The NCG Group is committed to protecting and respecting your privacy. This policy is to help you understand how and why we collect personal information about you and what we do with that information. The NCG Group is committed to protecting and respecting your privacy, we will never sell your data to third parties.
If you have any questions about this policy please contact Kerill Kennedy (NCG Liverpool Principal) on kkennedy@newcollegegroup.com or 0151 236 2749.
The term “NCG Group” used in this document refers to NCG Holdings Ltd and the companies over which it has substantial control including:
In this policy the terms “agent” and “agencies” refer to companies whose business involves arranging courses or other services for individuals or groups of individuals and choose NCG Group to provide these services. In cases where your primary relationship is with the agency, they are the “controller” of your data and NCG will only process data in a way they have agreed with you.
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.
We set out below examples of the different ways in which we use personal information and where this personal information comes from. NCG Group’s primary reason for using your personal information is to provide educational services to you.
We obtain information about you from admissions forms, forms that you fill on your first day at the school and from agencies you have contracted directly for the purpose of study where the agent has passed your details to us in order to fulfil their agreement with you. For NCG group this is typically the provision of English or other educational courses.
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 that relate 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 attendance and 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 other students at our schools/ summer schools. We use CCTV at our schools to make sure the school sites are safe and may
use CCTV at our summer schools for the same reason. CCTV is not used in private areas such as toilets.
We may take photographs or videos of you at NCG Group events to use on social media and on the School website. This is to show prospective students what we do here and to advertise NCG Group and also because students often like their photos to be shared through social media so that they can show others/remember events/times at the school. We may continue to use these photographs and videos after you have left the school. Your permission to allow or refuse to allow this is sought on or before your first day via the first day form.
We may send you information to keep you up to date with what is happening at the school. For example, by sending you information about events and activities taking place and may contact you with offers for courses similar to one you have taken in the past.
We may use information about you if we need this for historical research purposes or for statistical purposes.
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.
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 our accrediting bodies including Accreditation. 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, 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 and how much progress you are making in your learning.
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 NCG Group in fulfilling its obligations. We might need to share your information with them if this is relevant to their work.
We may share some information with our insurance company, for example, where there is
a serious incident at the school. If you have unpaid fees while you are studying at an NCG schools/summer school, we may share information about this with other schools or educational establishments to which you intend to go.
If your child leaves us to attend another school we may need to provide that school with
information about your child. 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 where this is part of our obligation to take care of your child, as part of our wider legal and regulatory obligations, or in connection with school fees.
We may need to share information if there is an emergency, for example, if you have an accident
whilst on school premises.
This section contains information about the legal basis that we are relying on when handling your information.
Legitimate interest
This means that the processing is necessary for legitimate interests except where the processing is unfair to you. The NCG Group relies on legitimate interests for most of the ways in which it uses your information. Specifically, the NCG Group has a legitimate interest in:
In addition, your personal information may be processed for the legitimate interests of others. For example, another school will have a legitimate interest in knowing if you have not paid fees that are due to us.
If you object to us using your information where we are relying on our legitimate interests as explained above, please contact Kerill Kennedy.
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.
Legal obligation
Where the NCG Group 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.
Vital interests
For example, to prevent someone from being seriously harmed or killed.
Public interest
The NCG Group considers that it is acting in the public interest when providing education services.
The NCG Group 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 NCG 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 may be processed where it allows us to promote your safety and mother tongue/country of origin are used to promote your education since it is useful for teachers to best plan their courses for the needs of their students.
Substantial public interest
The processing is necessary for reasons of substantial public interest.
Vital interests
To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.
Legal claims
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.
Medical purposes
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 contact Kerill Kennedy if you would like to withdraw any consent given.
For instances where your primary relationship is with an agent or other company which has selected/advised NCG Group to provide contracted services, NCG group serves as the data processor. This means that we will only process your data in order to provide the contracted services. Should you wish NCG Group 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.
We may send your information to other countries where:
The European Commission has produced a list of countries which have adequate data protection rules. The list can be found at 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.
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 Education. We will keep some information after you have left the NCG Group, 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 apply to return to study with NCG Group and potentially to advise you of offers for courses similar to ones you have studied 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 we are 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 the NCG Group.
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:
Kerill Kennedy can give you more information about your data protection rights.
All information you provide to us is stored on secure servers within the UK or EEA and we will take reasonable steps to protect your information, including without limitation:
The managing director is ultimately responsible for ensuring compliance with meeting all legal obligations. The key contact for matters related to data protection and privacy, however, is Kerill Kennedy (NCG Liverpool Principal). He can be contacted by email: kkennedy@newcollegegroup. com or telephone: 0151 2362749. 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 contact Kerill Kennedy if:
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.