Dragons Teaching Data Protection Policy 2022
Who we are
We are Dragons Teaching Ltd (which includes our other trading subsidiaries Connect Chinese Ltd, Interlink Teaching Ltd and Online Community Classroom Ltd). Our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
We provide language teaching services both face to face and online using a range of proprietary language teaching software and courseware. We deliver these services to a variety of different clients including schools (throughout the private and maintained sectors), businesses and individuals.
The purposes for which we collect and process personal data
We collect and process, in accordance with data protection legislation, personal data as follows:
If you are a teacher (or other members of staff) at a school to which we provide services:
We may collect your individual contact information (including your name, school name and address), your e-mail address, your role/job title at the school and a contact telephone number (which may be your personal mobile number should you choose to give it to us).
We may also collect other personal information relating to you to in the course of the provision of the services concerned, which may include, for example, information relating to the school year/age groups you teach, your experience, material that you access via our platforms and other information relating to you that is included in any communications between us and you or the school where you work in the course of the provision of our services.
We may also collect publicly available information about you or information about you we may acquire from service providers or educational information providers.
If you are a pupil or teacher (or other members of staff) at a school to which we provide services participating in a programme:
In the event that our service is being provided to you, you may be required to provide personal information to us that is not required by us to deliver our services to you.
Where we are processing personal information that is not required by us to deliver our services to you, we are acting as a data processor in respect of that data which will be processed in accordance with the instructions of the data controllers for that data who have determined the legal basis for processing it.
If we provide services to you as an individual in relation to the children under your care:
We may collect your individual contact information (including your name, your address and other similar details) to enable us to communicate with you in relation to the provision of services to you (for example, helping you cancel or change a time for classes, etc.) and other personal information relating to you to in the course of the provision of the services concerned.
We will not process any bank account, credit card or other financial details relating to you, as we transfer you to secure third-party service providers to process any relevant payments and do not process the payments ourselves.
We may also process any other information relating to you that is included in any communications between us and you during the provision of the services.
If you are a child who is enrolled in one of our learning programmes (or a teacher or a parent of such a child who wishes to know what information we process relating to children to whom we provide teaching):
We may collect information about the child necessary to enable us to deliver the lessons to the child, including name, age, gender, academic school year, educational needs and capabilities, and information about any relevant medical or learning needs or other special needs that we may need to take account of in providing the lessons to the child. The information about the child will normally be provided by the child’s school or parent, except to the extent that the child itself provides any information during a session directly to one of our teachers.
We limit the amount of information we collect about a child (in addition to the information provided by the child’s school or parent) to no more than is necessary to deliver the service.
As per our terms of service online lessons that we provide may be recorded and the recordings are used by us to monitor the quality of the teaching provided, compliance by teachers with our guidelines, and other factors relevant to the teaching. We also store the recordings for safeguarding and archival purposes. The recordings also provide us with a tool for ongoing continual professional development for our teachers and enable us to improve the services provided and enhance educational outcomes through conducting analysis and research.
If you request information about our services:
We may collect your individual contact details, including your name, school name and address, your email address, your role/job title at the school, and a contact telephone number (which may be your personal mobile number should you choose to give it to us) in order to arrange a demonstration or follow up with further information related to our services.
If we wish to send you advertising, marketing or promotional material:
We may collect your individual contact details to send you direct marketing material in order to advertise, market or promote our services.
If you provide goods or services (or you work for someone who supplies goods or services) to us:
We may collect your individual contact information to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of goods or services by you or the person that you work for (for example, in relation to the management and administration of the provision of the relevant goods or services) and other personal information relating to you to in the course of the provision of the goods or services concerned. This may include, for example, bank account or other financial details, personal description and photograph, and other information relating to you that is included in any communications between us and you or anyone you work within the course of the provision of the goods or services.
If we are assessing your suitability or ability to provide goods or services to us or to any of our group companies:
We may collect relevant personal information relating to you to the extent necessary to enable that assessment to take place – for example, if we need to assess or confirm your age, your right to work in the UK, your skills and previous experience, your qualifications or whether there is anything (for example, relating to your past history, your health or your conduct or reputation) that would adversely affect your suitability or ability to provide the goods or services concerned. This will be explained to you in more detail at the time we collect the personal data and, where appropriate, will be subject to your prior consent.
