data will be processed in accordance with the Data Protection Laws and The Language Gallery’s Privacy Policy: https://www.thelanguagegallery.com/cookie-settings-privacy-policy
Using your information in accordance with Data Protection Laws
Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a 'legal basis' for the processing.
The legal bases on which your personal data are collected, the types of personal data, and the purposes for which they are processed is given below.
Application for employment (Subsection)
We need to process your personal data that you supplied to The Language Gallery as part of your application for a position at The Language Gallery. This is to ensure that your application can be considered by the relevant department. In your application we will collect the following information:
Personal data gathered
In your application we will collect the following information
- First Name(s)
- Last Name
- Title
- Other Name(s)
- Preferred Forename
- Your Address
- Postcode
- Telephone (Home)
- Telephone (Work)
- Telephone (Mobile)
- Your personal Email
- Details of your Secondary and/or Tertiary education
- Professional qualifications
- Statement in support of your application
- Details within your submitted Curriculum Vitae (CV)
- Details of your right to work in the UK
Information about your present and employment history for the previous five (5) years including:
- Name of Employer(s)
- Address Line 1
- Address Line 2
- Town
- County
- Postcode
- Job Title
- Date From
- Date To
- Salary
- Notice Required
In addition, we may contact your referees as provided in your application to confirm the employment information that you provided.
Special categories personal data
As part of the application you will be asked to provide equality and diversity information, this may include data concerning:
- Any disability
- Your ethnicity
- Your sexual orientation
- Your religious beliefs
You have the right to not provide this information, in which case The Language Gallery will note to statutory bodies that you elected not to provide this information
Criminal records information
In some circumstances we may process your information to undertake a Disclosure and Barring Service (DBS) check, as required by law.
During your employment (subsection)
The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, data concerning sex life or sexual orientation. We will process this data, as well as the data provided in your application in order to perform our obligations arising from your contract of employment with us. The additional personal data we process to meet these responsibilities includes:
Additional data-personal information
The additional personal data (including some special category personal data) we process to meet our responsibilities as an employer includes the following:
- Previous sickness information including the reasons for the absence
- Bank account details
- Passport details
- Visa details
- Sick pay
- Leave entitlement
- Parental pay
- Pensions data
- Remuneration and benefits
- Emergency contacts
- Trade Union Membership
Statutory responsibilities
We may process your personal data in order to meet responsibilities imposed on us by legislation. The personal data processed to meet statutory responsibilities includes, but is not limited to, data relating to:
- tax;
- national insurance;
- statutory sick pay;
- statutory maternity pay;
- family leave;
- work permits, and equal opportunities monitoring.
Our lawful basis for processing
The lawful bases for processing personal data will be:
- Article 6(1) (b) Contract
- Article 6(1) (c) Legal obligation
- Article 6(1) (f) Legitimate interest
Purpose of processing
We will use your personal data in connection with your employment relationship with us, including for the following purposes:
- To facilitate staff training
- Managing our accounts and records and providing commercial activities to our clients.
- For the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime – The CCTV policy can be found HERE
- To provide you access to relevant systems to undertake your role.
- To fulfil our obligations for the contract of employment.
- Processing recruitment applications.
- Talent, performance and succession planning.
- Paying and reviewing salary and other remuneration and benefits.
- Providing and administering benefits (including pension, voluntary healthcare schemes, salary sacrifice schemes and others).
- Undertaking performance appraisals and reviews.
- Policy and Legal Governance requirements and compliance.
- Internal audit and data collection.
- External audit of the British Council, which is our accreditation body
- Legal compliance, requirements and obligations.
- Maintaining sickness and other absence records.
- Providing references and information to future employers and, if necessary, governmental bodies.
- Processing information regarding equality of opportunity and treatment of data subjects in line with the monitoring of equal opportunities and access.
- The information we process may be held on TLG’s Corporate systems some of which may be owned and operated by third parties. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered to by them to protect the personal data.
Special categories personal data
The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information about racial or ethnic origin; political opinions; religious beliefs or other similar beliefs; trade union membership; physical or mental health; sexual life. In certain limited circumstances, the Data Protection Laws permit us to process such data without requiring the explicit consent of the employee.
(a) We will process sensitive personal data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and consent.
(b) Other than in exceptional circumstances, The Language Gallery will process sensitive personal data about an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding The Language Gallery’s equal opportunities policies and related provisions.
(c) Information about an employee’s criminal convictions will be held as necessary and only in accordance with Data Protection Legislation.
The lawful basis for processing this special category personal data will be:
The UK GDPR Article 9(2)(b) ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
Sharing personal data
We sometimes need to share the personal information we process with you and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Laws.
We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the UK. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as Standard Contractual Clauses or equivalent measures.
Where necessary or required we will share your information with:
- family, associates and representatives of the person whose personal data we are processing;
- current, past or prospective employers;
- healthcare, social and welfare organisations;
- suppliers and service providers;
- financial organisations;
- auditors; such as the British Council
- police forces, security organisations;
- courts and tribunals;
- prison and probation services;
- legal representatives;
- local and central government;
- consultants and professional advisers;
- trade union and staff associations;
- survey and research organisations, and
- press and the media.
