Privacy Policy

Version: January 2023

Contents:

  1. General
  2. Students
  3. Tutors and Suppliers
  4. Agents and Educational Tour Operators

1. General

1.1 Our principles

1.1.1 We do our very best to protect your privacy by using security technology appropriately. This means:

  • We make sure that we have appropriate security measures in place to protect your personal information.
  • We make sure that when we ask another organisation to provide a service for us, they also have appropriate security measures.

1.1.2 We will respect your privacy.

1.1.3 We will collect and use personal information only if we have your permission. We collect different types of information from our clients and suppliers for three reasons:

  • To enable us to provide the services we are contracted to deliver;
  • To help us to monitor and improve the services we offer;
  • If we have specific permission, to market our services to them.

1.1.4 We will be clear as to what information about you we will collect and how we will use it.

1.1.5 We will use your personal information only for the purposes for which it was originally collected.

1.1.6 If we or our service providers transfer any information out of the UK it will only be done with the relevant protections (as stated under UK law) being in place.

1.1.7 Throughout this policy, InTuition Languages Ltd is referred to as ‘we’ or ‘us’. Under each section (Students, Tutors and Suppliers and Agents and Educational Tour Operators), the use of ‘you’ refers to the relevant counter-party.

1.2 Your Data Access Rights

1.2.1 You have a right of access to personal data held by us as a data Controller. This right may be exercised by emailing us, telephoning us, or contacting us by mail or via social media.

1.2.2 Your right of access includes the following elements:

  • Your right to be informed of what personal data of yours we hold
  • Your right to request correction of this data
  • Your right to request deletion of this data
  • Your right to object to the inclusion of this data
  • Your right to request that processing of your data be restricted
  • Your right to data portability
  • Your right to data transfer

1.2.3 Further information about your data access rights can be found on the Information Commissioner’s Office website, at https://www.ico.org.uk. Any data access requests should be directed to our Data Protection Manager, who will respond to you within one calendar month at the latest. To update your personal data submitted to us, you may email us at learn@intuitionlang.com.

1.3 Contact Details

Email: learn@intuitionlang.com

Telephone: +44 (0)207 739 4411

Address: Data Protection Manager, InTuition Languages Ltd, Business Central, 2 Union Square, Central Park, Darlington, DL1 1GL, UK

1.4 EEA Data Representative

Email: art-27-rep-intuition@rickert.law

Rickert Rechtsanwaltsgesellschaft mbH, Colmantstraße 15, 53115 Bonn, Germany

1.5 Policy Review Dates

Date

Reviewed by

Notes

May 2018

 Director Minor review to ensure GDPR compliance
December 2018 Director Changes made to incorporate Vis-a-Vis online programmes

October 2019

Director

Changes made in preparation for the UK’s exit from the EEA in Jan 2021

June 2021

CEO

Minor review and post-Brexit clarifications

January and March 2022

CEO

Addition of clauses relating to the recording of data for teaching observations

June 2022

CEO

Addition of clauses relating to split bookings

November 2022

CEO

Addition of clauses relating to J2J

January 2023

CEO

Addition of clauses relating to student identity verification

 

2. Students

How we use your information

2.1. What information do we collect?

2.1.1 We collect information on you:

  • When you make an enquiry or application for a course, either through the website or via email or phone, and
  • When you formally confirm a course enrolment, and
  • When data is passed to us by an Agent for the processing of an enquiry, application or enrolment. If you are enquiring, applying or enrolling on one of our courses via an appointed Agent, their Privacy Policy will also determine how your personal data is collected and processed by them.
  • If a lesson(s) during your course is recorded for academic management purposes

If you make (or your appointed Agent makes) a basic enquiry for more information about our courses, we require you to provide the following information:

  • Your name
  • Your email address
  • Your telephone number

If you choose to make a full course application, we require some or all of the following additional information in order to match you with a suitable tutor and provide you with an accurate course quote:

  • Your home address, date of birth, sex and nationality
  • Information regarding your current target language ability
  • Your interests and hobbies
  • Any relevant special needs or requirements

When we have referred a suitable tutor to you, and you have accepted and confirmed your course, we may require further information to finalise your programme of study:

  • Your travel details
  • Your next of kin contact email address and telephone number

2.1.2 Information which must be provided is highlighted on the relevant form(s).

2.1.3 By submitting your information to us for the purposes of making an enquiry or applying for a course, you grant us consent to use your personal data for the purposes of answering your enquiry or arranging your requested study programme. You may withdraw your consent at any time.

2.1.4 After you have made an enquiry or application, and with your explicit permission, we may send you marketing communcations. Newsletters may be personalised based on your enquiry / application requirements. You may withdraw your consent at any time.

