Eduvocation Ltd (trading as MyNewTerm) (the 'Company', 'we', 'us' or 'our') has created this privacy policy in order to demonstrate our firm commitment to privacy.

Our privacy policy will inform you as to how we collect, store, use and share your personal data only as it might be needed for us to deliver to you our products, services and websites (our "Services") and tell you about your privacy rights and how the law protects you. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

The Company is the data controller for the purposes of the UK GDPR.

The Company does not approve or endorse the employers which hold an account with us. We are not responsible for the privacy practices of those establishments, and you are advised to check their privacy policies and their terms and conditions so you are satisfied they will use your personal data correctly.

We evaluate the relevant sites which we provide links to, but we do not give approval or endorsement of those websites and we are not responsible for their content or privacy practices. As such, links to other websites are not covered by this policy and individuals are advised to check the privacy policies of those other sites for their terms and conditions.

Our details

• We are: Eduvocation Ltd (trading as MyNewTerm)
• Registered in England and Wales with company number: 9678975
• Address: MyNewTerm, Suite 132, Enterprise House, Wrest Park, Silsoe, Bedfordshire, MK45 4HR
• Information Commissioner's Office (ICO) Registration Number: A8348058
• Our Data Protection Officer is: Wayne Cartmel
• and his contact details are: MyNewTerm, Suite 132, Enterprise House, Wrest Park, Silsoe, Bedfordshire, MK45 4HR or email hello@mynewterm.com.

Why we collect Personal Data

We collect and hold Personal Data (as such term is defined in the UK GDPR) relating to the employers for which we advertise vacancies, prospective employees, employees and others.

We may share Personal Data with the recruiting employers as part of our Services or as necessary under our legal duties or otherwise in accordance with our duties/obligations as a Company.

The Personal Data we are provided with is provided to us on a voluntary basis. Personal Data may also be collected by your direct interactions with us by post, phone, e-mail or online or by automated technologies like cookies, server logs, analytics providers, advertising networks, search information providers and other similar technologies.

When you connect with services offered by third-parties, such as by "Liking" us on Facebook or following us on Twitter, or when you link to certain of our Services, this may include your Personal Data being transferred, and you hereby permit such transfers. The data we receive is dependent upon your privacy settings with the third-party. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to any Service we offer.

Below are set out the reasons why we collect and process Personal Data, as well as the legal basis on which we carry out this processing:

• registering you as a new user of our Services: to enable us to perform our obligations to you under a contract.
• processing and delivering your order of any Service including managing payments, fees and charges and collecting amounts owed to us: to enable us to perform our obligations to you under a contract; necessary for our legitimate interests to collect a debt owed to us.
• managing our relationship with you: to enable us to perform our obligations to you under a contract; necessary for our legitimate interests to keep our records updated.
• assess the quality of our Services: to enable us to reflect on our own practices to help us improve and provide the highest quality service.
• to assist with the continuing development of recruitment and retention policies and practices: to enable us and recruiting schools to better our and their recruitment and retention policies and practices.
• to contact you: to enable us to contact you to send you news about our Services and offers that we think may be of interest to you. If you do not want to be kept informed in this way by email, please let us know. You can do this by following the options set out in the "Choice/opt-out" heading of Section 11 below.
• to develop our understanding of the workforce and how employees are deployed: to help us create a fully informed, comprehensive picture of the make-up of the workforce and how each employee is utilised as a member of the workforce.
• to administer our Services including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data: to enable us to perform our obligations to you under a contract; necessary for our legitimate interests in running our business and in offering the Services.
• using data analytics: necessary for our legitimate interests in running our business and in offering the Services.

Legal basis for processing

The lawful basis for us to collect/process this Personal Data is that the processing is necessary for the performance of a contract to which the Data Subject (as such term is defined in the UK GDPR) is party (whether this be the recruiting school or the prospective employee) and/or as part of the Services.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We also process Personal Data where processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject.

Generally, and other than as set out below, we do not process any special categories of Personal Data except with your consent or where necessary for reasons of substantial public interest in complying with legal obligations including under the Equality Act 2010 or where necessary to protect the vital interests of the Data Subject or of another natural person and where safeguards are in place to ensure that this Personal Data is kept secure. For the avoidance of doubt where special categories of Personal Data are collected it shall not be used for the purposes of automated decision making and/or profiling.

Special categories of data mean Personal Data revealing:

• racial or ethnic origin;
• political opinions; religious or philosophical beliefs or trade union membership;
• genetic or biometric data that uniquely identifies you;
• data concerning your health, sex life or sexual orientation; or

Please note that as part of our Services, we may collect and process the following special category of Personal Data:

• racial or ethnic origin; or
• religious beliefs.

