PRIVACY POLICY

Privacy Policy

Information for you about how we look after personal information about yourself and your child or children.

1. Background
On 25th May 2018 a new law comes into place. It is known as the General Data Protection Regulation (GDPR). There is a lot of terminology used within the GDPR, but basically this is about how personal information is collected about you and your child or children’s study with us and how we use and look after it. This document sets out the detail about how the personal information provided will be used and looked after and explains your rights in relation to it.

2. Our commitment to you
Our commitment is to:

• Keep personal information about you and your child or children safe and private;
• Not use personal information for any purpose other than in connection with your children’s studies, keeping you informed of information about the Tutorwiz Ltd business, to continue to develop the Tutorwiz Ltd business to deliver the most effective and rewarding student experience possible and in accordance with the other purposes set out in this notice;
• Make it easy for you to approach us if you have any concerns or questions relating to the holding of personal information;
• Not provide personal information to others save where legally required to do so or to assist us with our tasks.

3. Who we are and how we operate
Tutorwiz Ltd is the leading supplementary education brand in the UK & Ireland and offers Maths and English study programmes for children of all ages and abilities.

The company is responsible for and motivated to provide the Tutorwiz Ltd study programme at the highest level possible. It interacts closely with operation in other countries in a continuing process of seeking to refine and improve the effectiveness of the study programmes and the student experience.

To effectively operate Tutorwiz Ltd require personal information concerning parents and legal guardians (parents) and the students. We set out in this document what personal information is collected and how it is used.

The term Data Controller is applied to a business which determines how personal information about yourself and your child or children is used.

Your study programme tutor is known as a Data Controller. His or her details are set out in a schedule to the document. Tutorwiz Ltd also requires personal information for similar, but slightly different purposes. As such Tutorwiz Ltd is also a Data Controller, but a separate one. The contact details of the individual with overall responsibility for personal information held by Tutorwiz Ltd is set out in a schedule to the document.

4. How information is collected from you
Information in relation to parents and students will be collected by Tutorwiz Ltd. This might be achieved by providing information verbally, whether face to face or by telephone, completion of paper documents or by electronic means such as through email or interaction with our websites. Please ensure that all personal information is accurately provided as the information which is held is only as accurate as the information provided in the first place.

If any of the personal information provided changes, please notify Tutorwiz Ltd as soon as possible in order that the personal information can be updated.

5. What personal information will Tutorwiz Ltd collect from you?
Tutorwiz Ltd will require the following information about the student:

• Name;
• Address;
• Contact details;
• Date of birth;
• Schooling related information;
• Gender;
• Health related information and other information relevant to being able to teach the student most effectively;
• As the student’s studies progress Tutorwiz Ltd will accumulate information in relation to the student’s work and its progression.

Information which will be required from parents/legal guardians:

• Name;
• Contact details;
• Relationship to student;
• Details of others who are authorised points of contact if a primary contact is not available;
• Any other information which may be provided, and which is relevant to the education of your child or children.

Tutorwiz Ltd may also ask for or receive contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and whether the student is a native English speaker.

Tutorwiz Ltd will not seek any further personal information in relation to parents or students without gaining specific authority.

Tutorwiz Ltd will not take or publish photographs of students or publish students’ names without your consent as the parent/legal guardian.

6. Who will Tutorwiz Ltd provide personal information to?
Tutorwiz Ltd will provide the personal information referred to above for it to use for the purposes set out below.

Tutorwiz Ltd will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators, for example Ofsted, or unless it is otherwise provided for in this Privacy Notice.

7. What about outsourcing by Tutorwiz Ltd?
It is possible that Tutorwiz Ltd will pass personal information to other organisations to assist him or her. This is not for other organisations to use on their behalf but rather to process information on Tutorwiz Ltd’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, training and printing.

8. What will Tutorwiz Ltd use the personal information for?
To fulfil his or her contractual obligations and to respond to enquiries:

• to provide the course of study;
• administer the course of study;
• ensure the quality of the programmes;
• to respond to enquiries about the study offered;
• to seek feedback about study experiences;
• to address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;
• to record and/or report upon the progress of the student;
• to consider, record and communicate other issues which may be impacting upon or related to the progress of the student;
• to respond to complaints.

To ensure vital interests:
This relates to the health and safety of a student. For example, if there was a medical emergency Tutorwiz Ltd may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.

