Privacy Policy

Your privacy is important to Spark to Connect Ltd and this notice is to help you understand how and why we collect personal data about you and what we do with that information. It also explains the decisions that you can make about your own information. This statement complies with the UK Data Protection Act 2018 and with the requirements of the European General Data Protection Regulation.

Please read this policy carefully and contact us on the details at the end of this notice if you have any questions or concerns. This notice applies to data that is collected through the Spark To Connect Ltd website, our booking form, registration forms, photography, and survey questionnaires.

What is personal data?

Personal data is information that identifies you as an individual. This includes your contact details, next of kin and financial information, photos and video recordings of you are also personal data.

Who are we?

Spark To Connect is a limited company, registered in England & Wales, No. 151804476

What information do we collect?

For all Educational Programs:

• Information that you provide by registering a student on to Spark To Connect Ltd. Programs.

• If you contact us, we will keep a record of that correspondence.

• A survey may be sent at the end of each course that we use for feedback purposes. This survey is optional. Some testimonials from it might be used in promotional material alongside the student's name and age if you have given us consent to do so.

• Records of payments. Financial details are collected by third-party financial systems, unless you have paid by bank transfer, in which case your details will be held securely by the Spark To Connect Ltd. accounts team.

• Students medical, travel and emergency contact information.

• Copy of a student’s passport and visa if applicable.

• Photographs for use on ID lanyards and internal Facebook if permission has been given.

How is data collected?

• Data is collected when you fill in registration form, and medical, travel, and emergency contact details are collected via the Parental Consent Form as part of the registration process.

• Passport copies and visas are collected when a student registers on their arrival.

• Survey data will be collected by a third-party website such as Google Forms.

• We will only use a system with a server in the EU.

• Student photographs for program are collected for ID purposes by our staff.

• Photographs and videos are taken by our professional photographer and videographer during the summer of any student who has given permission for their image to be collected and used.

• These students are identified by coloured lanyards.

How do we use personal information?

• Enrolling students on to a course as per legal obligations.

• Meeting internal and external audit requirements for the British Council.

• Personalisation of content, business information and user experience.

• Student course set up and administration.

• Delivering marketing communication.

• Carrying our polls and surveys.

• Internal research and development purposes.

 

• Providing goods and services.

• To ensure medical safety.

What legal basis we have for processing personal data?

• Consent – for attending program, you can withdraw a student until the commencement of the course by cancelling their course. We will then destroy the data relating to that student.

• Contract – to supply an educational course to a student who is under 18.

• Legal obligation – student registration data is held indefinitely in the interest of safeguarding; copies of

passports and visas are taken as a legal requirement; medical information is saved in case of emergencies.

When do we share personal data and how is it stored?

Spark To Connect Ltd. will treat personal data confidentially but at times may need to disclose or share it when necessary to provide our services or conduct our business operations, as outlined in our purposes for processing. Spark To Connect Ltd will inform a subject within 72 hours if we believe that there has been a breach of student or payee data.

How we secure personal data?

We have taken the appropriate technical and organisational measures:

• to protect data against accidental loss

• to prevent unauthorised access, use, destruction, or disclosure

• to ensure business continuity and disaster recovery

• to restrict access to personal information

• to conduct privacy impact assessments in accordance with the law and your business policies

• to train staff and contractors on data security

• to manage third party risks through use of contracts and security reviews

How long do we keep your personal data?

Personal data kept on a student under the age of 18 who participates in Spark To Connect Ltd. Programs will be kept archived indefinitely in the interest of safeguarding and as required by law, providing a record of who has attended our courses. Medical data is kept for 25 years as per NHS guidelines. Any other data such as correspondence, survey responses, course reports or copies of certificates will be kept for two years, in line with Spark To Connect Ltd. retention schedule.

Your rights in relations to personal data

Under current data protection laws, we respect the right of students and payees to access and control their personal data.

• You can request a copy of any personal information at any time.

• You can correct data at any time, but as our courses are for students under the age of 18, once they have

attended their data will be kept indefinitely as required by law.

• You can withdraw consent for future use of your photos and/or to withdraw consent for the newsletter once

registered by contacting us via the details below.

• You can file a complaint with the information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.

We aim to respond to any data requests within one month of receipt, as required by the legislation.

How to contact us?

You can get in touch if there have questions or concerns about Spark To Connect Ltd privacy practices, your personal information, or if you wish to file a complaint.

To contact us you can: email us info@sparktoconnect.com for Spark To Connect Ltd. Programs