If you apply for a position with us (including as a teacher):
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.
Where we process your personal data
We are established in the UK and the systems which we use to process your personal data are hosted here or elsewhere in the EU.
Our classes are delivered by our teachers who are based either:
- throughout the UK (where they are directly employed by Dragons Teaching Ltd), or
- in Taiwan and employed through our wholly owned subsidiary Dragons Teaching Taiwan Ltd.
Our teachers teach using online video software including (but not limited to) Zoom, MS Teams, Whereby and GoogleMeet. Our Online Learning Platforms (OLP) are all hosted in the UK or via our Digital Ocean cloud software.
Where necessary, to manage our business, we may share relevant personal data with our group companies, service providers (i.e. data monitoring or analytic tools) or suppliers, but only to the extent necessary in order to provide the services concerned. We will only share the minimum amount of personal data necessary for the purpose of processing and, where possible, we will share the personal data in a pseudo-anonymised or anonymised form.
All EEA member states and countries or territories with an “adequacy decision” by the EU have been assessed and given an “adequacy resolution” by the Information Commissioner’s Office (ICO) meaning the UK has determined that they offer a similar level of protection for personal data as in the UK allowing personal data to be transferred or made accessible without additional requirements or safeguards being needed to protect the data transferred.
Security of your personal data
All personal data processed by us is stored securely (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances). We use a range of organisational and technical security measures to protect your information to ensure it is not accidentally lost or used or accessed in an unauthorised way.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and to use a password that is appropriate (i.e. a mixture of upper and lower case letters and characters which is not used on other sites and would not be easily guessed).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
Who we share your personal data with
We will only share your personal information with other organisations after careful consideration and only when we have a legitimate reason and in compliance with data protection legislation.
We may, where appropriate, share your personal data with:
- any member of our group, which means our subsidiaries, our holding company and its subsidiaries,
- appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- third-party service providers who provide website and application development, hosting, backup, communication platforms, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information;
- our auditors, legal advisors and other professional advisors or service providers;
- credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for,
- analytics and search engine providers that assist us in the improvement and optimization of our site, in relation to information obtained via our website and subject to our Cookies Policy.
Other disclosures we may make
We may disclose your personal data to third parties:
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets,
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the person that you work for; or to protect the rights, property, or safety of our business, our group companies, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, or credit risk reduction.
The legal basis for our processing of personal data
The legal basis on which we process your personal data is as follows:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process personal data in the course of providing our services, including where we process the personal data of children to whom we provide teaching services, will fall into this category).
The provision of our teaching service to pupils (including the processing of personal data that takes place in the course of providing the tutoring service) is carried out on the basis of legitimate interests, including our legitimate interest in providing the service concerned and conducting our business accordingly, and of the interest of the relevant school population as a whole in enabling us to provide an effective language teaching service that may benefit them accordingly. To the extent that any special categories of personal data relating to a given pupil need to be shared with us in order to assist us in providing the service, this will be done only with the prior consent of the parents, directly or via the school, of the pupils concerned.
How long we keep your personal data
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose. These time periods are different depending upon the category of personal information and the nature of the processing activity.
You have the following rights in relation to personal data relating to you that we process:
- You may request access to the personal data we hold about you.
- You may request that inaccurate personal data that we are processing be corrected.
- In certain circumstances (normally where it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing your personal data for marketing purposes or otherwise based on our legitimate interests, you may in certain circumstances have a right to object to that processing. This may include where we are processing personal data relating to children to whom we provide tutoring services.
- In certain circumstances, you may have a right to request us to restrict our use of your personal information.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent, after which we shall stop the processing concerned.
To exercise any of your rights (including withdrawing relevant consents or obtaining access to your personal data), you should contact us as set out below.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal complaint with the Information Commissioner.
Contacting the regulator
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Our contact details are: Dragons Teaching, 9 Bonhill Street, London, England EC2A 4DJ
Contact: Adam Ennis (our Data Protection Officer (DPO))
Updates to this policy
Date of this policy
This policy was last updated on 1st February 2022