At International House Torquay, we understand our responsibilities with regards to the types of personal information we collect and use throughout our business in order to deliver our English Language Learning services. We’d like to tell you as clearly and simply as possible how we look after this information.

When we talk about data and personal data in this Privacy Policy, we mean personal data which identifies you or which could be used to identify you such as your name and contact details. It may also include information about how you use our website.

For students booking a course directly with International House Torquay (via the website or over the phone) – The school is responsible for your data. Our registered address is 15 St Marychurch Road, Torquay, TQ1 3HY. We are registered as a company in England and Wales under company number 08737177. We are the data controller of the data which we collect from you, and as such we determine how your personal data is collected and the purposes for which your personal data is used.

Our EU GDPR Representative is: Rickert Rechtsanwaltsgesellschaft mbH. Address: Colmantstraße 15, 53115 Bonn, Germany. art-27-rep-torquay@rickert.law

For students booking a course through an ETO – the ETO is the controller and is primarily responsible for how your information is collected and used. In this instance the school acts as an independent controller which means that we receive the information about you from the ETO in order to deliver the services they or you have requested and we keep this data, adding to it where necessary, until the course has come to an end. When the course is finished, International House Torquay becomes the processor and follows the instructions of the ETO as to what we do with your data.

ETO – Educational Tour Operator (commonly known as an agent).

Personal data we collect about you:
• Your full name, date of birth and contact details (email address, mobile number)
• Gender and nationality
• Next of kin and emergency contact details
• Proof of identity, passport number and visa (if applicable)
• Sensitive information about you and about your health (see information below about ‘sensitive personal data’)
• Information about any allergies or medical conditions
• Communication we have with you (emails, letters, messages sent to us through our social media platforms, feedback)
• Information about you, your location and how you use our website

Sensitive personal data
Certain kinds of personal data, such as data about your racial or ethnic origin, your physical or mental health or your religious beliefs are special categories of personal data which by law require additional protection. We try to limit the circumstances in which we collect sensitive personal data of this kind, but we do collect and process it when for example:
• You have requested special assistance
• You have requested a special meal type which implies or suggests your religion (e.g. a halal diet) or a health issue (e.g. a gluten-free meal).
If we ask you for this kind of information we will specify what we need it for at the time we ask for it. We need your explicit consent to collect and process this data, but in the case of health information, it will be very difficult for us to safeguard your wellbeing if you do not permit us to do so.

Students under the age of 18
We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a parent/guardian to collect this information through our Parental Consent Form. As part of this process, we request special category data relating to the health of the child, which we manage through Vital Interest.
We also gain consent from parents/guardians for the use of photos or video taken during their child’s course through the Parental Consent Form.

Who has access to your personal data?
We are dedicated to ensuring that personal data is accessible only to those individuals who require it to fulfil their responsibilities or the school’s obligations. Access is strictly limited to the specific data necessary for each individual’s role. This means the following people may have access to some or all of your data:
• The School Director and the Director / Owner
• Members of the Administration Team (including Admissions Officer, Finance Administrator, Accommodation Officer, Director of Studies, Assistant Director of Studies, Quality Assurance Manager, Finance Administrator Office Administrator, Activity Leaders and Social Programme Organiser)
• Teaching staff

Who do we share your personal data with outside of the school?
In order to fulfil our regulatory and contractual obligations we will need to share your personal data with third parties outside of the school. We share some of your data with the following categories of third parties, but only where strictly necessary, and we ensure that we only share the minimum amount. We communicate clearly with the following parties the need for them to take as much care with your information as we do:
• ETOs – Educational Tour Operators (commonly known as an agents)
• Quality Standard Inspectorates including The British Council, Quality English, IALC, International House World, EAQUALS
• Hotels and homestay providers
• Government Enforcement Agencies including The Home Office, Immigration, The Police
• Taxi & airport transfer companies
• Medical Professionals
• Data analytics companies

How long do we retain your personal data?
We will retain all your personal data for the duration of your contract and then for a further 5 years to enable us to meet our regulatory and legal obligations; to ease administration should you wish to return to undertake further studies; and to keep you up to date with news from International House Torquay which may be of interest to you. After 5 years all records will be deleted.
We may send you marketing communications by email if you have indicated that you are happy to receive such emails.
You can always opt out of receiving marketing emails by clicking on the unsubscribe link which we include in all our marketing materials.
Please note that if you ask us to stop sending marketing emails, we will keep the smallest possible amount of your personal information and your request so that we can make sure you are excluded from any future emails.

