隐私政策

​1. About us

We are Aspire Guardians UK Limited, referred to throughout this Privacy Policy as “Aspire Guardians”, “we”, “our”, or “us”.

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We provide educational guardianships to international students whom study at boarding schools in the UK. 

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We are a registered company in England and Wales under company number 15260752 and our registered office is at 167 - 169 Great Portland Street, 5th Floor, W1W 5PF.

 

For the purposes of this Policy, Aspire Guardians is the data controller and we are registered with the Information Commissioner’s Office under registration number is ZB672925.

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2. How we collect personal information 

We collect personal information about you whenever you engage with us, apply for a job with us, or use one of our services.

 

This includes, but is not limited to:

• When you use our website

• When you contact us via email, telephone, WhatsApp, WeChat, LINE or any other social media application 

• When you interact with us on social media platforms e.g. by sending a message on one of our accounts

• When you make a complaint 

• When you contact us to exercise one of your legal rights e.g. the right to access your personal information

• When you apply for a job with us

• When you attend a job interview 

• When you register to attend an event organised by us

• When you subscribe to our newsletter

• When you apply to use our services

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In addition, we may receive personal information about you from other individuals or organisations.

This includes, but is not limited to:

• When an Aspire Guardians employee provides your contact details as an emergency contact 

• When a job applicant gives your name and contact details as a referee

• When a referee provides information about you during the recruitment process

• When a complainant refers to you in their complaint correspondence

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3. What personal information we collect about you

Personal information means any information that relates to an identified or identifiable individual.

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The types of personal information we collect about you depends on the nature of your interactions with us.

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Depending on the circumstances, we may collect any of the following types of information:

• Your name, address and contact details, including email address and telephone number

• Date of birth

• Financial information, such as payment related information or bank account details

• Technical information, including the type of device you are using to access our website, the Internet Protocol (IP) address, and the browser and operating system being used to connect your device to the internet

• Information about your visit to our website, including pages you visit and how you use the website

• Details relating to a job application you have made, such as your covering letter and CV, your education and employment history, and any other information relevant to the recruitment process (please refer to Section 4a for more information about the recruitment process).

 

In some circumstances, we may collect information about you which is sensitive. This is called special category data. We may also collect information about your criminal history.  For example, if you apply for a job with us, you may be required to undertake a Disclosure and Barring Service (DBS) check (please refer to Section 4a for more information about the recruitment process).

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4. How we use your personal information

We must have a lawful, valid reason for using your personal information.

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The main lawful reasons that we rely on to process your personal information are:

• Contract performance: where your personal information is necessary to enter into or perform our contract with you

• Legal obligation: where we need to use your personal information to comply with a legal obligation

• Legitimate interests: where we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights

• Consent: where you have given us your consent to use your personal information (you may withdraw your consent at any time)

• We may use your personal information to:

• Deal with your enquiries, requests, or complaints

• Send you details about forthcoming events and training courses which you have requested, and we feel would be of interest to you

• Send you communications which you have requested to receive from us

• Process your application for guardianship if you are a parent

• Carry out our obligations under any contracts entered into between you and us, or to meet our legal obligations to regulators, government, and/or law enforcement bodies

• Assess your suitability for a job you have applied for, and to progress your application through the recruitment process (please refer to Section 4a for more information about our recruitment process)

• Better understand how you interact with our website, including pages you visit and areas that are of most interest to you. This is so we can improve our website, the user experience, and target our audience more effectively.

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4.a. How we use your personal information during the recruitment process

When you apply for a job with us, we will collect and process your personal information.  We will only collect personal information that is necessary to assess your suitability for the job you have applied for, to progress your application and keep you updated throughout the process, and to comply with any legal or regulatory obligations. 

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We collect personal information about you either directly from you or from a third party such as a recruitment agency.  

The information we collect may include, but may not be limited to:

• Your name, address and contact details, including email address and telephone number

• Details about your qualifications (including copies of certificates), skills, experience, and employment history

• Details about any professional memberships you hold

• Information gathered from any interviews you attend

• Information about your current salary level, including benefits and pension entitlements

• Information about your right to work in the UK

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In some circumstances, we may collect and process information about you which is sensitive. 

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This may include, but may not be limited to:

• Information about your racial or ethnic origin, religious or philosophical beliefs, or sexual orientation for the purpose of our equal opportunities monitoring

• Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process

• Information about criminal convictions and offences

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As part of our recruitment process, we may ask applicants to complete an equal opportunities questionnaire. This is not mandatory; it is entirely your choice as to whether you provide us with this information and there are no adverse consequences if you choose not to.

If you do choose to provide this information to us, we will not make it available to any employees outside of our recruitment team in a way that can identify you.  We will use this information to produce and monitor equal opportunities statistics.

