If you have any questions about this policy please contact the Privacy Manager on firstname.lastname@example.org or 01772 369349.
WHO WE ARE
The term “Student Xpress” used in this document refers to Student Xpress Ltd.
In this policy the terms “agent” and “agencies” refer to companies whose business involves arranging accommodation and educational services for individuals or groups of individuals, and who choose Student Xpress to provide these services. In cases where your primary relationship is with the agency, they are the “controller” of your data and Student Xpress will only process data in a way they have agreed with you.
WHAT IS PERSONAL INFORMATION?
Personal information is information that identifies you as an individual and relates to you or your child/children. Throughout the rest of this document “you” refers to adult students, students under 18 and their parents/guardians.
This personal information includes your contact details, next of kin, financial information, country of origin and mother tongue. We may also hold information such as your religion or ethnic group where this is required to provide appropriate services (for example in providing a Halal or Kosher diet). CCTV, photos and video recordings of you are also personal information.
HOW AND WHY DOES STUDENT XPRESS COLLECT AND USE PERSONAL INFORMATION?
We set out below examples of the different ways in which we use personal information and where this personal information comes from. Student Xpress’s primary reason for using your personal information is to provide accommodation and educational services to you.
We obtain information about you from booking forms and from agencies you have contracted directly for the purpose of accommodation and educational services where the agent has passed your details to us in order to fulfil their agreement with you.
We may have information about any family circumstances which might affect you or your child’s welfare, happiness or safeguarding. We will also keep a log of any issues related to welfare/safeguarding and this may be discussed by the appropriate teams and referred to in meeting minutes.
We may have information about any medical or SEND issues relating to you. This is to ensure that you have sufficient support, that we are prepared for emergencies and/or that your health and safety can be appropriately looked after.
We will keep information regarding your academic progress. This is to ensure you have sufficient support in your learning.
We may need information about any court orders or criminal petitions which relate to you. This is so that we can safeguard the welfare and wellbeing of you and others at our accommodation and classes.
We may take photographs or videos of you at Student Xpress events to use on social media and on our website. This is to show prospective students how we work and to advertise Student Xpress, and also because students often like their photos to be shared through social media so that they can show others/remember events/times. We may continue to use these photographs and videos after you have completed your time with us.
We may send you information to keep you up to date with what is happening at Student Xpress. For example, by sending you information about events and activities taking place, and may contact you with offers for accommodation or courses similar to those you have accessed in the past.
We will process financial information about you in relation to the payment of fees. In some cases we get information about you from third parties such as agencies you have contracted.
SHARING PERSONAL INFORMATION WITH THIRD PARTIES
In accordance with our legal obligations, we may share information with local authorities or UK Visas and Immigration (UKVI). We may also share information with accrediting bodies including the Independent Schools Inspectorate, Accreditation UK and AEGIS. Where we have safeguarding concerns we may contact the relevant Local Authority Designated Officer (LADO).
We may share information with third parties such as student residences, homestay hosts, tutors, transfer companies and excursion companies in order to fulfil our contract with you, or the contract you have agreed with your agent. In these cases we will only share what information is necessary to deliver the service.
For students sponsored by their government, we may need to share information with the relevant government department or embassy. This information may include details of your attendance, behaviour and learning progress.
On occasion, we may need to share information with the police.
We may also need to share information with our legal advisers for the purpose of obtaining legal advice.
Occasionally we may use consultants, experts and other advisors to assist Student Xpress in fulfilling its obligations. We may need to share your information with them if this is relevant to their work.
We may also share some information with our insurance company.
If you have unpaid fees while you are staying or studying with Student Xpress, we may share information about this with other educational establishments to which you intend to go. Your fee payer may also be contacted.
If you or your child leave us to access accommodation and educational services from another provider, we may need to provide that provider with information about you. For example, details of family circumstances for safeguarding reasons.
We may share information about you with others in your family, such as another parent or step-parent. For example, where this is part of our obligation to take care of a child as part of our wider legal and regulatory obligations, or in connection with fee payment.
We may need to share information if there is an emergency, for example, if you have an accident whilst using our accommodation and educational services
OUR LEGAL GROUNDS FOR USING YOUR INFORMATION
This section contains information about the legal basis that we are relying on when handling your information.
This means that the processing is necessary for legitimate interests except where the processing is unfair to you. Student Xpress relies on legitimate interests for most of the ways in which it uses your information.
Specifically, Student Xpress has a legitimate interest in:
- Providing accommodation and educational services to you;
- Safeguarding, promoting your health and safety and promoting your welfare;
- Promoting the objectives and interests of Student Xpress.
- Facilitating the efficient operation of Student Xpress;
- Ensuring that all relevant legal obligations of Student Xpress are complied with.