When it is Tutorwiz Ltd’s legal duty
Tutorwiz Ltd may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

When legitimate interests apply
It is possible that from time to time Tutorwiz Ltd may wish to communicate with parents concerning other matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:-

• To inform parents of potential career opportunities with Tutorwiz Ltd;
• Providing news updates about developments within Tutorwiz Ltd. This might for example be in relation to changes to the Tutorwiz Ltd programme, information relating to it, educational meetings and 11+ meetings;
• To communicate about particular study opportunities and useful information about Tutorwiz Ltd study, for example particular trials, promotions and campaigns.

Any communication under this heading will be of the nature referred to above. Tutorwiz Ltd will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.

If you do not wish to receive communications under this heading, please contact Tutorwiz Ltd and let us know which type of communications you would not wish to receive. If you receive this notice electronically you can do so by clicking the link in the Schedule.

When you consent
There are certain uses to which Tutorwiz Ltd will not put personal information without your specific consent. Where such consent is requested it will be sought separately. It is likely to be in areas such as in photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies.

If consent is given it can be withdrawn at any time by providing notification to Tutorwiz Ltd in writing or by email.

Other
Tutors may also use personal information for management and statistical purposes to enable better running of our Study Centres.

9. What personal information may Tutorwiz Ltd collect from you directly?
We have already indicated what information Tutorwiz Ltd may collect from you.

Sometimes early exchanges of information will be with Tutorwiz Ltd. This section deals with those and other circumstances.
In such circumstances Tutorwiz Ltd is likely to require the following information about the student:

• Name;
• Address;
• Contact details;
• Date of birth;
• Schooling related information;
• Gender.

Also, Tutorwiz Ltd is likely to require the following information from parents/legal guardians:

• Name;
• Contact details;
• Relationship to student;
• Details of others who are authorised points of contact if primary contact is not available;
• Any other information which may be provided, and which is relevant to the education of your children.

10. Who will Tutorwiz Ltd provide personal information to?
Tutorwiz Ltd will provide the personal information referred to in the preceding paragraph to Tutorwiz Ltd for him or her to use for the purposes set out above.

On occasion, Tutorwiz Ltd may seek student data for statistical purposes and to assist it in refining and further developing (i) employee training and (ii) the materials and instruction techniques. Tutorwiz Ltd processes the data in a statistical manner and no personally identifiable data is retained any longer than 24 months after your child or children have ceased to attend the programme without a legitimate reason to do so. We will ensure that appropriate technical and organisation measures are in place such that this data is shared with Tutorwiz Ltd in a secure way and that it is stored in a secure way.

Tutorwiz Ltd will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, or otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators, for example Ofsted, or unless it is otherwise provided for in this Privacy Notice.

11. What about outsourcing by Tutorwiz Ltd?
It is possible that Tutorwiz Ltd will pass personal information to other organisations to assist it. This is not for the other organisations to use on their behalf but rather to process information on Tutorwiz Ltd’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, printing and training. This might include the transfer of personal information outside of the European Union and if this is the case security measures will be taken to protect the integrity and security of the data.

12. What will Tutorwiz Ltd use personal information for?
Tutorwiz Ltd has day-to-day responsibility for the operation and interaction with parents and students. However, there will be times when for one reason or another Tutorwiz Ltd is not able to undertake a task and in so doing will make use of the personal information. Tutorwiz Ltd will also use personal information to seek to refine and improve the effectiveness of the study programme and the student experience.

Tutorwiz Ltd may therefore use personal information for the following purposes:-

To help Tutorwiz Ltd fulfil contractual obligations and to respond to enquiries:-

• to provide the course of study;
• administer the course of study;
• ensure the quality of the programmes;
• to respond to enquiries about the study offered;
• to seek feedback about study experiences;
• to record and/or report upon the progress of the student;
• to record and communicate other issues which may be impacting upon the progress of the student;
• to respond to complaints.

To ensure vital interests:
This relates to the health and safety of a student. For example, if there was a medical emergency Tutorwiz Ltd may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.

To comply with Legal Duties
Tutorwiz Ltd may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

When legitimate interests apply
This falls into two broad categories:

1. Work undertaken in refining and improving the effectiveness of the study programme and improving the student experience; and
2. Communicating news including news in relation to Tutorwiz Ltd’s operation, study and franchise opportunities.