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If your application for employment is unsuccessful, we will retain your personal information for six months. After six months, your personal information will be deleted or securely destroyed, unless we need to retain it for longer to exercise or defend any legal claims, or you have agreed that we can retain your details in our talent pool for a period of 12 months or an agreed period of time, should any suitable vacancies become available during that time.

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If your application for employment is successful, any personal information gathered during the recruitment process will be transferred to your employee file and retained for the duration of your employment with us, plus a period of six years following the end of your employment.

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When an offer of employment is made to you, we will be required to undertake pre-employment checks. For example, we may collect personal information about you from third parties, such as references from current or former employers, information from background check providers and criminal record checks from the Disclosure and Barring Service (DBS). We will only seek this information once an offer of employment has been made to you and we will always advise you of this prior to carrying out these checks.

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Once the necessary pre-employment checks have been completed and the outcomes are satisfactory, we will collect and process additional personal information relating to your employment.

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This includes, but may not be limited to:

• Your bank or building society details, so we can process your salary

• Your emergency contact details, so we know who to contact in the event of an emergency at work

 

You are under no statutory or contractual obligation to provide your personal information to us during the recruitment process. However, if you do not provide this information, we may not be able to process your application properly or at all or provide any reasonable adjustments during the recruitment process.

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5. Who we share your personal information with

We will only share your personal information with other organisations where it is lawful for us to do so. When we share your personal information, we will only share the information that is necessary. We will always share information securely and ensure we are giving it to the right recipient.

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We may share your personal information with others in the following circumstances:

• Where we are required to do so to comply with a legal or regulatory obligation.  For example, we are legally required to provide information about employee income tax contributions to HMRC

• In an emergency.  For example, where we need to protect a person from serious harm

• Where we have safeguarding concerns about a child, and we need to alert the local authority

• Where we are required to do so to comply with the instructions of a law enforcement authority.  For example, we might receive a request from the Police for personal information we hold about an individual, to help them investigate a crime

• To protect our business interests

• Third parties who provide a service to us.  For example, a course or camp provider

 

When we use third parties to process personal information on our behalf, they are required to follow the same rules and information security requirements as us and are not permitted to reuse your personal information for any other purpose.  We only share the personal information that is necessary to deliver the service.

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We will not share your personal information with third parties for marketing purposes and we will never rent or sell your personal information to any other organisation or individual.

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6. How we keep your personal information safe

We have robust technical and operational security measures in place to protect your personal information against unauthorised access or unlawful use.

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In addition, we limit access to your personal information to those employees, contractors and other third parties who have a legitimate business need to know. They will only process your personal information on our strict instructions and they are subject to a duty of confidentiality.

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We maintain internal policies and procedures regarding data protection and confidentiality to ensure that our employees are aware of and understand their responsibilities in relation to your personal information.

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We have a robust procedure in place to deal with any suspected personal data breaches.  We will notify you and the Information Commissioner’s Office (ICO) of any breach within the specified timescales where we are legally required to do so.

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You too can play a part in helping to keep your personal information safe.  This includes choosing strong passwords, being alert to any fraudulent emails that might appear to be from us (when they are not) and using suitable anti-virus software on your device.

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7. How long we keep your personal information for

We carefully consider how long we keep your personal information for and only keep it for as long as is necessary to fulfil the purpose it was collected for.

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We review our data retention periods on a regular basis to ensure that personal information is not held for longer than is necessary. We regularly review the information we hold and delete or securely destroy it when we longer need it.

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

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8. Children’s personal information

Aspire Guardians retains student’s information in order to fulfil our role as an educational guardian. 

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This may include, but not be limited to:

• Name, address, date of birth

• Details of ethnicity

• Contact details, such as phone numbers, email addresses and addresses

• School details

• Medical information

• Copies of passport, BRP and police checks

• Details of bank accounts and finances

• Details of mobile phone accounts

• Information on food preferences, interests and hobbies

• Copies of school reports

• Records of meetings held with students and schools

 

This information is treated as sensitive information and is stored securely as explained in this policy and is only shared with others on a need-to-know basis. Aspire Guardians may share information with staff members, homestays and school staff. Aspire Guardians may share information with external agencies where there is a safeguarding concern. 

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Through this privacy notice, Aspire Guardians provides information to students and their parents about what records we hold, why we need to hold them and who we might share their information with (for example as part of a multi-agency child protection team) (Information Commissioner’s Office, 2021). If we are keeping records for child protection reasons, please note that we don’t necessarily need to get consent from the adults and/or children concerned.

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We will store general student records for one year after the student completed their final year at boarding school.

