The School aims to deal with complaints fairly and promptly as soon as they arise. Many issues are rapidly solved by early informal discussion with members of staff or the Headmaster: open communication is strongly encouraged and welcomed by the School.

1.  New College School Complaints Procedure is available in the information pack for new pupils, in annual parents’ guides and for consultation in the School Office. The number of complaints registered under the formal procedure during the preceding school year is also available from the School Office.

2.  Informal Resolution (stage 1): A complaint or concern may first be made informally, with a boy’s teacher, form teacher, a member of the SLT, or the Headmaster. All complaints will normally be acknowledged within five school working days (i.e. Monday-Friday during term time; excluding bank holidays). An informal complaint may be made in writing; this means that not all written complaints or expressions of concern (e.g. by email) will automatically be considered to be formal complaints. If there is a lack of clarity as to the complainant’s intentions, follow-up clarity will be requested by the Headmaster. The member of staff in receipt of the complaint will make a written record of all concerns and complaints and the date on which they were received. 

A written record of all complaints is kept by the School, whether they are resolved at the informal stage, formal stage, or proceed to a panel hearing, including any action taken by the School regardless of whether the complaint is upheld. At the School’s discretion, additional records may be kept which may contain the following information: date when issue was raised; name of parent; name of pupil; description of the issue; records of all investigations (if appropriate); witness statements (if appropriate); name of member(s) of staff handling the issue at each stage; copies of all correspondence on the issue (including emails and records of conversations, including phone conversations).

Should the matter not be resolved within ten school working days, or in the event that a satisfactory resolution cannot be reached, the complainant will be advised to proceed with their complaint in accordance with point 3 below within thirty days (including weekends and bank holidays). 

3.  Formal Resolution (stage 2): If parents are not satisfied with the response to the complaint, or if they feel that the matter is sufficiently serious to bypass the informal complaint stage, they may put the complaint formally in writing to the Headmaster, who will respond in writing to parents as soon as possible indicating how the matter has been or is to be investigated and details of any outcomes. The Headmaster will decide, after considering the complaint, the appropriate course to take. Complaints will usually only progress to the formal stage after first being at least considered at the preliminary stage and only then if the complainant intends to escalate a matter to the formal stage. In most cases, the Headmaster will meet or speak to the complainant, normally within seven school working days of receiving the complaint. If possible, a resolution will be reached at this stage. The Headmaster may need to carry out further investigations; written records of all meetings and interviews held in relation to the complaint will be kept. If appropriate, he will convene a meeting of the parties concerned within two weeks, unless school/university term means a longer period is required. Once the Headmaster is satisfied that, as far as is practicable, all of the relevant facts have been established, a decision will be made and parents will be informed of this decision in writing within a further seven school working days. Reasons will be given for any decision. If the complainant is still not satisfied with the decision, they should proceed to point 4 below within thirty days (including weekends and bank holidays).

4.  Panel hearing (stage 3): If the complaint is still unresolved, parents may contact the Warden of New College who, as Chair of Governors, may convene a panel hearing of at least three people who were not directly involved in previous consideration of the complaint. Where a panel hearing is convened, one person on the panel must be independent of the management and running of the school. The Warden will ensure that, unless school/university term means a longer period is required, this hearing is held within one month. For complaints about the fulfilment of EYFS requirements, the outcome must be communicated within 28 days from the time a written complaint was submitted to the Headmaster. If the panel deems it necessary, it may require that further particulars of the complaint or any related matter be supplied in advance of the hearing. Copies of such particulars should be supplied to all parties not later than five days prior to the hearing. 

 4.a. Parents should be given adequate notice of the hearing. They must be allowed to attend and be accompanied to a panel hearing (e.g. by a relative, teacher or friend) if they wish; legal representation will not normally be appropriate. If, after a panel hearing has been convened, parents decide not to attend, the panel will nonetheless consider the parent’s complaint in absentia and issue findings on the substance of the complaint.

4.b. The panel will make findings and recommendations and copies of these will be sent or emailed to the complainant, the Headmaster, the Governing Committee and, where relevant, the person who is the subject of a complaint within thirty days (including weekends and bank holidays).

