Privacy policy

Privacy policy

Introduction
Welcome to the privacy notice of Teaching Education Limited (“Us / We”).
We respect your privacy and are committed to protecting your personal data. This privacy notice informs
you how we look after your personal data, what privacy rights you have, and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data,
including any data that we collect when using our services.
We do not knowingly collect data relating to children.
It is important that you read this privacy notice 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 notice supplements other
notices and privacy policies and is not intended to override them.
Controller
Teaching Education Limited is the controller and responsible for your personal data.
If you have any questions about this privacy notice or our privacy practices, please contact us using the
following details:

Email address: [email protected]

Postal address: Teaching Education Ltd, 18 Piccadilly Lofts, 70 Dale Street, Manchester, M1 2PE

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
We keep our privacy notice under regular review.
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 on our website

Our 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 follow third party
links, we encourage you to read the privacy notice of every website you visit.
2. The personal 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, last name, marital status, title, date of birth and gender.
  • Contact Data includes address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to you and other details of services you
    have purchased from us.
  • Profile Data includes your previous purchases, employment history, your interests, preferences,
    feedback and survey responses.
  • Marketing and Communications Data includes your preferences in receiving marketing from
    us and our third parties and your communication preferences.
  • Special Categories of Personal Data includes without limitation information relating to your

race, ethnic origin, religion, trace union membership, and health. Where we collect Special
Categories of Personal Data, we will always obtain your express consent before processing.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as
this data will not directly or indirectly reveal your identity. 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.
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. In this case, we may have to cancel our services with you, but we will notify you if this
is the case at the time.
3. How is your personal data collected?

We use different methods to collect personal data, such as:
a) 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:

  • enquire about, or procure our services;
  • request marketing to be sent to you;
  • give us feedback or contact us.

b) Publicly available sources. We may collect Identity and Contact Data about you from
publicly available sources, such as your current or past employer’s website, jobs boards,
LinkedIn and Companies House.
c) Third parties. We may also collect Identity and Contact Data about you from third parties,
such as your former employer, referees, friends and colleagues.
4. How we use your personal data
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 obligation.

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.
Definitions of the different types of lawful grounds are set out below.
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 client. (a) Identity
(b) Contact
Performance of a contract with you.
(c) Profile
(d) Marketing and
Communications

To register you as a new
candidate.

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(e) Special Categories of
Personal Data
Performance of a contract with you.
Where you are a candidate, to
carry out background checks on
you.

(a) Identity
(b) Contact
(c) Profile
(d) Special Categories of
Personal Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to ensure that the candidates provided to
our clients are suitable)
(c) Legal requirement.

Where you are a candidate, to
details about you to our clients.

(a) Identity
(b) Contact
(c) Profile
(d) Special Categories of
Personal Data
(a) Performance of a contract with you
(b) Necessary for the legitimate interests
of us, you and our clients (to ensure that
vacancies are filled with suitable
candidates).(a) Managing payments, fees and

To process and deliver our
services to you, including:
charges

(b) Collecting and recovering
money owed to us.
(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 recover debts due to us).

To manage our relationship with
you which will include:

(a) Notifying you about changes
to our terms or privacy notice
(b) Asking you to leave a review
or take a survey.
(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 deliver relevant website
content, marketing and
advertisements to you and
measure or understand the
effectiveness of the advertising
we serve to you.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
Necessary for our legitimate interests (to
study how clients and candidates use our
services, to develop them, to grow our
business and to inform our marketing
strategy).

To make suggestions and
recommendations to you about
goods or services that may be of
interest to you.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
Necessary for our legitimate interests (to
develop our services and grow our
business).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising.
We may use your Identity, Contact, 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).
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a
result of a service that we provide.
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, where this is
required or permitted by law.
5. Disclosures of your personal data

We may share your personal data with third parties, as set out below but for the purposes set out in the
table above.
a) Service providers acting as processors based in the EEA who provide IT and system administration
services;
b) Where you are a candidate, potential employers based inside and outside of the EEA;
c) Where you are a client, potential candidates based inside and outside of the EEA;
d) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors
and insurers based, in EEA who provide consultancy, banking, legal, insurance and accounting
services;
e) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
based in the United Kingdom.
f) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to
our business, then the new owners may use your personal data in the same way as set out in this
privacy notice.

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.

6.International transfers

If you are a candidate and you ask us seek employment for you outside of the European Economic Area
EEA, we may share your personal data with third parties based outside of the EEA.
Whenever we transfer your personal data out of the EEA, we will obtain your express consent.
7. 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 such data. They will only process your personal data on our instructions and they are subject to a
duty of confidentiality.
We will notify you and any applicable regulator of a data breach, where we are legally required to do so.
8.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.
In some circumstances you can ask us to delete your data: see ‘your legal rights’ below for further
information.
In some circumstances we will 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.
9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data..
For example, you have the right to:
a) Request access to your personal data (commonly known as a ” 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.
b) 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.
c) 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, or shortly after your request.
d) 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.
e) 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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding
    legitimate grounds to use it.

f) 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.
g) 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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will normally 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.
10. Glossary
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 obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.