Furthermore, in order to fulfil its statutory responsibilities, The Language Gallery is required to provide some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
Automated processing
The Language Gallery does not use automated processing and decision making without manual intervention.
Principles
We will handle your personal data in accordance with the principles set out below:
| Principle | Personal Data shall be: |
|
Lawfulness, fairness and transparency |
be processed lawfully, fairly and in a transparent manner in relation to the data subject. |
|
Purpose limitation |
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. |
|
Data minimisation |
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. |
|
Accuracy |
accurate and, where necessary, kept up to date. |
|
Storage limitation |
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. |
|
Integrity and confidentiality |
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures |
|
Accountability |
be able to demonstrate compliance with the above principles |
Keeping personal data up-to date
The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up-to-date. Employees are responsible for informing us of any changes to the personal data that they have supplied during the course of their employment. You can use CEZANNE to update your personal data or contact askhr@gus.global to update your personal data.
Retention of your data
The Language Gallery retains personal information it collects from you where there is an ongoing business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When there is no ongoing business need to process your personal information, The Language Gallery will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then The Language Gallery will securely store your personal information and isolate it from any further processing until deletion is possible. Personnel files are retained for a period of at least 6 years from the date of termination of employment.
How does The Language Gallery protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
Your rights
Under certain circumstances, you may have the following rights in relation to your personal data:
Right 1: A right to access personal data held by us about you.
Right 2: A right to require us to rectify any inaccurate personal data held by us about you.
Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.
Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.
Right 6: A right to object to our processing of personal data held by us about you.
Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.
Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: dpo@thelanguagegallery.com
Changes to our privacy Policy
Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.
Who regulates the use of my personal information?
The Language Gallery maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. The Language Gallery registration number is ZA190401 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.
Who do I contact with questions?
The data controller for the purposes of the UK General Data Protection Regulation is The Language Gallery. If you have any questions or concerns about how your personal data is used, please consult https://www.thelanguagegallery.com/cookie-settings-privacy-policy and if you have a complaint please email The Language Gallery Data Protection Officer at: dpo@thelanguagegallery.com
If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website
Recruitment Privacy Notice
1. What is this notice?
This notice applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.
We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.
This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.
2. Your personal information
In this privacy notice, 'your personal information' means your personal data i.e. information about you from which you can be identified. Sections 5 and 6 below set out your personal information that we may process.
Your 'personal information' does not include data where the identity has been removed (anonymous data).
It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.
3. Special categories of personal information
'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.
Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below.
4. Where does your personal information come from?
Your personal information will come from you or us, and may also come from the following sources:
- Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.
- Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.
- Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.
- The Language Gallery staff may provide us with: personal information about you if they are referring you for recruitment.
- Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability.
- Professional bodies such as the, Association of Chartered Certified Accountants, Law Society of England and Wales, and / or the Solicitors Regulation Authority may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.
- Google and social networking accounts (such as LinkedIn): as part of the recruitment process we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.
- Disclosure Scotland: as described at section 6 below.
- Some of the sources above will only be relevant in certain circumstances, or if you have applied for a particular role. If you would like more information on the source of your personal information please contact the HR department.
5. Processing your personal information
We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.
In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:
- Retain records relating to the recruitment process;
- Establish, exercise or defend legal claims;
- Comply with the law or requirements of any regulator; and
- Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).
| Reason for processing your personal information | Legal ground(s) for processing, and legitimate interest (where applicable) | Your personal information |
|
Contact you regarding the recruitment process and any offer of work |
To enter a contract |
Personal contact details (including name, address, email, telephone number) |
|
Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the work |
To enter a contract For our legitimate interests:
|
|
|
If you have accepted an offer of work from us that is subject to such checks:
|
To enter a contract For our legitimate interests:
|
|
|
Determine the terms of any potential contract between you and us |
To enter a contract To comply with a legal obligation |
Offer letter, and proposed contract between you and us |
|
If you have accepted an offer of work, check you are legally entitled to work in the UK |
To enter a contract To comply with a legal obligation |
Documentation confirming your right to work in the UK |
|
Consider reasonable adjustments to the recruitment process for disabled applicants
|
To enter a contract To comply with a legal obligation For our legitimate interests:
*For special categories of information:
|
Information about a disability, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability*
|
|
Carry out equal opportunities monitoring. |
For our legitimate interests:
*For special categories of information:
|
The following information you have provided via our equal opportunities monitoring form:
|
6. Information about criminal convictions
To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 6.
We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.
If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) from Disclosure Scotland, and provide us with a copy of this.
7. Data necessary for the contract
Sections 5 and 6 above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.
8. Statutory requirement to provide your personal information
In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:
- Documentation confirming your right to work in the UK – you are not obliged to provide this information, but if you don't provide it, we will not be able to enter into a contract with you.
9. Sharing your personal information with third parties
We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:
- Health professionals and occupational health providers involved in your care, in order to consider reasonable adjustments to the recruitment process for disabled applicants.
- Relevant regulators
- Our professional advisors.
- Other third parties as necessary to comply with the law.