2.1.5 If a lesson observation take places during your course, your image may be video recorded alongside your tutor's. Recordings are viewed only by our academic management team, and not used for any wider training or promotional purpose.

2.1.6 We require all students to verify their identity prior to their Course Start Date. This may be done by the student's appointed Agent, or directly by InTuition Languages. Any data used for identity verification purposes (copies of passports, driving licences or other forms of ID) is retained only until the verification process is complete.

2.2 Ongoing data retention

2.2.1 To satisfy UK government requirements, we retain details of all payments made by you with records of invoices and other relevant documents.

2.2.2 We retain records of all courses which we teach for British Council accreditation purposes. This data includes the names and ages of students and their precise course of study (course type and dates) followed. We retain this information as an obligation of our accreditation as a British Council school.

2.2.3 If you have given consent to be contacted for marketing purposes, we may retain all data collected in order to effectively tailor the messages we send to you. You may opt-out of receiving marketing messages at any time.

2.2.4 All of your data which we retain is stored on servers physically located in the UK or EEA.

2.3 Whom we share data with

2.3.1 After you enrol on a course with us, we will share relevant information with selected tutors who are registered with us. This is so that they can decide whether they wish to teach you the requested course. The information we share includes your name, age, gender, English level, requested course type, duration and dates, and any voluntary information you have provided during the enquiry / application process which may be relevant. We do not share next of kin information.

  • If you have applied for a course in the UK or an online EFL course, your data will be controlled by us and processed by a tutor or tutors under the requirements of UK GDPR. To ensure that we and our tutors are compliant under EU GDPR when controlling and processing your data, we have appointed a Data Representative within the EEA. Details can be found at the top of this policy.
  • If you have applied for a course outside the UK and EEA (for example, in the USA, Canada or Australia), your data will be controlled by us under the requirements of UK GDPR and processed by a tutor or tutors under the requirements of the data protection regulations in their country. To ensure that the standards of UK GDPR are maintained in these circumstances, we sign individual Standard Contractual Clauses with tutors and / or local organisers who live outside the UK and EEA.
  • If you have applied for a course in the EEA or an online MFL course, your data will be controlled by us under the requirements of UK GDPR and processed by a tutor or tutors under the requirements of EU GDPR.

2.3.2 Once you have confirmed your course, we provide the confirmed tutor(s) with your email address, phone number, home address, and any travel information you have provided. For J2J courses or any other programme where you share tuition and / or accommodation with a third party, your email address and phone number will also be shared with the relevant third party at this time. The third party will act as a processor of your data under UK GDPR.

2.3.3 Tutors are not permitted to use your contact information for any purposes other than those immediately related to your course of study with them.

2.3.4 We will not share your personal information with any other organisation for marketing purposes unless you have provided consent. You can withdraw your consent at any time.

2.3.5 We may use service providers to help us manage our commercial operations, some of whom may be based outside the UK and EEA. Any organisations which access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and adhere to any data protection and privacy laws which apply.

2.3.6 Some of our webpages use plug-ins from other organisations (such as the ‘Facebook Recommend’ function). These other organisations may use information about your visit to our websites on their pages. If you browse these pages while still also logged in to your account with us, information they collect may be connected to your account on their site. For more information on how these organisations use information, please read their privacy policies.

2.4 Data shared with you

2.4.1 Once a tutor whom we have contacted on your behalf has indicated that they would be interested in hosting and / or teaching you, we will send you their profile. The profile includes personal information regarding the teacher’s name, general location, family, professional experience and qualifications.

2.4.2 When you confirm a course, we will send you additional information, including the tutor’s email address, phone number and home address.

2.4.3 You act as a Processor of this data under UK GDPR. You must not use any personal data shared with you for any purposes other than those directly necessary for the organisation and study of your InTuition Languages course.

2.5 Google Analytics

2.5.1 We use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)

  

3. Tutors and Suppliers

How we use your information

3.1 What information do we collect?

3.1.1 We collect information on you:

  • when you make an enquiry or application about registering as a tutor, either through the website or via email, phone or social media, and
  • when you formally register as a tutor following an enquiry or application
  • When making a video or audio recording for the purpose of observing your teaching practise. Recordings are viewed only by our academic management team, and not used for any wider training or promotional purpose.