Also please note that as part of our Services, we and the recruiting employer may also collect and process data relating to criminal convictions or offences or related security measures.

This Personal Data will only be collected and/or processed where specific consent has been given. Additional further Personal Data including special categories of Personal Data may be collected and/or processed where consent has been given. If consent is the only legal basis for processing and has been given, then this may be revoked in which case the Personal Data will no longer collected/processed.

Cookies

The www.mynewterm.com website uses cookies, which are small text files that are placed on your computer by websites 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. They cannot be used to get information from your computer about you or read any personal material kept by you on your computer.

The cookie is used to make the link between you and the information you have provided to the website. The creation of a cookie on your computer does not give the website any access to other information such as your email address. For more information on our use of cookies, please see our cookie policy https://www.mynewterm.com/cookie-policy

Categories of Information we collect and store

We may collect the following types of Personal Data (please note this list does not include every type of Personal Data and may be updated from time to time):

• name and contact details;
• date of birth;
• national insurance number;
• health and/or other medical information;
• information in connection with education (and the curriculum of the school);
• personal characteristics, such as:
  • nationality and ethnic group;
  • religion;
  • first-language;
  • any special educational needs;
  • any relevant protected characteristics.
• employees' employment history, qualifications and employment contractual information, such as:
  • qualifications information;
  • right to work information;
  • criminal conviction information including results from Disclosure and Barring Service (DBS);
  • name of past and current employers and periods of employment and unemployment;
  • past and current employee position and/or role;
  • past and current employment start dates;
  • past and current salary / remuneration details (including national insurance and other financial details);
  • references from previous employers;
  • any relevant protected characteristics.

Who will have access to your Personal Data

Certain of your Personal Data will be shared with potential employers as part of our Services.

Personal Data will be accessible by our directors and other members of staff as necessary for us to provide the Services.

We will not share information with third parties without consent unless we are required to do so by law or our policies. We will disclose Personal Data to third parties:

• if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation;
• in order to enforce any agreements with you;
• in order to perform contracts with third party suppliers for purposes listed in Section 2. To protect the rights, property, or safety of the Company, the recruiting employers, their pupils or others. This includes exchanging information with other organisations for the purposes of child welfare.

This may include our Local Authority, the DfE, the Police and other organisations where necessary.

Certain data collection obligations are placed on us by the DfE. To find out more about the data collection requirements placed on us by the DfE (for example; via the school census) visit: www.gov.uk/education/data-collection-and-censuses-for-schools.

We may disclose your Personal Data to our external service providers acting as processors who provide IT and system administration services and also to our professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers, as the case may be, who provide consultancy, banking, legal, insurance and accounting services, as the case may be.

We may also disclose your Personal Data to HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with all relevant laws. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may also disclose your Personal Data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets but only provided that the new owners use your Personal Data in substantially the same way as set out in this Privacy Policy.

How Personal Data will be processed

Personal Data may be processed in a variety of ways; this will include but is not limited to:

• maintaining written records for employment purposes;
• identification;
• marketing purposes;
• sharing information with recruiting employers (please note that we are not responsible for the privacy practices of other organisations);
• sending by e-mail (whether this be contacting individuals and recruiting employers or responding to enquiries);
• to improve our Services;
• adding to spreadsheets, word documents or similar for the purposes of assessing Personal Data;
• for educational software use.

Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.

Where we store Personal Data and how we keep it secure

Electronic copies of Personal Data are kept securely, and information will only be processed where we are satisfied that it is reasonably secure.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share your password with anyone.

When giving Personal Data to third parties (for example, software providers) it is possible that this Personal Data could be stored in a location outside of the UK. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy. In particular, any transfer of your Personal Data made by us to a location outside of the UK will be governed by clauses in a written contract in order to keep these secure or will be subject to EU GDPR for transfers within the European Economic Area (EEA).

More particularly, this site has security measures in place to protect the loss, misuse and alteration of the information under our control. All instances of unauthorised attempted access to our site are logged and investigated. Where necessary, we will inform law enforcement agencies or other relevant organisations regarding misconduct. We store your email addresses securely. Your details will not be passed to any organisation beyond the Company other than the employer(s) which you submit a job application in respect of, without your explicit permission.

Retention periods

We will only retain Personal Data for as long as is necessary to achieve the purposes for which they were originally collected. As a general rule, Personal Data will be kept in accordance with guidance from the Information & Records Management Society Ltd (IRMS). Further information on retention periods can be obtained by contacting us via the details in Section 1 of this Notice.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our customers for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your Personal Data (see "Your Data Rights" below).