Personal data we collect about you:
• Full Name
• Address
• Contact telephone numbers
• Contact email address
• Bank details
• Contract
• Risk Assessments on your property
• Ages of all residents
• DBS

Who has access to your personal data?
We are dedicated to ensuring that personal data is accessible only to those individuals who require it to fulfil their responsibilities or the school’s obligations. Access is strictly limited to the specific data necessary for each individual’s role. This means the following people may have access to some or all of your data:
• The School Director and the Director / Owner
• Members of the Administration Team (including Admissions Officer, Finance Administrator, Accommodation Officer, Director of Studies, Assistant Director of Studies, Quality Assurance Manager, Finance Administrator Office Administrator, Activity Leaders and Social Programme Organiser)

Who do we share your personal data with outside of the school?
In order to fulfil our regulatory and contractual obligations we will need to share your personal data with third parties outside of the school. We share some of your data with the following categories of third parties, but only where strictly necessary, and we ensure that we only share the minimum amount. We communicate clearly with the following parties the need for them to take as much care with your information as we do:
• ETOs – Educational Tour Operators (commonly known as an agents)
• Students and their parents/guardians
• Quality Standard Inspectorates including The British Council, Quality English, IALC, International House World, EAQUALS
• Government Enforcement Agencies including The Home Office, Immigration, The Police
• Civil & Corporate – DBS Checking Service
• Taxi & airport transfer companies
• Data analytics companies

How long do we retain your personal data?
We will retain all your personal data for the duration of your contract and then for a further 2 years to enable us to meet our regulatory and legal obligations. After 2 years all records will be deleted.

Personal data we collect about you:
• Full Name
• Company Address
• Contact telephone numbers
• Contact email address
• Bank details

Who has access to your personal data?
We are dedicated to ensuring that personal data is accessible only to those individuals who require it to fulfil their responsibilities or the school’s obligations. Access is strictly limited to the specific data necessary for each individual’s role. This means the following people may have access to some or all of your data:
• The School Director and the Director / Owner
• Members of the Administration Team (including Admissions Officer, Finance Administrator, Accommodation Officer, Director of Studies, Assistant Director of Studies, Quality Assurance Manager, Finance Administrator Office Administrator, Activity Leaders and Social Programme Organiser)

Who do we share your personal data with outside of the school?
In order to fulfil our regulatory and contractual obligations we will need to share your personal data with third parties outside of the school. We share some of your data with the following categories of third parties, but only where strictly necessary, and we ensure that we only share the minimum amount. We communicate clearly with the following parties the need for them to take as much care with your information as we do:
• Quality Standard Inspectorates including The British Council, Quality English, IALC, International House World, EAQUALS
• Government Enforcement Agencies including The Home Office, Immigration, The Police

How long do we retain your personal data?
We will retain all your personal data for the duration of your contract and then for a further 5 years to enable us to meet our regulatory and legal obligations. After 5 years all records will be deleted.
We may send you marketing communications by email if you have indicated that you are happy to receive such emails.
You can always opt out of receiving marketing emails by clicking on the unsubscribe link which we include in all our marketing materials.
Please note that if you ask us to stop sending marketing emails, we will keep the smallest possible amount of your personal information and your request so that we can make sure you are excluded from any future emails.

We can only use your personal data if we have a legal basis for doing so. According to the law, we can only use your data for one or more of these reasons:
• To fulfil a contract we have with you, or
• If we have a legal duty to use your data for a particular reason, or
• When you consent to it, or
• When there is a legitimate business interest.
Another way of describing legitimate interest is fair and balanced reasons for processing data. We would use this reason for processing your personal data if we have a necessary business activity or if we believe that you would benefit from us processing the data in this way.

We protect your personal data against unauthorised access, accidental loss, corruption or destruction.
We use technical measures such as secure servers and password protection to protect your data and the systems they are held in.

You have the following rights in relation to the personal data we hold on you:
• the right to be informed about the data we hold on you and what we do with it;
• the right of access to the data we hold on you;
• the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
• the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
• the right to restrict the processing of the data;
• the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
• the right to object to the inclusion of any information;
• the right to regulate any automated decision-making and profiling of personal data.

To raise any objections or to exercise any of your rights, you can email the School Director on georgian@ihtorquay.uk or write to us at FAO GDPR LEAD, International House Torquay, 15 St Marychurch Road, Torquay, TQ1 3HY.

When you get in touch, we respond promptly without undue delay. We may ask you to verify your identity before we provide any information to you.

If we need to send any information outside of the EEA, it will only be done with the proper legal protections or permissions being in place.

International House Torquay is a company registered in England with the number 08737177. Our address is 15 St Marychurch Road, Torquay, TQ1 3HY. The telephone number is 01803 295576. We are registered as a data controller with the Information Commissioner’s office – our registration number is ZA321601.

If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority – details of which are given below:
Information Commissioner’s Office
https://ico.org.uk/concerns/
Telephone: +44 303 123 1113