If you make a basic enquiry for more information about registering as a tutor, we require you to provide the following information:

  • Your name
  • Your email address
  • Your telephone number

If you then choose to proceed with your registration, we require the following additional information in order to create your profile (which is shared with potential students) and ensure compliance with British Council and International House requirements:

  • Your date of birth, sex and home address
  • Your current or most recent occupation
  • Details of your academic and ELT qualifications and experience, including proofs or certificates where applicable
  • Details of your home (including its size, location and facilities)
  • Details of your personal interests
  • Details of family members or other individuals living with you, including their names, dates of birth, interests and occupations
  • Photographs of your home and family (family photographs are optional)
  • Proof of identity and of your right to work in your country of residence
  • Details of two professional referees who consent to be contacted by us our your behalf
  • Your bank details, in order to facilitate payment for courses undertaken

3.1.2 We ask students to provide feedback on their tutor(s). This feedback includes opinions about you, which is retained for marketing and quality management purposes.

3.1.3 If you wish to register to host under 18s, we will also require that you provide further information as outlined in our separate Safeguarding Policy and Procedure. This includes DBS / police check certificates.

3.1.4 This information is used to build your profile which is sent to prospective students on an as-required basis and which may be used in general marketing campaigns.

3.1.5 By submitting your information to us for the purposes of making an enquiry or registering as a tutor, you grant us consent to use your personal data for the purposes of answering your enquiry or processing your registration. You may withdraw your consent at any time.

3.1.6 After you have made an enquiry for more information about registering as a tutor, and with your specific consent, we may send you marketing communications. Newsletters may be personalised based on your location and professional specialisation(s). At any time you can withdraw your consent to receive these communications.

3.1.7 By completing a full registration as a host tutor you provide us with consent to contact you both with details of potential courses and with information bulletins regarding training and social opportunities, and general school updates.

3.1.8 As outlined in our Observations Policy, all tutors are required to undergo periodic observation and assessment by a member of our Academic Management Team. Observations are conducted asynchronously: tutors use Zoom or alternative video recording software to record themselves and their students during the lesson in question. The recording is then sent to us for evaluation and feedback. Once we have received a recording from you, we act as Controller of that data. We use observation recordings only for academic management purposes and not for any broader commercial application. Recordings are stored on our data servers in the UK.

3.2 Ongoing data retention

3.2.1 To satisfy UK government requirements, we retain details of all payments made to you along with records of invoices and other relevant documents.

3.2.2 Should we not receive any communication from you over a five year period, we will contact you to check whether you still wish to remain registered as a tutor. If you do not respond to this enquiry, we will permanently delete all of your personal data with the exception of that data necessary to maintain internal records of courses delivered: your name and email address. We are obliged to retain this data for British Council accreditation purposes.

3.3.3 If you no longer wish to remain registered with us, you may cancel your registration at any time. We will permanently delete all of your personal data with the exception of that data necessary to maintain internal records of courses delivered: your name and email address. We are obliged to retain this data for British Council accreditation purposes.

3.3 Whom we share data with

3.3.1 The information which you provide to us during the registration process is shared with prospective students during the course placement process.

3.3.2 In each instance where we feel you would be a suitable tutor for a specific course, we will seek your permission to be recommended (i.e. for your profile to be sent to the student or their agent) before doing so.

3.3.3 The information provided on your profile does not include your address, phone number, email address or surname. It focuses on your personal and professional background relevant to the course requested. It also includes feedback from any previous students who have consented for their feedback to be shared. You may access and review the data presented on your profile at any time.

  • If a prospective student lives in the UK, your data will be shared with the student and / or their appointed agent under the requirements of UK GDPR. To ensure that we and our tutors are compliant under EU GDPR when controlling and processing your data, we have appointed a Data Representative within the EEA. Details can be found at the top of this policy.
  • If a prospective student lives in the EEA, your data will be shared with the student and / or their appointed agent under the requirements of EU GDPR equivalency with UK GDPR.
  • If a prospective student lives outside the UK and EEA, your data will be shared with the student / and or their appointed agent under the terms of a specific Standard Contractual Clause (SCC) agreement, unless the UK recognises the data protection laws in the student’s host country as being equivalent to UK GDPR.

3.3.4 Once a student confirms a course, we share further information with them and / or their appointed Agent. This includes your full name and address, contact phone number, and email address.

3.3.5 Students and their Agents are not permitted to use your contact information for any purposes other than those immediately related to their course of study with you.

3.3.6 If you are teaching a 'split course' (i.e. one with more than one tutor), your email address and phone number will be shared with the other tutor(s) concerned, in order to allow communication between tutors for academic discussion, the making of transfer arrangements, setting arrival and departure times, and anything else relevant to the management of the student's programme of study.

3.3.7 We will not share your personal information with any third parties for marketing purposes unless you have given us your consent. You may withdraw your consent at any time.

