1.
Definitions
a. “FLE Learning” is a trading name of FLE
Learning Ltd
c. “Conference” means the conference you have
selected to attend in your abstract or registration form.
d. “Delegate” means the delegate who attends
or wishes to attend the Conference.
e. “Data” means collectively all information
that you submit to our WebSite. This includes, but is not limited to, account
details and information submitted using any of our services or systems;
f. “Service” means collectively any online
facilities, tools, services or information that FLE Learning makes available
through its website either now or in the future;
g. “System” means any online communications
infrastructure that FLE Learning makes available through its website either now
or in the future. This includes, but is not limited to, web-based email,
message boards, live chat facilities and email links;
h. “Website” means the website of FLE
Learning ie., www.flelearning.co.uk
and any sub-domains of this site unless expressly excluded by their own terms
and conditions.
2.
FLE Learning Duties
2.1. FLE Learning needs to process personal
data about its current, prospective and former delegates and their sponsoring
institutions, its current, prospective and former staff, its suppliers/
contractors, its current and prospective supporters and other individuals
connected to the company, as part of its everyday operations and is legally
obliged to process such personal data in accordance with the General Data Protection
Regulation (“the GDPR”).
2.2. For the purposes of the GDPR, the data
controller is FLE Learning Ltd, which is a company incorporated in Scotland
(registration number SC472947). FLE Learning is committed to compliance with
the GDPR and takes seriously the responsibility of handling personal
information.
2.3. This Policy has been developed to ensure
that FLE Learning meets its obligations under the GDPR.
3.
Data Protection Principles
The Data Protection Principles require FLE
Learning to ensure all personal data is:
- fairly and lawfully processed;
- processed for a lawful purpose;
- adequate, relevant and not
excessive;
- accurate and up to date;
- not kept for longer than
necessary;
- processed in accordance with the data
subject’s rights;
- protected by appropriate security;
and
- not transferred to other countries
without adequate protection.
4.
Personal data processed by FLE Learning
4.1 Personal data processed by FLE Learning
can take different forms – it may be factual information, expressions of
opinion, images or other recorded information which identifies or imparts
something of significance about a living individual.
4.2 Personal data processed by FLE Learning
may include (but is not limited to) basic personal details, contact details
and: (for staff and contractors) additional information required for their
employment or appointment including images and biometric data; (for delegates)
passport and visa information (if received), academic, disciplinary and other education
related records, employment details,
information about special educational needs, references, photographs, and
financial information/bank details.
4.3 FLE Learning collects the personal data
it processes directly from the data subject and from third parties (for example
referees, sponsoring institutions, universities and the Criminal Records
Bureau).
5.
Purposes for which Personal data may be processed
Personal data (including sensitive personal
data, where appropriate) is processed by FLE Learning in accordance with the GDPR for the following purposes:
- The provision of education including
the registration of prospective delegates and administration of the
application/registration process; administration of the Conference programme
and timetable; providing certificates of attendance/participation to delegates;
publication of conference proceedings, abstracts handbook and e-journal.
- The provision of educational support
and ancillary services including the administration of the Conference social
programme activities; conference venue administration; and provision of wi-fi
at conference venue.
- The general administration of FLE
Learning including the compilation of delegate records; the administration of
invoices, fees and accounts; the management of the University/College/Hotel
property where summer Conference is organised; the management of security and
safety arrangements (including the use of CCTV); the administration and
implementation of FLE Learning’s policies; and other reasonable purposes related
to the FLE Learning’s operations, such as information given to University or
College or Hotel venue providers.
- The protection and promotion of FLE
Learning’s legitimate interests and objectives including the publication of its
website, the prospectus, fixtures and other promotional publications promote
FLE Learning conferences to prospective delegates.
- The administration of its staff, agents
and suppliers including the recruitment of staff/ engagement of contractors
(including compliance with CRB procedures); administration of payroll, pensions
and sick leave and the maintenance of appropriate human resources records for
current and former staff; and providing references.
- The fulfilment of the FLE Learning’s
contractual and other legal obligations.
6.
Processing of Personal Data
6.1 FLE Learning will only process personal
data for the purpose(s) for which it was originally acquired and will not
process it for any other purpose without the data subject’s permission, unless
it is permitted to do so under the GDPR. FLE Learning may communicate with data
subjects for the purposes set out above by post, email and SMS.
