Privacy Policy

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.

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.

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. 

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

* 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.

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/.

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.