The first category includes:-

• Research and development purposes;
• Market research;
• Training of new and experienced employees;
• Performance analysis;
• Support for students;

Any processing of personal information under this category will be of the nature referred to above. Tutorwiz Ltd will not process personal information under this category where there is any perceived detriment to you or your children in undertaking the processing.

Tutorwiz Ltd may need to process some personal information of this nature for measurement and statistical purposes as referred to under the ‘Other’ heading but if you do not wish Tutorwiz Ltd to process personal information for the above purposes please contact Tutorwiz Ltd using the contact details set out in the Schedule.

The second category:
It is possible that from time to time Tutorwiz Ltd may wish to communicate with parents concerning matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:-

• Providing news updates about developments at Tutorwiz Ltd;
• To communicate about particular study opportunities and useful information about Tutorwiz Ltd study, for example particular trials, promotions and campaigns;
• Provision of information and consultation in relation to your child or children.

Any communication under this category will be of the nature referred to above. Tutorwiz Ltd will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.

If you do not wish Tutorwiz Ltd to process personal information for the above purposes please contact Tutorwiz Ltd using the contact details set out in the Schedule.

When you consent
There are certain uses to which Tutorwiz Ltd will not put personal information without your specific consent. Where such consent is requested it will be sought separately. It is likely to be in areas such as in photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies and using your children in case studies for training purposes.

If consent is given it can be withdrawn at any time by providing notification to Tutorwiz Ltd in writing or by email.

Other
We may also use personal information for measurement and statistical purposes.

13. What happens if I don’t wish to provide personal information to Tutorwiz Ltd?
Tutorwiz Ltd require the personal information set out in this privacy notice to ensure that the Tutorwiz Ltd programme can be safely and effectively delivered to your children and continually developed and improved for the benefit of your children. Without this information it will not be possible to deliver the services for the benefit of your children or at least not as well as we would like. We have though set out above some purposes for which Tutorwiz Ltd wish to use personal information under the heading of “Legitimate interests”. If you do have an objection to any personal information being used under this heading, you may object to Tutorwiz Ltd. If Tutorwiz Ltd wish to gather personal information for which consent is required they will obtain that specific consent before gathering that information and you have the right not to provide such information.

14. How long will you keep personal information for?
Tutorwiz Ltd will only retain personal information:

• For as long as necessary to fulfil the purposes it was collected for as set out in this Privacy Notice;
• In relation to those that enquire about the services which we can provide we would not normally keep that information for longer than 12 months after the last communication from the enquirer;
• In some circumstances you have the right to request erasure of personal information held. This will be addressed below.

15. Your rights in relation to the information held in relation to you or your children
Access – the right to make what is known as a Subject Access Request to either a copy of the personal information which we hold about you or your children. If you make such a request we are required, in most circumstances, to provide a copy of the personal information without charge and within 30 days. You may also seek confirmation of the personal information that Tutorwiz Ltd hold about either you or your children.

Correction – it is important that you keep Tutorwiz Ltd up to date with any changes to the personal information provided. Subject to that you have the right to ask Tutorwiz Ltd, as appropriate, to correct or complete any inaccurate or incomplete data held about you or your children. It is possible that evidence will be required of the new information provided.

Erasure – you are entitled to ask Tutorwiz Ltd to delete or remove personal information held where there is no good reason for Tutorwiz Ltd to continue to hold it. It may not always be possible to comply with your request due to ongoing obligations in relation to the personal information. However, where this is the case you will be informed and be told of the reasons why it is not possible to comply with the request.

Object to processing – you may object Tutorwiz Ltd processing personal information. There are some circumstances in which it will not be possible to comply with your request, for example if it is necessary to process the information in connection with obligations which Tutorwiz Ltd (as appropriate) have and which have been explained to you in this document. If you object to Tutorwiz Ltd processing information which has been processed under the legitimate interest head, we will stop processing it.

Restriction of processing – you may ask Tutorwiz Ltd to suspend processing of personal information in the following situations:

• If you want the data accuracy to be established;
• Where the use of the personal information is unlawful, but you do not want it to be erased;
• You need the data to be held even though Tutorwiz Ltd (as appropriate) no longer require it as you need it to establish, exercise, or defend legal claims; or
• You have objected to the use of the data by Tutorwiz Ltd but Tutorwiz Ltd (as appropriate) need time to determine whether they have overriding legitimate grounds to process it.

