Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
Compass Culture and Education Ltd.  
Privacy Notice  
POLICY STATEMENT  
This privacy notice tells you what to expect us to do with your personal information.  
CONTACT DETAILS  
Post: Compass Culture & Education, 3 Union Street, BARNET, Hertfordshire, EN5 4HY, GB  
Telephone: 0208 449 0119  
WHAT INFORMATION WE COLLECT, USE AND WHY  
We collect or use the following information for student education and welfare:  
Names and contact details for students/children  
Names and contact details for carers  
Gender  
Date of birth  
Dietary requirements (including vegetarian, vegan, gluten free and halal requirements)  
Payment details and financial information including transactions  
Special Educational Needs and Disabilities (SEND) or additional support information  
(includes reasonable adjustments and special educational needs and disabilities)  
Welfare information (includes family and home life circumstances and history)  
Details of any criminal convictions  
Photographs  
Attendance and reason for absence data  
Account access information  
Exam results and qualifications  
Progress reports  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
Information relating to compliments and complaints  
Exclusion, suspension and behavioural information  
Racial or ethnic origin  
Religious or philosophical beliefs  
Health information  
We collect or use the following information for disciplinary investigations or to prevent, detect,  
investigate or prosecute crimes:  
Names and contact details for students/children  
Names and contact details for carers  
Gender  
Details of any criminal convictions  
Attendance and reason for absence data  
Witness statements and contact details  
Records and reports  
Video recordings of public areas (including entrances and outside spaces to which some  
or all members of the public have access)  
Audio recordings of public areas (including entrances and outside spaces to which some  
or all members of the public have access)  
Video recordings of student access areas (including classrooms, corridors, canteens and  
outside spaces to which students have access)  
Audio recordings of student access areas (including classrooms, corridors, canteens and  
outside spaces to which only staff have access)  
Call recordings  
We also collect or use the following information for disciplinary investigations or to prevent,  
detect, investigate or prosecute crimes:  
Racial or ethnic origin  
Religious or philosophical beliefs  
Health information  
We collect or use the following personal information for dealing with queries, complaints or  
claims:  
Names and contact details  
Address  
Purchase or service history  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
Video recordings of public areas  
Audio recordings of public areas  
Video recordings of private or staff only areas  
Audio recordings of private or staff only areas  
Call recordings  
Witness statements and contact details  
Relevant information from previous investigations  
Financial transaction information  
Information relating to health and safety (including incident investigation details and  
reports and accident book records)  
Correspondence  
We collect or use the following information for information updates or marketing purposes:  
Names and contact details  
Marketing preferences  
Photographs  
Records of consent, where appropriate  
We collect or use the following information to comply with legal requirements:  
Identification documents  
Health and safety information  
Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure  
Scotland checks)  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
LAWFUL BASES AND DATA PROTECTED RIGHTS  
Under UK data protection law, we must have a “lawful basis” for collecting and using your  
personal information. There is a list of possible lawful bases in the UK GDPR. You can find out  
more about lawful bases on the ICO’s website.  
Which lawful basis we rely on may affect your data protection rights which are in brief set out  
below. You can find out more about your data protection rights and the exemptions which may  
apply on the ICO’s website:  
Your right of access - You have the right to ask us for copies of your personal information. You  
can request other information such as details about where we get personal information from  
and who we share personal information with. There are some exemptions which means you  
may not receive all the information you ask for. You can read more about this right here.  
Your right to rectification - You have the right to ask us to correct or delete personal information  
you think is inaccurate or incomplete. You can read more about this right here.  
Your right to erasure - You have the right to ask us to delete your personal information. You can  
Your right to restriction of processing - You have the right to ask us to limit how we can use your  
Your right to object to processing - You have the right to object to the processing of your  
Your right to data portability - You have the right to ask that we transfer the personal  
information you gave us to another organisation, or to you. You can read more about this right  
Your right to withdraw consent – When we use consent as our lawful basis you have the right to  
withdraw your consent at any time. You can read more about this right here.  
If you make a request, we must respond to you without undue delay and in any event within  
one month.  
To make a data protection rights request, please contact us using the contact details at the top  
of this privacy notice.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
Our lawful bases for the collection and use of your data  
Our lawful bases for collecting or using personal information for student education and  
welfare are:  
Consent - we have permission from you after we gave you all the relevant information. All of  
your data protection rights may apply, except the right to object. To be clear, you do have  
the right to withdraw your consent at any time.  
Contract - we have to collect or use the information so we can enter into or carry out a  
contract with you. All of your data protection rights may apply except the right to object.  
Legal obligation - we have to collect or use your information so we can comply with the law.  
