PRIVACY POLICY

Welcome to Home and Away Student Services privacy policy.

Home and Away Student Services respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Home and Away Student Services collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us by following this link: CONTACT US LINK we aim to respond to you within 5 working days.

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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 03/11/2018

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

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 do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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 as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes billing address, email address and telephone numbers.

  • 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, purchases made by you, 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 do collect special categories of information for some of our service users- namely in the form of information gathered from DBS checks for criminal conviction.

DBS POLICY

This section of our privacy policy sets out our commitment to comply with the DBS Code of Practice and our data protection obligations, to treat prospective hosts/contractors/employees or otherwise fairly and not to discriminate unfairly against any subject of a criminal record check on the basis of a conviction or other information revealed.

Its purpose is to set out how we comply with our data protection obligations in respect of criminal records information and seek to protect such information, and to ensure that any person subject to this process understands the rules governing the collection, use and deletion of criminal records information to which they may have access in the course of their work.

Home and Away Student Services has conducted a privacy impact assessment; weighing up our reasons for processing criminal conviction information against the right to privacy of the individual and we are committed to complying with our data protection obligations and the DBS Code of Practice in relation to criminal records information, in particular:

  • in relation to the circumstances in which we seek criminal records information;

  • by being concise, clear and transparent about how we obtain and use such information, and how (and when) we delete it once it is no longer required; and

  • by ensuring the correct handling, use, storage, retention and disposal of DBS certificates and certificate information.

Before Home and Away Student Services recruits or obtains the services of any person, we will assess whether it is justified in seeking criminal records information for that particular post, and if so:

  • whether it is appropriate to limit the information sought to offences that have a direct bearing on suitability for the job in question; and

  • whether the information should be verified with the DBS.

Home and Away Student Services will be justified in obtaining criminal records information for a particular post if it is necessary:

  • in order for Home and Away Student Services to comply with a legal or regulatory obligation to which it is subject, for example where the individual is applying for the role of a financial services professional regulated by the Financial Conduct Authority;

  • where, due to the nature of the role, the individual is required to be of the utmost honesty and integrity and the checks are necessary to prevent or detect unlawful acts.

We will only ask an individual to provide criminal records information in relation to convictions and cautions that Home and Away Student Services would be legally entitled to see in a DBS check for the relevant post, ie:

  • if Home and Away Student Services is justified in seeking criminal records information for the post, and the post is not exempt from the Rehabilitation of Offenders Act 1974, applicants will complete an information form which states that applicants are not required to disclose convictions that are spent under the Rehabilitation of Offenders Act 1974; and

  • if Home and Away Student Services is justified in seeking criminal records information for the post, and the post is exempt from the Rehabilitation of Offenders Act 1974, applicants will complete an information form which asks applicants if they have any convictions, cautions, reprimands or final warnings which are not filtered (or ‘protected’ as defined by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended).

If Home and Away Student Services is not justified in seeking criminal records information for the post, it will not ask an applicant for criminal records information

Once criminal records information has been verified through a DBS check, Home and Away Student Services will:

  • if inconsistencies emerge between the information provided by the individual and the information in the DBS certificate, give the applicant the opportunity to provide an explanation;

  • record that a DBS check was completed and whether it yielded a satisfactory or unsatisfactory result; and

  • delete the DBS certificate and any record of the DBS information contained in it unless, in exceptional circumstances, the data protection officer assesses that it is clearly relevant to the ongoing employment/engagement relationship

DBS certificate information will be handled and kept in accordance with Home and Away Student Services policy on handling personal information in line with this wider Privacy Policy

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.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct interactions. You may give us your Identity, Contact 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:

  • create an account on our website;

  • subscribe to our service;

  • request marketing to be sent to you;

  • give us feedback or contact us.

HOW WE USE YOUR PERSONAL DATA

We use Personal Information to do some or all of the following:

  • Communicate with you as part of our business;

  • Send you information regarding changes to our policies, other terms and conditions;

  • Provide improved quality, training and security and manage other commercial risks;

  • Carry out market research and analysis, including satisfaction surveys;

  • Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed;

  • Personalise your experience by presenting tailored information, advertisements and opportunities to you;

  • Facilitate social media sharing functionality;

  • Resolve complaints, and handle requests for data access or correction;

  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);

  • Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including (recruiters):

(a) Manage payments, fees and charges

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

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 purchased services from us and 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 third party for marketing purposes.

OPTING OUT

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

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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 [insert link]

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.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with third parties for the purpose of fulfilling the role required of us.

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-party service providers 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.

DATA SECURITY

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.

ONLINE SECURITY

If you are buying a product from Website via the Web site, your personal details and credit card information are scrambled using SSL encryption technology before being sent over the Internet. Although we cannot guarantee encryption or the privacy of your personal details and credit card information, SSL makes it very difficult for your information to be stolen or intercepted while being transferred. When we receive your order, it is kept encrypted until we’re ready to process it. Website is committed to keeping the information you provide us with secure. We have security procedures in place to protect your personal information.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

YOUR LEGAL RIGHTS

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

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 could 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.