3.3.8 Some of our webpages use plug-ins from other organisations (such as the ‘Facebook Recommend’ function). These other organisations may use information about your visit to our websites on their pages. If you browse these pages while still also logged in to your account with us, information they collect may be connected to your account on their site. For more information on how these organisations use information, please read their privacy policies.

3.4 Data shared with you

3.4.1 When contacting you with regards to a potential booking, we will share certain student information with you: the student’s name, age, course requirements and preferences.

3.4.2 Once a student confirms a course of study with you, we will send you further information: their email address, phone number and home address.

3.4.3 When teaching a 'split course', we will also send you the email addresss and phone number for other tutors involved in the delivery of the programme in question.

3.4.5 Under UK GDPR and EU GDPR, you are a Processor and responsible for the security of this data. You must not use the information provided for any purpose other than those directly necessary for the student’s course of study with you. You must not share any student data with any other third parties. If you live outside the UK and EEA, we will ask you to sign a Standard Contractual Clause agreement prior to student data being transferred to you.

3.5 Google Analytics

3.5.1 We use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)

3.6 Legal information and how to contact us

3.6.1 If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the Data Protection Manager at InTuition Languages Ltd, Business Central, 2 Union Square, Central Park, Darlington, DL1 1GL, UK. Complaints will be dealt with by the Data Protection Manager, and will be responded to within 30 days at the latest. If you are not satisfied with the way your complaint was handled, you may be able to refer your complaint to the UK Information Commissioner’s Office (ICO).

4. Agents and Educational Tour Operators (ETOs)

4.1 Registering as an Agent or ETO

4.1.1 If you choose to register with us as an Agent or ETO, we will require you to provide certain information regarding your organisation:

  • Your company name and contact details (phone, email and address)
  • The name(s) of relevant staff members (manager and student counsellors) and their contact information

4.1.2 We act as controller of this data under UK GDPR. It is retained securely on our computer systems in the UK.

4.2 Ongoing data retention

4.2.1 To satisfy UK government requirements, we retain details of all payments made to you or received from you, along with records of invoices and other relevant documents.

4.2.2 Within the exception of financial information, if you decide that you no longer wish to represent our school as an Agent or ETO, we will delete or anonymise all retained data on request. You may make this decision at any time.

4.3 Data you share with us

4.3.1 When you enrol a student with us, we become the Controller of that student data.

4.3.2 If you are located inside the EEA, you will require a Standard Contractual Clause (SCC) agreement to be in place with us before any transfer of student data takes place. If you are located outside the EEA, your local regulations may also require an SCC agreement to be in place.

4.3.3 During the process of an enquiry, application or enrolment, you must share with us certain student data in order to allow us to recommend a suitable host tutor.

4.3.4 The data required is outlined on our enquiry and application form(s). In all cases, we require the following:

  • Student’s name and date of birth
  • Student’s course requirement (location, duration, intensity, type)
  • Student’s current target language level
  • Student’s special educational or hosting needs, if applicable

4.3.5 Once a student has confirmed their enrolment, we also require the following information:

  • Student’s mobile phone number
  • Student’s email address
  • Student’s next of kin details and contact information

4.3.6 Throughout the enquiry, application and enrolment process, and during a student’s course of study, we act as a Controller of the student’s data. We do not use student information for any purposes not directly necessary for organising of their course of study. We share student information with tutors in accordance with the policies outlined under Tutors in this Policy.

4.4 Data we share with you

4.4.1 We Control tutor data under the requirements of UK GDPR. You Process tutor data under the data protection requirements in your country.

4.4.2 Once we receive a complete enrolment from you, we select a tutor whom we consider a suitable match, considering the student’s specific requirements.

4.4.3 We send you the tutor’s profile, which contains includes information regarding the host tutor’s name, general location, family, professional experience and qualifications. You share this information with students according to the principles outlined under Students in this policy, and your own privacy policy.

  • If you are located in the UK, tutor data will be transferred to you under the requirements of UK GDPR.
  • If you are located in the EEA, tutor data will be transferred to you under the requirements of EU GDPR through UK GDPR equivalency.
  • If you are located outside the UK and EEA, tutor data will be transferred to you under the terms of a Standard Contractual Clause (SCC) agreement. This agreement must be signed before transfer of data can take place.

4.4.4 When you confirm a course, we also send you the tutor’s email address, phone number and home address. Again, you share this information with students according to the principles outlined under Students in this policy, and your own privacy policy.

4.4.5 You are responsible for the security of this data under UK GDPR, EU GDPR or the terms of an SCC agreement. You must not use the information provided for any purpose other than those directly necessary for organising a student’s course of study. You must not share any tutor data with any third parties, except the student themselves.