WHO WE ARE
We are Talis Education Ltd. Our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
We provide a hosted, online platform that enables an education establishment to manage and administer its reading lists and digital content for use by its teaching staff and students.
THE PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL DATA
We collect and process personal data as follows:
|If you are a member of staff at an educational establishment to which we provide services and we communicate with you in relation to the provision of the services concerned||We may collect your individual contact information (including your name, the user ID we allocate to you, your email address, your phone number and where you work – for example, your educational establishment) to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of our services to you or the educational establishment that you work for (for example, in relation to the management and administration of the provision of the relevant services, or the provision of support services), together with other personal information relating to you that you provide in the course of provision of the services concerned.|
|If we wish to send you advertising, marketing or promotional material||We may collect your individual contact details in order to send you direct marketing material in order to advertise, market or promote our services. We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you use our services or browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.|
|If you provide goods or services (or you work for someone who supplies goods or services) to us||We may collect your individual contact information to enable us, our group companies or other suppliers of ours or our group companies to communicate with you in relation to the provision of goods or services by you or the person that you work for (for example, in relation to the management and administration of the provision of the relevant goods or services) and other personal information relating to you to in the course of provision of the goods or services concerned. This may include, for example, bank account or other financial details, and other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the goods or services.|
|If we are assessing your suitability or ability to provide goods or services to us or to any of our group companies||We may collect relevant personal information relating to you to the extent necessary to enable that assessment to take place – for example, if we need to assess or confirm your age, your right to work in the UK, your skills and previous experience, your qualifications or whether there is anything that would adversely affect your suitability or ability to provide the goods or services concerned. This will be explained to you in more detail at the time we collect the personal data and, where appropriate, will be subject to your prior consent.|
|If you are invited to, or attend, an event organised or managed by us||We may collect your individual contact and related information (as well as that of anyone who is attending the event with you) as necessary to enable you and any other relevant individuals to be invited to, and to attend, the event and to facilitate your attendance (for example, dietary or special access requirements).|
|If you apply for a position with us||We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.|
|If you are an academic or other member of staff or a student at an educational establishment to which we provide services and the educational establishment allows you to register on, and use, our online platform||We may collect the user ID that we allocate to you, email address, password and sometimes your name, together with information about your use of your educational establishment’s resources (including reading lists and digital content) hosted on our platform. In that case, in doing this, we will generally be acting as a data processor on behalf of the relevant educational establishment, and any processing of your personal data by us will be solely in accordance with the relevant educational establishment’s instructions and under their control.|
WHERE WE PROCESS YOUR PERSONAL DATA
We are established in the UK and the systems which we use to process your personal data are hosted here or elsewhere in the EU.
Where necessary in order to manage our business, we may share relevant personal data with our group companies or suppliers outside the EU, but only to the extent necessary in order to provide the services concerned.
SECURITY OF YOUR PERSONAL DATA
All personal data processed by us is stored securely (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access
WHO WE SHARE YOUR PERSONAL DATA WITH
We may where appropriate share your personal data with:
- Any member of our group, which means our subsidiaries, our holding company and its subsidiaries.
- Appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- our auditors, legal advisors and other professional advisors or service providers;
- credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
- In relation to information obtained via our website, analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to our cookies policy.
OTHER DISCLOSURES WE MAY MAKE
We may disclose your personal data to third parties:
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the person that you work for; or to protect the rights, property, or safety of our business, our group companies, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, or credit risk reduction.
THE LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
The legal basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (in relation to any processing we are carrying out with your consent, see below for how to withdraw your consent).
- Otherwise, we will process your personal data where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process your personal data in relation to a relationship that we have with the person that you work for will fall into this category).
- In circumstances in which we are acting as a data processor, the relevant educational establishment (data controller) will be responsible for ensuring the legal basis of the processing concerned.
HOW LONG WE KEEP YOUR PERSONAL DATA
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
You have the following rights in relation to personal data relating to you that we process and in relation to which we are the controller:
- You may request access to the personal data concerned.
- You may request that incorrect personal data that we are processing be rectified.
- In certain circumstances (normally where it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing your personal data for marketing purposes or otherwise based on our legitimate interests, you may in certain circumstances have a right to object to that processing.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent, after which we shall stop the processing concerned.
To exercise any of your rights (including withdrawing relevant consents or obtaining access to your personal data), you should contact us as set out below.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.
CONTACTING THE REGULATOR
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Our contact details are:
Talis Education Ltd
1 Oliver’s Yard
55 City Road
London EC1Y 1SP
Contact: Company Secretary
UPDATES TO THIS POLICY
DATE OF THIS POLICY
This policy was last updated on 16 April 2019