10. Automated decision-making
We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.
11. Transferring your personal information outside the UK
We share your personal data within the GUS Group. This will involve transferring your data outside the UK. Some of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as Standard Contractual Clauses or equivalent measures.
12. Data retention
If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:
- to allow us to establish, exercise or defend legal claims; and
- for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.
If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.
If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Notice, and will retain your personal information as detailed in the Staff Privacy Notice.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
- To gain access to your personal data;
- To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
- To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
- To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
- To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
- To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
- To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.
Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month
If you require more information or have any queries, please contact our Data Protection Officer at: dpo@thelanguagegallery.com
If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website
Former employees Privacy Notice
The Language Gallery ("we", "our", "us") are committed to protecting and respecting your privacy.
This privacy notice applies to former employees of The Language Gallery.
It is important that you read this privacy notice together with our privacy notice at: https://www.thelanguagegallery.com/cookie-settings-privacy-policy or any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you. This is so that you are fully aware of how and why we are using your data.
Information we collect
The Language Gallery does not collect personal data from former employees after they have left our employment, but it may hold the information that was collected before and during the employment relationship, including:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth
- Gender
- Marital status and dependants
- Next of kin and emergency contact information
- National insurance number
- Copy of identification (Passport/driving licence)
- Bank account details, payroll records and tax status information
- Salary, annual leave, pension and benefits information
- Start date
- Location of employment or workplace
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
- Employment records (including job titles, work history, working hours, training records and professional memberships)
- Compensation history
- Performance information
- Disciplinary and grievance information
- CCTV footage and other information obtained through electronic means such as swipecard records
- Information about your use of our information and communications systems
- Photographs
Our lawful basis for processing
The lawful bases for processing personal data will be:
- UK GDPR Article 6(1) (b) Contract
- UK GDPR Article 6(1) (c) Legal obligation
- UK GDPR Article 6(1) (f) Legitimate interest
How we process your information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the obligations in a contract we have entered into with you, such as the employment contract, or a settlement agreement. Some of the contractual obligations in these contracts continue after your employment has terminated, such as the duty to observe confidentiality.
2. Where we need to comply with a legal obligation.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your vital interests (or someone else’s vital interests). UK GDPR Article 6(d).
2. Where it is needed in the public interest. UK GDPR Article 6(1) (e).
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may process your data for the following purposes:
- Paying you and deducting tax and National Insurance contributions and other lawful deductions.
- Providing you with any employee related benefits to which you are entitled after the termination of your employment.
- To reimburse you for expenses incurred in the course of your employment.
- Liaising with your pension provider and the trustees/administrators of pension schemes.
- Administering any contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- Gathering evidence for possible grievance or disciplinary hearings.
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
- To prevent and detect fraud.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies (such as the staff survey) to review and better understand employee retention and attrition rates.
- Equality and diversity monitoring
- Publicising our activities (e.g., group photos of events, site visits, etc.).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
How we process “special categories” of more sensitive personal information
We may also store and use the following “special categories” of more sensitive personal information that we have collected from you:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Trade union membership.
- Information about your health, including any medical condition, health and sickness records.
- Biometric data.
- Information about criminal convictions and offences.
These “special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for storing and using this type of personal information. Our data protection policy contains details of the safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
1. Where we need to carry out our legal obligations or exercise rights in connection with employment.
2. Where it is needed in the public interest: for example, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equality and diversity monitoring and reporting. Where possible, we would seek to anonymise this data.
3. In limited circumstances, with your explicit written consent. However, we do not need your consent to use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Who is the information shared with
We may share your data with third parties, including third-party service providers, Government departments and agencies.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
The Language Gallery shares your data with:
- Occupational Pension Scheme Trustees and Administrators.
- Occupational Health providers screening
- Trade Unions of which you are a member
Retention
The Language Gallery will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.
The Language Gallery has a records retention schedule that outlines how long we will retain information.
To determine the appropriate retention period for personal data collected as part of your employment, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee we will retain and securely destroy your personal information after the following periods
- 12 months from date of leaving for employees; except
- Payroll, tax and NIC records which must be retained required for 6 years. This is a legal requirement.
However, these periods only apply to your employment records and not for example to images and materials created and use for marketing and communication purposes (e.g. group photographs taken at away days etc.)
Your rights
Under certain circumstances, you may have the following rights in relation to your personal data:
Right 1: A right to access personal data held by us about you.
Right 2: A right to require us to rectify any inaccurate personal data held by us about you.
Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.
Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.
Right 6: A right to object to our processing of personal data held by us about you.
Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.
Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: dpo@thelanguagegallery.com
Changes to our privacy Policy
Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.
Who regulates the use of my personal information?
The Language Gallery maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. The Language Gallery registration number is ZA190401 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.
Who do I contact with questions?
The data controller for the purposes of the UK General Data Protection Regulation is The Language Gallery. If you have any questions or concerns about how your personal data is used, please consult https://www.thelanguagegallery.com/cookie-settings-privacy-policy, and if you have a complaint please email The Language Gallery Data Protection Officer at: dpo@thelanguagegallery.com
If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website.