6.2 Personal data shall only be disclosed to
those members of FLE Learning’s staff and suppliers who need to access the
personal data to carry out the purpose(s) for which it was acquired. FLE
Learning adopts appropriate security measures to ensure that personal data is
kept secure and not processed without proper authority. FLE Learning observes
legislative requirements and current best practice to ensure personal data is
kept for no longer than necessary.
6.3 FLE Learning will not transfer personal
data outside of the EEA unless it is satisfied that the data subject’s rights
under the GDPR will be adequately protected.
6.4 FLE Learning would seek permission from
the delegate before featuring the delegate particularly prominently in
documentary films or articles for which FLE Learning may give permission.
6.5 When processing personal data for the
purposes set out above, FLE Learning may communicate by post, email and SMS and
may make use of cloud computing services.
7.
Third parties with Whom FLE Learning may need to share information
From time to time FLE Learning may pass
personal data (including sensitive personal data where appropriate) to third
parties, including local authorities, other public bodies (eg, UK Border
Agency, HM Revenue and Customs, British Consulate in different countries),
health care professionals, social activities providers,
university/college/hotels providing conference venue, who will process the
data:
- to enable the relevant authorities to
monitor FLE Learning’s performance;
- to compile statistical information
(normally used on an anonymous basis);
- to ensure the delegates’ safe arrival
to the UK;
- to safeguard delegate’s welfare and
provide, where relevant, medical care;
- where necessary, in connection with
conference and social activities undertaken by delegates, to monitor delegate’s special needs and
requirements; to obtain appropriate professional
advice and insurance for FLE Learning;
- where a reference or other information
about a delegate is requested by an educational establishment or employer to
whom they have applied or already working;
- where otherwise required by law;
- where otherwise reasonably necessary
for the operation of the FLE Learning and employment of its staff;
- In the event of sale or purchase of any
business or assets by FLE Learning, in which case we may disclose your personal
data to the prospective seller or buyer of such business or assets;
- If FLE Learning or substantially all of
its assets are acquired by a third party, in which case personal data held by about its customers will be one of the transferred assets. All third party
organisations are expected to comply with the GDPR themselves and FLE Learning has no influence over the way they use their
data.
8.
Rights of Access to Personal Data
8.1 Delegates have the right under the GDPR to be given access to personal data held about them by FLE
Learning. If a delegate wish to access his/her personal data held by FLE
Learning, a request should be submitted to FLE Learning's Data Protection Officer at info@flelearning.org
8.2 FLE Learning aims to respond to such subject access
requests as quickly as possible and will ensure that any information is
provided within 30 days unless an exemption from the right of access under the
GDPR applies. Some information is exempt from the right of access, such as
details of a third party or disclosure of another individual. FLE Learning also
has the right to withhold information that may cause distress or is damaging to
read. Any references FLE Learning has received by a third party will not be
disclosed unless the disclosure will not identify the source of the
reference.
9.
Accuracy
FLE Learning will endeavour to ensure that
all personal data held in relation to delegates is accurate and up to date.
Delegates must notify FLE Learning of any changes to information held about
them. A delegate has the right to request that inaccurate information about
them is to be corrected.
10.
Security
FLE Learning will take reasonable steps to
ensure that personal data is kept secure and is only accessed by authorised members
of its staff for the purposes for which it is held. All staff will be made
aware of this Data Protection Policy and their duties under the GDPR.
11.
Delegate's responsibility
All delegates have a responsibility to comply
with the General Data Protection Regulation. They should not disclose personal information
about another person without the consent of that person. This includes posting
photographs on the Internet. If a delegate is found to have breached
confidentiality, it will lead to serious implications.
12.
Enforcement
12.1 If a delegate believes that FLE Learning
has not complied with this Policy or has acted otherwise than in accordance
with the GDPR, he/she should notify FLE Learning which shall, where appropriate,
refer the matter for resolution in accordance with FLE Learning’s grievance/
disciplinary procedure (for staff) or complaints procedure (for
delegates).
12.2 This policy forms part of the terms and
conditions of all employees' contracts of employment. A breach of the policy
may be regarded as misconduct, leading to disciplinary action up to and
including summary dismissal.
13.
Changes to Our Data Protection Policy
Any changes we may make to our data
protection policy in the future will be posted on this page and, where
appropriate, notified to you by e-mail. Please check back frequently to see any
updates or changes to our privacy policy.
14.
Our Details
Any
questions, comments and requests regarding our data protection policy are
welcomed and should be addressed to the Data Protection Officer at info@flelearning.org
This Data Protection Policy was last updated on 24th May 2018.