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8.a Child Protection Records

Aspire Guardians is required to keep child protection records where there has been a safeguarding concern. These will be stored separately to other information in a secure file. There will be one file for each child and access is limited to the Designated Safeguarding Lead – Ms Thomas. If it is necessary to share records (within our organisation or externally), we will ensure that they are kept confidential. Passwords and encryption will be used where possible when sharing electronic files. If the person responsible for managing our child protection records leaves Aspire Guardians will appoint somebody to take over their role and arrange a proper handover.

 

We will store any child protection records until a child turns 25.

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9. Marketing

We will keep you up to date with our latest news and details about any services, upcoming events or training courses if you have told us that you are happy to receive marketing communications from us.

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If you decide that you no longer want to hear from us, you can opt-out at any time.  You can do this by contacting us using the details contained in this Policy, or by clicking on the ‘unsubscribe’ link contained in any email marketing communication you receive from us.

 

Please note, in unsubscribing from our mailing list, you may miss out on important information that is circulated that may be of interest.

 

10. Links to third-party websites and services

This website may include links to other websites and applications that are operated by third parties.  For example, we provide links to websites of other organisations, including accredited guardianship organisations and member schools.  When you click on one of these links, you will be directed to that website.

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We do not have any control over these third-party websites, and we cannot take any responsibility for any information you might give to them.

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When you leave our website, we encourage you to read the privacy notice of every website you visit so you can understand how that website will collect and use your personal information.

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11. Cookies

A cookie is a small file of letters and numbers which is downloaded to your device when you access a website.  When you visit a website, that site will ask your device for permission to store this file.

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Cookies are used by many websites and have several different uses. For example, they can remember your preferences and count the number of people who have visited a website.

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‘Session cookies’ are those which expire at the end of your browser session.  They allow a website to recognise and link the actions of a user during a browsing session.  This means we can gather statistics to help us understand how our website is being used, and to improve its structure.

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‘Persistent cookies’ are stored on a user’s device in-between browsing sessions.  They help us to recognise you as a unique visitor to our website and allow us to tailor the content of certain areas.

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At Aspire Guardians, we use ‘session cookies’ and ‘persistent cookies’.

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You can use your web browser to accept, decline, or delete cookies. You can also clear cookies at the end of your browsing session. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. This may, however, prevent you from taking full advantage of our website.

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12. Your legal rights

We want to ensure that you are always in control of your personal information.

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We have outlined below what your legal rights are in relation to your personal information, together with details as to how you can exercise them:

The right to access your personal information

• You have the right to request a copy of the personal information we hold about you.

 

The right to edit and update your personal information

• You have the right to request that your personal information is rectified if it is inaccurate or incomplete.

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The right to request to have your personal information erased (also known as the ‘right to be forgotten’)

• You have the right to request that your personal information is erased.  However, this is not an absolute right, and it only applies in certain circumstances.  For example, the law may require us to keep some types of personal information for a specific period of time. We will review each request on a case-by-case basis.

 

The right to restrict the processing of your personal information

• You have the right to request the restriction or suppression of your personal information. However, this is not an absolute right, and it only applies in certain circumstances.

 

When processing is restricted, we will continue to store your personal information, but we will not use it.  

• The right to object to your personal information being used 

 

You have the right to object to the processing of your personal information at any time.  However, this is not an absolute right, and it only applies in certain circumstances.

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You do, however, have an absolute right to stop your personal information being used for direct marketing purposes.  

The right to data portability

• You have the right to request that we transfer your personal information from one organisation to another or give it to you. This right only applies to information that you have provided to us and is held electronically.

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The right to complain to a supervisory authority if you believe we have not handled your personal information in accordance with data protection laws

 

You can make a complaint or raise a concern about how we process your personal information by contacting us using the details set out below.

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If you are not happy with how we have handled your complaint, or you believe that your data protection or privacy rights have been infringed, you have the right to complain to the Information Commissioner's Officer (ICO).  The ICO is the UK’s independent body established to uphold information rights.

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If you wish to exercise any of the rights outlined in this section, please write to us at the following address:

Postal: 167 - 169 Great Portland Street, 5th Floor, W1W 5PF

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We will endeavour to respond to all requests without delay, and in any event within one month of receiving your request. There may be circumstances when we need to extend the time limit for responding to a request. We shall endeavour to tell you if this is the case and keep you informed.

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Before responding to a request, we may be required to ask for further information and/or proof of your identity.

Please keep in mind that there are exceptions to the rights outlined above and although we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

13. Changes to our Privacy Policy

This Privacy Policy will be regularly reviewed and may change from time to time.  If it does, the most current version will always be available on our website.  

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We will keep our privacy notice under regular review. Our privacy notice will be next reviewed in three years or sooner if data protection legislation changes in the interim, therefore the review date will be 7 October 2027.