customers and associates.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the websites and International House Bristol. Furthermore, the way these websites and our internal systems process, store and protect user data and information will also be detailed within this policy. We take data protection very seriously and this policy has been written in accordance with the regulations set down by GDPR.
This websites and their owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all UK national laws, GDPR and requirements for user privacy.
At International House Bristol, we collect different types of information about our users & customers for five main reasons:
- To provide personalised services unique to individual users.
- To help us to monitor and improve the services we offer.
- To keep customers up to date about the services and products we offer, or that they have opted into, subscribed to or purchased. By accepting our terms and conditions, you are accepting our use of your data for our own marketing purposes. You can opt out of our serivcs and products at any time by unsubscriing or be sending us an email - firstname.lastname@example.org - to say you want to remove you data.
- To fulfil contracted services.
- If we have permission from the user, to market promotions and services to them.
To make it easier for you to read this policy, it is divided into sections.
- About us
- What data we collect and how we use it
- Legal basis
- How long we keep your data
- Registration for clients and subscribers
- Other uses of your data (the data is anonymised before it is submitted to EUK, IHWO or other bodies)
- Updating your data
- Who we share you data with
- Google Analytics
- About advertising
- Legal information and how to contact us
- External Links
- The protection of your privacy and personal information is important to us. We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us. We do this through processor agreements where appropriate.
- We will respect your privacy. We never share your data with third parties for marketing purposes. You should receive marketing emails only from us. We will make sure that the boxes that you need to tick if you are happy to receive marketing are presented clearly and at the appropriate time.
- We will make it clear at the point at which we request your information, what we are collecting it for and how we are going to use it. In genral, we collect only the data we need to process your application or subscription and provide the services you have requested from us.
- We will collect and use your personal information only if we have your permission or we have sensible, business reasons for doing so, such as collecting enough information to manage your registration or subscription.
- We will minimise the amount of information we collect from you to what we need to deliver the services or products you have requested.
- We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
- We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.
- Our website is accessible via the internet. Please remember that if you post any comments or links on any our sites that they can be read and accessed by anyone and everyone.
- If we, our service providers, or our commercial partners - agents, embassies, scholarship organisations - transfer any information out of the European Economic Area (EEA), it will only be done with the relevant legal instruments or permissions being in place.
What information do we collect about you when you register and how do we use it?
This is the sort of information about you that we collect:
- Personal information - name, address, email, telephone number, passport details, photographs, student id, emergency contact details
- Characteristics - nationality, first language, country of birth
- Any medical information which it is necessary for us to have and pass on to accommodation services or medical services if required
- SEN - Special Educational Needs information
- Travel information - flight details, times, etc.
- Payment information
- Once you are studying with us, we will collate information on your attendance and progress.
This is when we collect information from you:
- When you register for a course or event, including competitions
- When you contact us for information
- When you work with us in a commercial capacity, for example, as a sponsor or partner
- When you sign up for a newsletter
- When you subscribe to our online materials, either free or paid for
- When you download an app
- When you use the website
- Through cookies
- If you choose to reveal information through postings
- If you complete your details on research/feedback questionnaires and
- When you enter sales promotions and competitions
- When you register as a homestay host
- When you register as an agent
- When you are studying in one of our centres, please be aware that CCTV footage is automatically recorded on a daily basis for security purposes and kept for approximately 40 days
- Photos: your photo may be used in our online or print publicity. When you sign our Terms & Conditions, you are agreeing to our use of your image in our online or print publicity. This is your 'opt-in'. If you prefer not to have your image used in this way, please inform us in writing: email@example.com, subject line: Image use.
What legal basis do we use for processing your data?
We use a different legal basis depending on the purpose for collecting your data in the first instance.
- For all data collected to sign up for a service or product such as a newsletter, an event, or a competition, we process the data using Legitimate Interest, i.e. you are able to access an extensive range of information in exchange for supplying your information, you are entitled to certain discounts and special offers, we are in a position to support your job applications or further study through references and we have a relationship where the balance of benefits is in your favour. It is in our interest becasue we are unable to provide you with services unless we have your information. You have a choice in the management of your data in this manner and can opt out of processing under this basis at any time.
- Where you provide data in the course of the purchase of a service or product, we process your data under Contract, i.e. your data is necessary for the fulfilment of the service. Any additional contact, i.e. telling you about another service or product closely related to the service or product you have bought is managed under Legitimate Interest.
- Any secondary processing of your data, i.e. sharing with third parties, sending you a message on behalf of third parties, transfer to third countries, is managed under Consent.
Under the terms of current data protection legislation, we will always make it as easy as possible for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the service you have requested.
How long do we hold onto your data?
We collect data for a wide range of purposes. We retain your data until such time as you ask us to remove it. After you ask us to remove your data, the data is managed to ensure that it is either erased from our system, minimised and retained for legal reasons or pseudonymised and retained on a global suppression list to ensure that you do not receive unwanted messaging from us.
Registering as a subscriber or delegate
The minimum information we need from you to register either as a student, subscriber or delegate is your name, title, address, date of birth, telephone number and email address. We will only ask you more questions for different services, accommodation or marketing emails, for example. Unless we say otherwise, you must answer all the registration questions.
We may also ask you some other voluntary questions during registration (for example, demographic questions) so we can gain a clearer understanding of who you are. This enables us to assess whether you qualify for a free subscription or registration, need to be invited to a specific event or have specific products delivered to you. We may also use these details to create anonymised audience information for our sponsors and partners to facilitate their advertising or commercial decision-making process.