Request the transfer of information – sometimes rights apply to request a transfer of personal information held to other organisations. This right only applies to personal information that is processed by automated means and is held because it was necessary for the performance of the contract with you or personal information which is processed based on consent.

16. Keeping personal information safe
Tutorwiz Ltd have put in place appropriate security measures to prevent the personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal information is limited to those employees and contractors who have a business need to know the personal information and will only be processed upon instructions from Tutorwiz Ltd (as appropriate) and procedures had been put in place to deal with any suspected breach of the requirements under the GDPRs and you and/or the Regulator referred to below will be notified of any potentially significant breach.

17. What happens if you want to complain?
It is hoped that you will not have cause to complain. If you do complaint relating to Tutorwiz Ltd should be referred to Tutorwiz Ltd directly where possible. If it is not possible or appropriate to refer a complaint to Tutorwiz Ltd it may be referred to the Regulator. This will vary depending upon whether you are based in the UK or Ireland. For the UK the contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

For more information contact www.ico.org.uk

In Ireland the contact details are:
Office of the Data Protection Commissioner
Canal House
Station Road
Port Arlington
Co. Laois
R32 AP23

For more information contact www.dataprotection.ie

18. Miscellaneous

• It is not anticipated that any personal information will be transferred outside of the European Union save where specifically set out in this Notice. We will notify you if this position changes.
• Tutorwiz Ltd anticipate using automated decision making in relation to the personal information provided.
• This Privacy Notice may be updated from time to time. The latest Privacy Notice will be displayed Tutorwiz Ltd website.

19. If I have any questions who do I ask?
Please ask your tutor or contact Tutorwiz Ltd using the details in the Schedule.

Dated 1 August 2018

Schedule

Contact information
Unit 2C
Crowborough Business Park
Park Road
Crowborough
East Sussex
TN6 2GZ

Info@tutorwiz.uk
0800 181 4221

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Terms of Use
www.tutorwiz.uk is a site operated by Tutorwiz Limited.

Company Information
Tutorwiz Limited
Company registration number: 11243796
Company registration address: Unit 2C, Crowborough Business Park, Park Road, Crowborough, East Sussex, TN6 2GZ
Registered in England
Main trading address: Unit 2C, Crowborough Business Park, Park Road, Crowborough, East Sussex, TN6 2GZ

Terms of Use
Please read the following terms of use for this website carefully before you start to use our website. By using our website, you confirm that you accept these terms of use and agree to comply with them. If you do not agree to these terms you must not use our website.

We may revise these terms at any time by amending this page; please check this page regularly to take notice of any changes, as they are binding.

Data Protection
Personal data entered into this website is treated as confidential and will be dealt with in accordance with Data Protection Act 1988.

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Tutorwiz Limited is the licensee of all the Intellectual Property rights on our site, and in the material published throughout it. Those works are protected by copyright law and treaties around the world. The content of this website is protected under the Intellectual Property laws of England and Wales. All such rights are reserved. You acknowledge that you must not modify, copy, distribute, reproduce the website or any of the Intellectual Property Rights on our website.

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The use of this website is at the user own risk. Tutorwiz Limited may update our website from time to time and may change content at any time. Tutorwiz Limited do not guarantee that this website will be free from errors and omission and therefore Tutorwiz Limited makes no representations and warranties of any kind whether expressed or implied relating to the accuracy of this website.

Tutorwiz Limited accept no liability for any damage, loss or consequential loss arising or in connection with using or the inability to use our website and/or the reliance of information and content obtained from our website.

Tutorwiz Limited do not guarantee that our site is free from viruses or any other technologically harmful material and therefore Tutorwiz Limited accept no liability for loss or damage in relation to viruses that may affect your computer equipment, computer software, data, programs and any other material due to the use of our website. Please ensure you have adequate protective measures to protect yourself against loss or damage.

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Third Party Linking
The website may refer to other websites or provide links to third party websites, use of these other websites is entirely at the user’s own risk. Where our website provides links to third party websites these inks are provided for your information only. Tutorwiz Limited have no control over the content of those websites and therefore this should not be seen as an endorsement from Kumon UK.

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If you have any comments or queries relating to our website, please contact us at: info@tutorwiz.uk