All of your data protection rights may apply, except the right to erasure, the right to object  
and the right to data portability.  
Vital interests - collecting or using the information is needed when someone’s physical or  
mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life  
sustaining food, water, clothing or shelter. All of your data protection rights may apply,  
except the right to object and the right to portability.  
Our lawful bases for collecting or using personal information for disciplinary investigations or to  
prevent, detect, investigate or prosecute crimes are:  
Consent - we have permission from you after we gave you all the relevant information. All of  
your data protection rights may apply, except the right to object. To be clear, you do have  
the right to withdraw your consent at any time.  
Contract - we have to collect or use the information so we can enter into or carry out a  
contract with you. All of your data protection rights may apply except the right to object.  
Legal obligation - we have to collect or use your information so we can comply with the law.  
All of your data protection rights may apply, except the right to erasure, the right to object  
and the right to data portability.  
Vital interests - collecting or using the information is needed when someone’s physical or  
mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life  
sustaining food, water, clothing or shelter. All of your data protection rights may apply,  
except the right to object and the right to portability.  
Our lawful bases for collecting or using personal information for dealing with queries, complaints or  
claims are:  
Consent - we have permission from you after we gave you all the relevant information. All of  
your data protection rights may apply, except the right to object. To be clear, you do have  
the right to withdraw your consent at any time.  
Contract - we have to collect or use the information so we can enter into or carry out a  
contract with you. All of your data protection rights may apply except the right to object.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
Legal obligation - we have to collect or use your information so we can comply with the law.  
All of your data protection rights may apply, except the right to erasure, the right to object  
and the right to data portability.  
Vital interests - collecting or using the information is needed when someone’s physical or  
mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life  
sustaining food, water, clothing or shelter. All of your data protection rights may apply,  
except the right to object and the right to portability.  
Our lawful bases for collecting or using personal information for information updates or marketing  
purposes are:  
Consent - we have permission from you after we gave you all the relevant information. All of  
your data protection rights may apply, except the right to object. To be clear, you do have  
the right to withdraw your consent at any time.  
Contract - we have to collect or use the information so we can enter into or carry out a  
contract with you. All of your data protection rights may apply except the right to object.  
Legal obligation - we have to collect or use your information so we can comply with the law.  
All of your data protection rights may apply, except the right to erasure, the right to object  
and the right to data portability.  
Vital interests - collecting or using the information is needed when someone’s physical or  
mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life  
sustaining food, water, clothing or shelter. All of your data protection rights may apply,  
except the right to object and the right to portability.  
Our lawful bases for collecting or using personal information to comply with legal requirements are:  
Consent - we have permission from you after we gave you all the relevant information. All of  
your data protection rights may apply, except the right to object. To be clear, you do have  
the right to withdraw your consent at any time.  
Contract - we have to collect or use the information so we can enter into or carry out a  
contract with you. All of your data protection rights may apply except the right to object.  
Legal obligation - we have to collect or use your information so we can comply with the law.  
All of your data protection rights may apply, except the right to erasure, the right to object  
and the right to data portability.  
Vital interests - collecting or using the information is needed when someone’s physical or  
mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life  
sustaining food, water, clothing or shelter. All of your data protection rights may apply,  
except the right to object and the right to portability.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
3 Union Street, Barnet EN5 4HY  
020 84490119  
WHERE WE GET PERSONAL INFORMATION FROM  
Directly from you  
Parents or carers  
HOW LONG WE KEEP INFORMATION  
Retain all client-related documents, including agreements, correspondence, invoices, financial  
transactions, and internal communications, for 2 years after the contract ends to meet legal, audit,  
and business requirements. After this period, securely dispose of all records, either by shredding paper  
documents or permanently deleting electronic files, in line with data protection and confidentiality  
policies.  
WHO WE SHARE INFORMATION WITH  
Data processors  
Jessie Chang: This data processor does the following activities for us: store our HR records, overall  
office admin  
Tina Liu: This data processor does the following activities for us: store our HR records, overall office  
management  
Others we share personal information with: Parents and carers, Local authorities, Emergency  
services, Professional advisors  
HOW TO COMPLAIN  
If you have any concerns about our use of your personal data, you can make a complaint to us using  
the contact details at the top of this privacy notice.  
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also  
complain to the ICO.  
The ICO’s address:  
Information Commissioner’s Office  
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF  
Helpline number: 0303 123 1113  
REVIEW  
We are committed to reviewing our policy and good practice annually.  
This policy was last reviewed on: 3 SEP 2024  
Signed: Tina Liu  
Registered in England No. 9024815