Once the retention period concludes your Personal Data is securely and safely destroyed/deleted.

Your Personal Data Rights

The UK GDPR and associated law gives you rights in relation to Personal Data. These are:

• Right to be informed: you have the right to be informed about the collection and use of your Personal Data. This policy contains information in relation to the collection of your Personal Data, however, if we collect additional data for other purposes, we will inform you about this.
• Right of Access: if your Personal Data is held, you are entitled to access your Personal Data (unless an exception applies) by submitting a written request. We will aim to respond to that request within one month. If responding to your request will take longer than a month, or we consider that an exception applies, then we will let you know.
• Right of Rectification: you have the right to require us to rectify any inaccurate Personal Data we hold about you. You also have the right to have incomplete Personal Data we hold about you completed. If you have any concerns about the accuracy of Personal Data that we hold then please contact us.
• Right to Restriction: you have the right to restrict the manner in which we can process Personal Data where:
  • the accuracy of the Personal Data is being contested by you;
  • the processing of your Personal Data is unlawful, but you do not want the relevant Personal Data to be erased; or
  • we no longer need to process your Personal Data for the agreed purposes, but you want to preserve your Personal Data for the establishment, exercise or defence of legal claims.
  • employment start date;
  • any relevant protected characteristics.
  • remuneration details (including national insurance and other financial details).

Where any exercise by you of your right to restriction determines that our processing of particular Personal Data are to be restricted, we will then only process the relevant Personal Data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

• Right to Erasure: you have the right to require we erase your Personal Data which we are processing where one of the following grounds applies:
  • the processing is no longer necessary in relation to the purposes for which your Personal Data were collected or otherwise processed;
  • our processing of your Personal Data is based on your consent, you have subsequently withdrawn that consent and there is no other legal ground we can use to process your Personal Data;
  • the Personal Data have been unlawfully processed; and
  • the erasure is required for compliance with a law to which we are subject.
• Right to Data Portability: you have the right to receive your Personal Data in a format that can be transferred. We will normally supply Personal Data in the form of e-mails or other mainstream software files. If you want to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, please contact us via the details in Section 1 of this Notice.
• Right to object: you have the right to object to the processing of your Personal Data where one of the following grounds apply:
  • the processing is based on legitimate interests or the performance of a task in the public interest;
  • the processing is for direct marketing; or
  • the processing is for the purposes of scientific/ historical research and statistics.

You can find out more about the way these rights work from the website of the Information Commissioner's Office (ICO).

Questions or concerns

If you have any questions or concerns relating to this policy and data protection, please contact us using any of the methods listed below.

Choice/opt-out
If you no longer wish to receive communications from us, you can:

• Send an email to hello@mynewterm.com identifying yourself and asking that we remove you from our contact lists.
• Write to us at: MyNewTerm, Suite 132, Enterprise House, Wrest Park, Silsoe, Bedfordshire, MK45 4HR

To change or modify information previously provided, you can:

• Send an email to hello@mynewterm.com clearly identifying yourself and asking that we correct or update your Personal Data.
• Write to us at: MyNewTerm, Suite 132, Enterprise House, Wrest Park, Silsoe, Bedfordshire, MK45 4HR

Requesting Your Personal Data

Where the Company holds Personal Data concerning you, you are entitled to access that Personal Data and the following information (unless an exception applies):

• a copy of the Personal Data we hold concerning you, provided by the Company;
• details of why we hold that Personal Data;
• details of the categories of that Personal Data;
• details of the envisaged period for which that Personal Data will be stored, if possible;
• information as to the source of Personal Data where that Personal Data was not collected from you personally.

Further information or making a complaint

If you are unhappy with the way we have dealt with any of your concerns, you can make a complaint to the ICO, the supervisory authority for data protection issues in England and Wales. We would recommend that you complain to us in the first instance, but if you wish to contact the ICO on the details you can do so on the details below. The ICO is a wholly independent regulator established in order to enforce data protection law.

ICO Concerns website: www.ico.org.uk/concerns

ICO Helpline: 0303 123 1113

ICO Email: casework@ico.org.uk

ICO Postal Address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Changes to this Privacy Policy

Any changes we make to our privacy policy in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes.

This privacy policy was last updated in July 2021.

By using this website, you are accepting the terms and conditions of use contained within this policy and our General Terms of Website Use. If any our terms and conditions and policies are not acceptable to you, please do not use this website.

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