- In addition your personal information may be processed for the legitimate interests of others.
If you object to us using your information where we are relying on our legitimate interests as explained above please speak to the Privacy Manager.
Necessary for a contract
We will need to use your information in order to perform our obligations under our contract with you, or contract you have entered with an agent for whom we are providing the required services. For example, we need the name and contact details of your next of kin in case of emergency, and require the contact details of the legal guardian for under 18 students so that we can update parents on their child’s progress and contact them if there is a concern.
Where Student Xpress needs to use your information in order to comply with a legal obligation- for example to report a concern to Children’s Services, we may also have to disclose your information to third parties such as the courts, the local authority or the police where legally obliged to do so.
For example, to prevent someone from being seriously harmed or killed.
Student Xpress considers that it is acting in the public interest when providing accommodation and educational services.
Student Xpress must also comply with an additional condition where it processes special categories of personal information. These special categories are as follows: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information, and information about sex life or orientation. In most cases Student Xpress will not process any of the information above, however religious beliefs may be processed where we are providing food appropriate for a particular religious group, health information/ mother tongue may be processed where it allows us to promote your safety, and mother tongue/country of origin is used to promote your education since it is useful for teachers to best plan their courses to meet student needs.
Substantial public interest
The processing is necessary for reasons of substantial public interest.
To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisers and insurers.
This includes medical treatment and the management of healthcare services.
We may ask for your consent to use your information in certain ways. If we ask for your consent to use your personal information, you can withdraw this consent at any time. Any use of your information before you withdraw your consent remains valid. Please speak to the Privacy Manager if you would like to withdraw any consent given.
AS DATA PROCESSOR RATHER THAN CONTROLLER
For instances where your primary relationship is with an agent or other company which has selected/advised Student Xpress to provide contracted services, Student Xpress serves as the data processor. This means that we will only process your data in order to provide the contracted services. Should you wish Student Xpress to process your information in any way beyond this (for example you would like us to share your graduation photo on social media), this must have been agreed with the data controller.
SENDING INFORMATION TO OTHER COUNTRIES
We may send your information to other countries where:
- we store information on computer servers based within the EEA.
- The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here: http://ec.europa.eu/justice/data- protection/internationaltransfers/adequacy/index_en.htm
If the country that we are sending your information to is not on the list or is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland) then it might not have the same level of protection for personal information as there is in the UK.
HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as we need to in order to provide the services that you or your agency have contracted us for. Our core business is accommodation and educational services .
We will keep some information after you have left Student Xpress, for example, so that we can find out what happened if you make a complaint. We will also keep some of your information in case you return to study with Student Xpress and potentially to advise you of offers for accommodation and educational services similar to ones you have accessed in the past. In normal circumstances we will delete all of your data after 6 years.
In exceptional circumstances we may keep your information for a longer time than usual, but we would only do so if we had a good reason and only if allowed to do so under data protection law.
We can keep information about you for a very long time or even indefinitely if we need this for historical, research or statistical purposes. For example, if we consider the information might be useful if someone wanted to write a book about Student Xpress.
WHAT DECISIONS CAN YOU MAKE ABOUT YOUR INFORMATION?
From May 2018 data protection legislation gives you a number of rights regarding your information. Some of these are new rights whilst others build on your existing rights. Your rights are as follows:
- If information is incorrect you can ask us to correct it;
- you can also ask what information we hold about you, and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to;
- you can ask us to delete the information that we hold about you in certain circumstances. For example, where we no longer need the information. In such cases we may keep sufficient information to ensure that you will not be re-added to our system in the future;
- you can ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer;
- our use of information about you may be restricted in some cases. For example, if you tell us that the information is inaccurate, we can only use it for limited purposes while we check its accuracy;
The Privacy Manager can give you more information about your data protection rights.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure servers within the EEA and we will take reasonable steps to protect your information including without limitation:
- installing a secure firewall
- using antivirus protection software
- encrypting data
- carrying out regular back-ups
FURTHER INFORMATION AND GUIDANCE
The Privacy Manager is the person responsible at Student Xpress for managing how we look after personal information and deciding how it is shared. The Privacy Manager can be contacted by email: email@example.com (subject matter PRIVACY) or telephone: 00 44 (0)1772 369349.
Like other organisations we need to keep your information safe, up to date, only use it for what we said we would, destroy it when we no longer need it and, most importantly, treat the information we get fairly.
Please speak to the Privacy Manager if:
- you object to us using your information for marketing purposes e.g. to send you information about Student Xpress products. We will stop using your information for marketing purposes if you tell us not to;
- you would like us to update the information we hold about you;
- you would prefer that certain information is kept confidential.
If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner’s Office – https://ico.org.uk