We will process data collected for the purpose of facilitating your registration or subscription on the basis of Legitimate Interests to deliver the service for which you have registered, oted in to or subscribed. We may contact you occasionally about other relevant services and products which we think will interest you. You always have a choice and can opt out of the processing on this basis at any time by contacting us at firstname.lastname@example.org with the subject line: Opting out of data processing.
Other uses of your data
We do not sell your data at any time. We will only share your data with our sponsors and commercial partners (embassies and agents) with your permission. If you book via an agent or are sponsored by an embassy, your data is shared with the agent or embassy. See Who we share your data with below. Data is only shared for your benefit, to enable service or to fulfill a legal requirement.
Use of children’s data
We only collect or store any personal information about children under the age of 16 in the context of their being a student or subscriber and for the purposes of providing them with the services and products requested. This is applicable also to young people under 18 and to all those where permission is obtained directly from a legal adult (parent or guardian) to collect this information.
Updating your personal information
You have rights to your information. You have the right to request access to the information we hold about you. You also have the right to:
Amend, Rectify, Erase, Restrict, Block, Destroy your personal information
Object to data processing which is causing or is likely to cause distress or damage
Claim compensation for damages caused by a breach of GDPR regulations
You have these rights as the data subject or, for parents and carers of under 18s, as the teh parent/carer of a data subject.
Who we share data with
Your personal information may be shared with:
* Host families, residences, letting agents, hotels, B&Bs and other accommodation providers where you have requested accommodation services
* Industry bodies of which we are a member or to whom we subscribe such as International House World Organisation, English UK, Accreditation UK, the Bristol Council, Cambridge ESOL, Trinty College
* Agents (ETOs and Introducers ) who help you to arrange your travel to Bristol and stay in the UK; embassies where you course is arranged through your embassy in the UK; teachers and school bodies who arrange trips to the UK of which you are a part
* UK Visa and Immigration services when they ask us for information about you
* Airport pick-up service companies adn taxi compnaies when you ask us to arrange transport for you in the UK
* Coach companies when you ask us to arrange soical events for you
* We take photos and videso of students at our social events and at other times during the school day. These are often uploaded to social media sites such as Instagram, Facebook and Twitter
We will not share your information with others for marketing purposes unless you give your permission. We do not currently share information for marketing purposes with any third parties.
We can access and release personal information to keep to relevant laws and government requests, to operate our systems properly and to protect both us and our users.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA or countries deemed adequate by the EDPB.
- For statistical purposes to track how many users we have and how often they visit our websites. We collect information listings on which of our pages are most frequently visited, and by which types of users and from which countries.
- We use other organisations to collect anonymised user information, sometimes through cookies and web beacons, (information embedded in images which allow them to analyse how the website is being used and the number of visitors, e.g. how many people clicked on the Learn French in Bristol link or visited our Useful Expressions page).
- We may use ‘Flash’ cookies to store your preferences for your media player (for example, volume and so on). If we do not use them, you may not be able to watch some video contact. All of our videos are broadcast on YouTube, Vimeo and 3rd party video sharing applications which are embedded on our own website.
- You can turn cookies off but if you do this, you may not be able to use all services on our websites and you might see more pop-ups and other advertising. This is because we won’t be able to limit what you see by using cookies. However, you will still be able to see our editorial content.
We use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. If you would like to opt out of Google Analytics monitoring your behaviour on our sites, please use this link: https://tools.google.com/dlpage/gaoptout.
About our Advertising
We may share anonymised behavioural data with advertising partners, including commercial organisations that fund content labelled ‘Supported By’, ‘Paid content/Paid for by’ or ‘Sponsor content/from our sponsors’. This may mean that when you are on other websites, you will be shown advertising based on your behaviour on IH Bristol’s website. We may also show you advertising on our site based on your behaviour on other sites.
If you want to opt of receiving online behavioural advertising, this does not mean that you will no longer receive advertising when you are using our sites, it just means that the advertising you see will not be customised for you.
Sometimes we also use Google Adwords Remarketing and Similar Audiences, LinkedIn Matched Audiences and Facebook Lookalike Audiences services to advertise on third party websites (including Google, LinkedIn and Facebook advertising networks) to previous visitors to our site or users with similar interests. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example, using the contact name to make an enquiry, or users with interests like our previous visitors.
It you wish to opt out of Google Remarketing or Similar Audiences, you can do so by visiting Google Ads Settings here: support.google.com/ads/?????/2662922?hl=en-GB.
If you want to opt out of receiving online behavioural advertising (OBA), this does not mean that you will no longer receive advertising when you are using our sites. It just means that the advertising you see will not be customised for you. If you would like more information about OBA and how to opt out of it, please visit: https://www.youronlinechoices.com/uk or optout.networkadvertising.org.
Advertising on mobile devices may require the collection and sharing of the unique device ID with companies who purchase advertising space on the mobile application.
Legal Information and how to contact us
Under the currently applicable laws, we have assessed with help from ICO that we do not have to have a namde DPO for IH Bristol services and products provided via our websites, newsletters, events and other products and services. The data controller is the organisation responsible for protecting information and in our case, is IH Bristol. You can contact the data controller via email to email@example.com.
If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the data manager by email firstname.lastname@example.org or 01179090911.
Requests will be dealt with by the DM and will be responded to within a reasonable period no longer than 30 days.
If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority:
Information Commissioner’s Office
Tel: +44 303 123 1113
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, who may have detailed privacy policies relating directly to the adverts they serve.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons, which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls (this is an example: http://bit.ly/zyVUBo).
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Resources & Further Information
- Privacy and Electronic Communications Regulations 2003
- Privacy and Electronic Communications Regulations 2003 - The Guide
v.4.0 March 2019 Edited & customised by: International House Bristol