5. If the complaint is against the Headmaster, the complainant should complain directly to the Chair of Governors, who is the Warden of New College (warden@new.ox.ac.uk) 

6. Under the regulations for Early Years, parents may make a complaint direct to OFSTED/ISI if they so wish.

OFSTED, Picadilly Gate, Store Street, Manchester M1 2WD 0300 123 1231; 0161 618 8524 enquiries@ofsted.gov.uk

ISI, Ground Floor, CAP House, 9-12 Long Lane London EC1A 9HA 020 76000100 info@isi.net

7. All correspondence, statements and records of complaints will be kept confidential, save that copies can be made available to the Secretary of State or a body conducting an inspection under section 108 or 109 of the Education and Skills Act 2008 should they request them, for example OFSTED/ISI when they inspect the school. We are here for your child and complainants can be assured that pupils will not be penalised for a complaint that is raised in good faith. Any personal data collected as a result of raising a complaint with the School will be kept in accordance with the School’s data protection policy and privacy notices, available on the NCS website: https://www.newcollegeschool.org/privacy-policy

8. The number of formal complaints in the latest academic year is available from the Head’s PA on request (office@newcollegeschool.org) 

Guidance for the conduct of panels to arbitrate on complaints

Introduction

• This guidance is for the use of panels set up to consider Stage 3 of the New College School Complaints Procedure or to review the decision of the Head to exclude or expel a pupil from New College School.
• It is private guidance for members of Panels and should not be provided to parents or placed on the school’s website.

Principles

• Decisions taken by the Headmaster must be reasonable and proportionate and take into account all relevant facts and circumstances and disregard irrelevant factors.  Such decisions must also be subject to review by an independent authority, which must have the right to set aside the decision or to refer it back to the Headmaster where the Headmaster’s decision falls within the bounds of what a reasonable Headmaster, acting proportionately, might have decided given all the facts.  In sum, the hearing should follow the principles of natural justice:
• Panel members should be impartial, unprejudiced, have taken no previous part in the case and have no personal interest in its result. They should not have played any part in the Headmaster’s decision. Panel members will generally be people who have held responsible positions and are used to scrutinising evidence and putting forward balanced arguments.
• Parents and the Headmaster should be informed of each other’s case and have an opportunity to challenge it.
• Both the parents and the Headmaster should be allowed to present their case without unreasonable interruption.
• Parents should be able to bring a friend or adviser with them.  However, it will be at the discretion of the Panel as to whether that person can address the hearing.
• All documents to be referred to by the parties during the hearing should be distributed to all parties (including the Panel members) in advance.
• If new material is introduced at the hearing, all parties must have time to consider it.
• The panel is, therefore, a necessary check and balance to ensure that we treat parents and pupils fairly and that the reasonable and proportionate decisions of the Head are supported and protected against reversal by external authorities.

Procedure “A”

This is the procedure that will normally be followed by the Panel and is designed to ensure that all parties have the opportunity to present their views to the Panel.

Meeting format.  The meeting will take the form of a ‘round table’ hearing, where all parties and the Panel are present in the same room throughout.  Present in the room throughout the hearing will be:

• The Panel members.
• The Clerk to the Panel (the Clerk will take notes of the meeting.  Any notes produced by the Clerk will not be verbatim and will belong to the Chair.  The Chair can authorise the release of the Clerk’s notes on condition that they remain confidential.)
• The parents who have made the complaint.
• Any person that the parents have brought as a supporter.
• The Headmaster.
• Any other appropriate member of staff.

Note: any witnesses called by any of the above parties may be asked to make their contribution and then leave rather than staying for the whole proceeding.

Suggested agenda

• Welcome and introductions by the Chair.  This will include explaining the purpose of the hearing, the process that the Panel intends to follow and ensuring that all parties have had time to consider all documents which might be referred to in the hearing.
• Parents present their complaints.  Where two parents are present, it is often more helpful if one parent undertakes the responsibility of presentation and answering of questions.
• The Panel and the Headmaster may ask questions of parents for clarification.  Questions should be put through the Chair of the Panel who can intervene if he or she thinks that questions are inappropriate or are straying into cross examination (which is not appropriate).
• The Headmaster puts his case, explaining the reasons for the decision and consideration and calling witnesses if necessary.
• The parents and Panel members may ask questions of the Headmaster for clarification.  Again such questions should be put through the Chair who can intervene as necessary.
• The Headmaster is invited to make any further relevant points.
• The parents are then invited to make any further relevant points.
• When the Panel is satisfied that it has established facts sufficient for it to make its decision, the Chair may bring the hearing to a close and inform the parties that they will be notified in writing of the decision, normally within ten working days.
• The parents and the Headmaster leave together with any witnesses, supporters or representatives.

