Privacy Notice for Tutors 

Fleet Tutors, a division of Fleet Education Services Limited (the ‘Company’), is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR). It applies to all tutors.

Fleet Tutors is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former tutors. This policy does not form part of any contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practicable.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

The Company is an education service provider which provides education services for clients and work-finding services to its work-seekers (“tutors”) whom it places with clients to provide tutoring for students. The Company must process personal data (including Special Category personal data) so that it can provide these services – in doing so, the Company acts as a data controller. This notice pertains to how the Company processes data with respect to work-seekers. There is a separate privacy policy which pertains to how the Company processes client and student data. 

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws. 

 

Collection and use of personal data 

a. Purpose of processing and legal basis 

The Company will collect your personal data (which may include Special Category personal data) and will process your personal data for the purposes of providing you with work-finding services and related marketing. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. 

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards. 

The legal bases we rely upon to offer our work-finding services to you are: 

Where we have a legitimate interest 

To comply with a legal obligation that we have 

To fulfil a contractual obligation that we have 

Your consent 

b. Consent 

The Company will seek your specific consent to process data relating to your health, our ability to undertake regular and ongoing status checks with the Disclosure and Barring Service and any criminal convictions. If you have opted-in we may also send you various company and sector news, career development advice and courses, and job alerts via email/ text. You can opt-out from receiving these at any time by emailing ClientSupport@fleet-tutors.co.uk. 

c. Legitimate interest 

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows: 

Managing our database and keeping work-seeker records up to date 

Providing work-finding services to you and our clients 

Contacting you to seek your consent where we need it 

Giving you information about similar products or services that you have used from us recently 

d. Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data. These include, but are not limited to:

To comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 

Immigration and tax legislation 

To carry out pre-engagement vetting checks, including but not limited to:

▪ To comply with the Safeguarding Vulnerable Groups Act 2006 

▪ To comply with the Department for Education statutory guidance (Keeping Children Safe in Education) to verify your physical and mental fitness to teach and/or work with children 

▪ To comply with the Education (Health Standards) (England) Regulations 2003 to verify your suitability to work in regulated activity with children 

▪ Verify your right to work 

Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect then we will be unable to continue to provide work-finding services to you. 

e. Recipients of data

The Company will process your personal data and/or Special Category personal data with the following recipients: 

Clients (whom we may introduce or supply you to) 

Former employers whom we may seek references from 

Named individuals you provided for seeking a reference from 

Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to 

Third parties which provide, host and/or support our IT systems and software (subject to appropriate security measures) 

Capita plc for the purposes of carrying out DBS checks 

GOV.UK, the Disclosure and Barring Service and Department for Education for performing criminal records update checks, qualification checks, teacher sanction and restriction checks and the overall protection of vulnerable groups 

Teaching Regulation Agency and Education Workforce Council to perform teacher status checks 

HMRC for audit purposes and the provision of employment and payroll information 

Pension providers 

UK Government’s Visas and Immigration and the Home Office for checking right to work status 

Overseas criminal records agencies and law enforcement agencies if you have been resident outside of the UK in the last 5 years for at least 6 months 

Audit and accreditation providers, such as The Recruitment and Employment Confederation (REC) and the International Organization for Standardization (ISO) 

Any of our group companies, including EdPlace Limited, that may need to know the details of your personal data for the purposes of carrying out their services to our clients and students.

f. Partners and Group Company Responsibilities

Fleet Tutors is part of the Supporting Education Group family of companies. We may share your personal information with our group companies as necessary to carry out the purposes for which the information was supplied or collected (i.e. to carry out services to our clients and students).

Please be assured that we have put in place data privacy compliance measures to ensure that those companies comply with data protection obligations and your data is kept safe and secure. In particular, we ask our group companies and partners to do the following:

Obtain explicit consent from their students or their students’ guardians before sharing personal data with Fleet Tutors;

Ensure data accuracy and integrity;

Implement appropriate security measures to protect personal data;

Inform Fleet Tutors of any data breaches or security incidents involving their tutors’ or students’ data.

 

The Company may have collected the following personal data on you in addition to information you provided

Personal data: 

  • Contact details, CV, type of candidate, subject specialisms, focus areas and work preferences when provided on job boards and/or professional/social networks 
  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Next of kin and emergency contact information
  • Bank account details, payroll records and tax status information
  • References 
  • Client feedback 
  • Consultant notes 
  • Online activity specific only to the Company’s websites 

Special category personal data:

  • Health information in accordance with the Education (Health Standards) (England) regulations 2003 
  • Criminal conviction and record checks strictly adhering to all established codes of conduct and processing 

Source of the personal data: The Company sourced your personal data personal data: 

  • Former employer 
  • A referee whose details you provided to us 
  • Various Jobs boards and aggregators, such as indeed and Reed 
  • Various professional networks, such as LinkedIn 
  • Various applicant processing and job posting platforms, such as Broadbean and Idibu 
  • Cookies 

This information did not come from a publicly accessible source. 

 

Overseas transfers 

The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. 

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us at dataservices@judicium.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. 

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years. 

There is a legitimate interest to hold your personal data for no longer than 6 years after our work-finding service relationship ends. 

Where the Company has obtained your consent to process your personal data and Special Category data, we will do so in line with our retention policy. 

Where consent is not granted the Company will cease to process your personal data and Special Category personal data. 

 

If you have any questions about our data retention policy, you can email the Data Protection Officer at dataservices@judicium.com. 

Your rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your erasure request for specific legal reasons or if doing so would impact upon our tuition customers. You will be notified that we are unable to comply for these reasons, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide work-finding services to you. We will advise you if this is the case at the time you withdraw your consent.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  
We will try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above. 

Cookies 

We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. 

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser. 

Log files 

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. 

Links to external websites 

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website. 

Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. 

Data security

The Company has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Security measures include, but are not limited to, the use of firewalls and endpoint protection, browser certification technology, encryption, limited access principle, malware protection, and use of artificial intelligence based ransomware and exploit protection. 

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. 

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. If you have any questions about the security at our website, you can email dataservices@judicium.com. 

Changes to this privacy statement 

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you. 

Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact the Data Protection Officer using the details above. 

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.