We take the security of the information you entrust to us extremely seriously and that includes information which is personal to you, and those around you.
WHO WE ARE
We are Sherpa Kids England Limited (company number 11705893) whose registered address is 12 New Fetter Lane, London, EC4A 1JP.
HOW TO CONTACT US
Our Data Protection Officer is:
Dawn Engelbrecht +64 27 291 9904 via email firstname.lastname@example.org
The kind of information we hold about you
We will collect, store and use the following categories of personal information about you:
We may also collect, store and use the following “special categories” of more sensitive personal information:
We are the data controller in respect of the information we collect from you.
How is your personal information collected
Information we collect directly from you
We collect personal information about you and your child through our enrolment process. We may sometimes collect additional information from third parties such as the school your child attends.
Information collected by our franchisees
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to provide our services to you as well as enabling us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
The personal data which we collect includes information which is considered to be special category data. We need to collect and process this information in order to ensure the safety of the children in our care. Our lawful basis for doing so is that such processing is necessary for complying with our legal obligations and providing our contractual services to you, and we need to use this information in order to provide treatment to a child who becomes unwell in our care, or alternatively with your explicit consent.
Who has access to your data
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. Some of your information may be shared with:
We will also transfer yours and your child’s data to New Zealand and Australia where the head offices of Sherpa Kids International are located (see section Transferring information outside the EU for more information).
What about other third parties?
We may need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
The personal information we collect about you and your child is available to our head offices in New Zealand and Australia, and we may transfer it to service providers who process data on our behalf in other locations outside of the EU – in all cases in order to provide our services to you. There is an adequacy decision by the European Commission in respect of New Zealand. This means that the European Commission deems New Zealand provides an adequate level of protection for your personal information. Australia and most other locations outside of the EU do not have adequacy decisions in their favour.
To ensure that the personal information we send to Australia and certain other locations does receive an adequate level of protection we have put in place standard contract clauses between us and the recipients that have been approved by the European Commission. If you require further information about this protective measure[s], you can request it from the Data Protection Officer.
How long we keep your data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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.
To comply with our obligations to the HMRC and Regulators we have to retain:
Once 7 years have passed, we will delete or anonymise your data in accordance with applicable laws and obligations.
Because the data we hold about you is your data, you have the right to:
If you would like to exercise any of the above rights, please contact us using the contact details above.
Your Duty to Inform us of Changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Right to Complain
If you have any concerns about our handling of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) by visiting https://ico.org.uk/concerns/or by telephoning the ICO helpline on 0303 123 1113.