Legal advice

If, during the hearing, parents introduce legal points on which the Panel members feel they will need advice, they will consider one of two options:

• The Panel may decide to take a careful note of points made and to consider the advice of the College’s lawyers before making their final decision; or
• If the Panel feel that an immediate response is required, they may adjourn the hearing to take telephone advice from the College’s lawyers.

Administration

The Panel will wish to ensure the following administrative issues are dealt with:

• The Chair of Governors, who convened the Panel, should also have arranged for someone to act as clerk to the Panel, to take notes and ensure all administrative arrangements have been made.  This can be the Complaints Coordinator, if one is appointed, or someone else may be given the task (such as the HR Adviser).
• The parents must have been invited with at least five days notice to attend the hearing and told of their right to be accompanied.  Legal representation is not normally appropriate.  If parents indicate that they wish to have legal advisers present at the hearing, the Chair of the Panel should consult the Bursar who can arrange for legal advice as required.  Normally, however, it will be preferable to accede to such a request.
• All documents to be considered by the Panel must have been made available to both parties at least five days before the hearing.
• A room and refreshments should be made available for the parents and their companions before the hearing.
• Any special requirements of the parents (due to disability for example) should be appropriately addressed.
• If there are witnesses, there will need to be somewhere for them to wait before being called to give evidence.
• After the Panel has reached a decision, the Chair should draft a letter setting out the considerations of the Panel, its findings and reasons for them.  Once agreed with all the members of the Panel, this letter should be despatched within ten working days of the date of the hearing.

Procedure “B”

This procedure will only be followed if, having considered all the circumstances of the case, the Panel Chair feels it is necessary in the interests of natural justice and good order to change the format of the hearing from its normal ‘open’ approach. Panel members must bear in mind that adopting this procedure, whilst not unlawful, per se, does increase the risk that, if the Panel decides not to uphold the parents’ complaint, its decision (and therefore the original decision of the Headmaster) might be reversed by an external authority if challenged further by the parents.  The weakness of the procedure is that neither party can hear the evidence of the other and so cannot challenge it. The Panel will, therefore, have to be meticulous in ensuring each side had an opportunity to answer the main points of the other’s case through the Panel.

In all cases, if the Panel Chair is minded to adopt this procedure, he/she should consult the Bursar and consider any legal advice before starting proceedings.

Meeting format.  The hearing will take the form of separate meetings by the Panel with each party.  Hence the parties will sit down with the Panel in turn to present their views and evidence.

Suggested agenda

• Welcome and introductions by the Chair.  This will include explaining the purpose of the hearing, the process that the Panel intends to follow and ensuring that all parties have had time to consider all documents which might be referred to in the hearing.
• Parents present their complaints.  Where two parents are present, it is often more helpful if one parent undertakes the responsibility of presentation and answering of questions.
• The Panel may ask questions of parents for clarification.  Questions should not stray into cross examination (which is not appropriate). The Parents leave.
• The Headmaster puts his case, explaining the reasons for the decision and consideration and calling witnesses if necessary.
• The Panel members may ask questions of the Head for clarification. 
• The Headmaster is invited to make any further relevant points.  The Headmaster leaves.
• The parents are then invited back in to the Panel room and may make any further relevant points.
• After the Panel has reached a decision, the Chair should draft a letter setting out the considerations of the Panel, its findings and reasons for them.  Once agree with all the members of the Panel, this letter should be despatched with ten working days of the date of the hearing.
• When the Panel is satisfied that it has established facts sufficient for it to make its decision, the Chair may bring the hearing to a close and inform the parties that they will be notified in writing of the decision, normally within ten working days.
• Matters concerning legal advice and administration are the same as for Procedure “A”.

Purpose of this privacy notice

This privacy notice aims to give you information on how New College School collects and processes your personal data.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data protection law requires New College School, as data controller for your data:

• To process your data in a lawful, fair and transparent way;
• To only collect your data for explicit and legitimate purposes;
• To only collect data that is relevant, and limited to the purpose(s) we have told you about;
• To ensure that your data is accurate and up to date;
• To ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
• To ensure that appropriate security measures are used to protect your data.

Controller

New College School is the controller and responsible for your personal data (collectively referred to as the School, we, us or our in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the DPO using the details set out below.

Contact details

Our full details are:      

Full name of legal entity: New College School

Name or title of DPO:  ClearComm (info@clearcomm.org)

Email address: office@newcollegeschool.org

Postal address: Savile Road, Oxford, OX1 3UA

Telephone number: 01865 285560

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 23/05/2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform the DPO of any changes in your data at the following email address: office@newcollegeschool.org

THIRD-PARTY LINKS AND SOCIAL MEDIA

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We and organisations connected with us have a social media presence for the purpose of engaging with our students, alumni and visitors.

