Gaia Learning Ltd is committed to protecting you, and your family’s personal information. This Privacy Notice, together with any other documents referred to within, sets out the basis on which we will process any personal data about current, past and prospective pupils (referred to as “pupils” in this Privacy Notice), and their parents, carers or guardians (referred to as “parents” in this Privacy Notice).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Gaia Learning Ltd is the Data Controller and is committed to protecting the rights of individuals in line with the Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR).

Gaia Learning Ltd has a Data Protection Officer who can be contacted via email, dataprotection@gaialearning.co.uk

Gaia Learning Ltd is committed to safeguarding all personal information. We are legally obliged to use your information in line with all laws concerning the protection of personal information, including the General Data Protection Regulations, 2018 (these laws are referred to collectively in this Privacy Policy as the “data protection laws”).

What information will Gaia Learning Ltd collect about me?

Gaia Learning Ltd will collect information from pupils and their parents via its website and directly during the admissions process and throughout the period during which we are providing education.

Gaia Learning Ltd may also collect information from third parties, such as previous schools and/or education providers, social services, local authorities and the DfE.

Gaia Learning Ltd will collect the following information about pupils and their parents:

• name, email address, postal address, telephone number and other contact details;
• date of birth;
• bank details and other financial information;
• academic records including test and examination results;
• details of any support received including plans and support providers;
• safeguarding records;
• health information;
• references received from previous schools or education providers;
• references given to future schools or education providers;
• correspondence between Gaia Learning Ltd and pupils and/or their parents.

How will Gaia Learning Ltd use the information they collect about me?

Gaia Learning Ltd will use your personal information for the purposes of providing information about services and providing education. This may include, but is not limited to:

• Safeguarding and promoting the welfare of students
• Administering finance
• Providing school access
• Monitor and report on Pupils’ progress
• Provide appropriate pastoral care
• Ensuring students’ safety and security

The data will not be used to make automated decisions.

What is our legal basis for processing your personal data?

For processing to be lawful under the GDPR, Gaia Learning Ltd must establish a lawful basis before processing personal data. Most commonly, Gaia Learning Ltd will use the personal information of its pupils and parents in the following circumstances:

• To perform the contract between Gaia Learning Ltd and pupils/parents
• To comply with a legal obligation
• To protect the interests of the pupils/parents (or someone else’s interests)
• Where it is necessary for legitimate interests pursued by us or a third party (see below)

On rare occasions, Gaia Learning Ltd may use the personal information of its pupils and parents where it is needed in the public interest.

If none of these reasons apply, we will ask for the consent of the pupil or parents before processing their personal information.

What is legitimate interest?

The legal basis of legitimate interest means that we will process personal data based upon an interest of the individual, Gaia Learning Ltd or a third party. Where there is a legitimate interest for processing personal data, Gaia Learning Ltd will consider whether the processing is necessary for the purpose and whether the interests of the individual override the legitimate interest before processing personal data.

The following legitimate interests may apply:

• To provide details about our services
• To give and receive references and information about pupils and their parents during the admissions stage
• To meet pupils’ educational needs
• To enable Gaia Learning Ltd to monitor pupils’ home education and progress
• To enable relevant authorities to monitor pupils’ home education and progress
• To enable relevant authorities to monitor Gaia Learning Ltd’s performance as an education provider
• To safeguard pupils and provide pastoral care
• To keep in touch with former pupils and their parents
• To obtain professional advice

How long will your information be held?

Gaia Learning Ltd will ensure that no personal data is kept for longer than is necessary for the purpose for which it was provided, whilst also fulfilling all legislative obligations. Please see the Gaia Learning Ltd Data Retention Policy for more information.

Will Gaia Learning Ltd share my personal information with anyone else?

We will keep your information confidential. It will be shared with teachers and employees of Gaia Learning Ltd for the purposes of administering education to pupils.

It may also be necessary for Gaia Learning Ltd to share personal information with third parties, such as:

• Professional advisers, such as lawyers, accountants and insurance providers
• Relevant government authorities, such as the DfE, HMRC, local authorities or police
• Regulatory bodies, such as OFSTED/ISI
• Other education providers, such as examination boards
• Third-party service providers, such as IT service providers

We do not disclose personal information about pupils or parents to advertisers or sell your information to any other organisation for marketing purposes.

How does Gaia Learning Ltd keep my data safe?

Gaia Learning Ltd has put in place appropriate technical and organisational steps to ensure the security of personal data about pupils and their parents. These include ensuring all company computers have up-to-date anti-virus protection and the use of granular user permissions to restrict user access to the required level for their role.

Gaia Learning Ltd will securely dispose of personal data when it is no longer required.

Cookies and Site Statistics

We do gather non-personal data regarding site visitors to our website. This is provided to use statistical information on visits to pages, type of browsers being used to view the site, paths taken through the site and other general information. Under no circumstances can this be linked to a particular person.

A “cookie” is a small text file, which helps the server to identify your computer but not the individual. The cookies help us to make your visitor session a more personal and enriching experience. If you wish not to have this facility you are able to disable cookies using that option in your particular browser’s settings. Alternatively, you can opt out of collection of information by using the following services:

• Digital Advertising Alliance
• Your Online Choices

What are your rights?

Data protection laws provide that the data we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should be kept up to date, where necessary, and not retained for longer than is necessary. It should be kept securely to prevent unauthorised access by other people.

The individual about whom the data relates (the data subject) has rights under data protection laws. It is generally regarded that pupils aged 13 or above have sufficient maturity to assert their rights under data protection law, although we will judge this on a case-by-case basis.

As a data subject, you have a right to access your personal information, to object to the processing of your personal information, to rectify, to erase, to restrict and to port your personal information. Please contact Gaia Learning Ltd’s Data Protection Officer for more information or advice on this.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Gaia Learning Ltd’s Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to make a complaint

If you are unhappy with the way in which your personal data has been processed you may in the first instance contact Gaia Learning Ltd’s Data Protection Officer using the contact details above.

If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision.

The Information Commissioner can be contacted at:-

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

www.ico.org.uk