SPM Development Services Ltd
October 2022
Introduction
Your privacy is important to us. This privacy policy explains how we maintain the privacy of your personal data and explains your legal rights and our legal obligations in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) 2018 (collectively, the “GDPR Regulations”).
It explains what information we collect about you, the lawful basis and purpose for which we collect the information, how we use your information and protect its privacy and under what circumstances we disclose it. This notice also provides further information on your rights under GDPR and the actions you can take to address any concerns you may have. Please read it carefully. If we update this policy, we will post any changes on our website.
Who are we?
In this policy, “we”, “our” or “us” refers to SPM Development Services Ltd. The legal information for which is:
SPM Development Services Ltd. 90 East India Way, Croydon, Surrey, CR0 6RZ. Our website is http://spmdevelopmentservices.co.uk/
What information do we collect about you?
We collect personal data about students, their parents, legal guardians or other persons that arrange for tuition/mentoring on their behalf (i.e., clients), tutors that wish to provide tuition on our behalf, and our mentors/staff.
Parents/Students: The personal data we hold
Personal data that we may collect, use and store about parents and students may include, but is not restricted to:
- Parent / Guardian’s name, email address and contact number
- Student’s name and date of birth
- Student’s school of attendance
- Information about the student’s tuition needs
- Student’s assessment report
Why/ how we use this data
We use this data to:
- Provide tailored tuition
- Communicate with parent / guardian
How we store this data
We store this data in both digital and paper-based formats.
Safeguarding
As a professional company working with children, we have a duty of care towards any child/young person we work with. If we suspect the abuse of a child/young person we are working with, we are obliged to refer our concerns to a relevant safeguarding body.
Tutors/Mentors: The personal data we hold
We process data relating to those applying to work for our organisation. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Contact details
- Copies of right to work documentation
- References
- Evidence of qualifications
- Employment records, including work history, job titles, training records and professional memberships
We may also collect, store and use information about you that falls into “special categories” of more sensitive personal data. This includes information about (where applicable):
- Race, ethnicity, religious beliefs, sexual orientation and political opinions
- Disability and access requirements
Why we use this data
The purpose of processing this data is to aid the recruitment process by:
- Enabling us to establish relevant experience and qualifications
- Facilitating safe recruitment, as part of our safeguarding obligations towards pupils
- Enabling equalities monitoring
- Ensuring that appropriate access arrangements can be provided for candidates that require them
Note that the GDPR Regulations have additional requirements in place that must be met in order to store personal data relating to criminal records background checks (specifically in our case, an Enhanced Disclosure & Barring Service (DBS) Certificate). We are entitled to request and store this personal data as we are supplying tuition/mentoring services to children and young people. We also require our tutors/mentors to register for the DBS update service and provide us with permission to use the update service to check that their Enhanced DBS Certificates remain valid.
How we store this data
Personal data we collect as part of the job application process is stored in line with our data protection policy.
Disclosure of your information
We will never sell, trade, or disclose any personal information to any third party (other than to any of our service providers, and only to the extent necessary to provide such service and in cases where we are satisfied with their privacy policies and procedures), other than as required by law, court order or any governmental or regulatory authority, or in terms of our Safeguarding and Child Protection Policy.
Our retention of your information
We retain client information for a period of 10 years after tuition/mentoring services have ceased. We retain student information until the student turns 26 years’ old (this is to enable us to retain information on students that may be covered under the Special educational needs and disability code of practice: 0 to 25 years’). We retain tutor/mentor information for a period of 5 years after the tutor/mentor has ceased to provide services for us. We retain staff data for a period of 3 years after the staff member has ceased to work for us.
Your data protection rights:
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate.
- You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.