If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy notice of every website of forum that you visit or use.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender and photographs.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Professional data: includes academic qualifications and achievements, references, profession, job title, employer and professional history.
• Welfare data: includes grievance and disciplinary information, information relating to criminal convictions and allegations of criminal activity, medical records and information including dietary requirements and religious information.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password to any School online service, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We refer to the above categories of data in the information table which can be found below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Much of this information is provided by way of Welfare Data and identified as such in our information tables. We may also collect information about criminal convictions and offences. Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. All such information is collected in accordance with this privacy notice. We have in place appropriate policy documents and/or other safeguards which we are required by law to maintain when processing such data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Professional and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • enrol with us;
  • make a donation to the School;
  • request access to our facilities;
  • keep in touch with us;
  • make a payment to us for events or services; or
  • give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below (further details can be found in the information table below):

• Technical Data from the following parties:    
  • analytics providers such as Google based outside the EU; and
  • search information providers based inside OR outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Professional Data from your previous educational establishments and/or employers if they provide references to the School.
• Identity and Contact Data from members of New College, family members, friends, visitors to the School and other contacts who may provide us with information about you.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU. 

We use CCTV recordings for the purposes of crime prevention and investigation and also in connection with our obligation to safeguard the welfare of pupils, staff and visitors to the NCS site. Clear signage is placed in the vicinity of CCTV cameras to alert individuals to their presence. CCTV recordings may be disclosed to third parties but only where such disclosure is in accordance with data protection law. Staff and pupils are also reminded that although the primary purpose of the school's CCTV system is the detection and prevention of crime, any evidence of misconduct captured incidentally on these cameras can be used as evidence in disciplinary matters. There is no routine monitoring of data captured by CCTV for disciplinary purposes, but in the event of an incident or allegation in relation to a visitor, pupil or member of staff, any existing footage may be reviewed if relevant to the allegations.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• We may also use your personal information, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests.

See the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

We do not sell your personal data to third parties. We will only share your personal data with third parties where we are allowed or required to do so by law. We set out in the relevant table the identity and purpose of such disclosure where it is possible for us to do so. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Third parties who process your data on our behalf are subject to contracts under which their processing activities are managed. Where your personal data is shared with third parties, we will seek to share the minimum amount of information necessary to fulfil the purpose. 

Online and Remote Learning

All platforms that the school uses for providing online learning / remote teachings are appropriately selected to serve the needs of teachers and pupils.   Selection criteria consider the safeguarding of pupils and rigorous application and compliance of UK Data Protection requirements.    

The school will communicate clearly and effectively the instructions on these systems to both the children and parents/carers for login and use of the platforms.

All pupils' work and assessments remain confidential between the student and their teacher(s).  To ensure this, teachers and parents/carers should remind children of the following guidelines:

• Keep your personal details private
• Do not share login information 
• Think before you post 
• Do not use identifiable personal data in posts, for example only use first names.
• Be respectful of what others post
• Talk to a trusted adult if you are worried.

The vast majority of online 'live lessons' at New College School will not be recorded, but there may be occasions when for safeguarding reasons, or other appropriate reasons at the discretion of the Headmaster, some 'live lessons' will be recorded. Further information can be found in New College School’s Policy on the Recording of Online Teaching & Learning Activity: /_site/data/files/documents/EB550D59BE70DBA98055459990EEBA8E.docx

Any concerns that teachers, or parents/carers have with the online learning / remote teaching should be immediately communicated to the Headmaster of New College School.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you attended one of our events or accessed one of our facilities and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the School for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided to you or other use of or access to our facilities or services.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy below.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

By law we have to keep some basic information (including Contact, Identity, Financial and Transaction Data) for pre-determined periods such as for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• The right to have access to your personal data
• The right to request correction of your personal data
• The right to request erasure of your personal data
• The right to object to processing of your personal data
• The right to request restriction of processing your personal data
• The right to request transfer of your personal data
• The right to withdraw consent
• The right to object to any direct marketing
• The right to object to any automated decision-making

Information about these legal rights can be found in the Glossary. If you wish to exercise any of the rights set out above, please Contact us. Some of your rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

LAWFUL BASIS

Legitimate Interest  means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation  means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

You have the right to:

Request access  to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure  of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing  of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer  of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.

Object to automated decision-making about you which produces legal effects or otherwise significantly affects you.