Data Protection

Bell is committed to compliance with all national Swiss laws in respect of personal and sensitive data, and to protecting the rights and privacy of individuals. E-mail messages and any files transmitted with them are strictly confidential and intended solely for the use of the individual or entity to whom they are addressed. Bell is registered as a Data Controller with the Information Commissioner’s Office, to access further information about our Policy, please see below.

If you are not the named addressee of an e-mail you should not disseminate, distribute or copy it. Please notify the sender immediately by e-mail if you have received an e-mail by mistake and delete it from your system. Please note that any views or opinions presented in e-mails are solely those of the author and do not necessarily represent those of the organisation. Finally, the recipient should check this e-mail and any attachments for the presence of viruses. We accept no liability for any damage caused by any virus transmitted by this e-mail.

Bell Switzerland SA, known as ‘Bell’ is committed to processing your data fairly and lawfully. This privacy policy explains how we use any information we collect about you or your child when you engage with us.

Any reference to ‘your data’ includes any data collected on those attending our different courses. It also includes Bell employees and, other individuals Bell engages with.

What information do we collect about you?

We collect information about you when you book onto one of our courses or engage you in employment. Information is also collected when you submit an enquiry either through our website (bell-school.ch), directly by email, or if we meet you at an event. Website usage information is collected using cookies.

We will only collect information necessary to your relationship with Bell and will retain this data for no longer than is necessary for its intended purpose or until you request otherwise.

How will we use the information about you?

We collect information about you to process your booking, manage your account throughout this process and your time at Bell. With your permission, we will occasionally contact you following your time with Bell, with offers on our products and services we think may be of interest to you.

Information gathered from your usage of our website will be used for internal analytics to inform how we can improve the website for the benefit of the customer journey.

We will only share your information with third parties that are necessary during your time with Bell. Bell will never share your information for marketing purposes with companies outside Bell.

Marketing

We would like to occasionally send you information on our products and services which may be of interest to you. If you have consented to receive marketing, you can opt out at any time.

If you no longer wish to be contacted for marketing purposes you can do so through the unsubscribe link on our emails, or by emailing enquiries@bellenglish.com. Where you do opt-out of communications from us, we will retain your information to ensure we do not contact you in the future, while still maintaining a record of your academic achievements with Bell.

Access to your information and correction

You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please email info@bell-school.ch or write to us at Bell Switzerland, Chemin des Colombettes 12, 1202 – Geneva, and Bell will aim to respond within 40 days. We may make a small charge for this service

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Other websites

If our website contains links to other websites, we are not responsible for its content. This privacy policy only applies to our website only, so you should ensure you read their privacy policy.

Changes to our privacy policy

We will keep our privacy policy updated and under regular review and will place any updates on this webpage. This privacy policy was last updated 17 May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold on you, please contact us by email info@bell-school.ch or write to us at Bell Switzerland, Chemin des Colombettes 12, 1202 – Geneva.

We use technologies on the site www.bell-school.ch (the Site) to collect information that helps us improve your online experience. In this Cookie Policy, we refer to these technologies, which include cookies, pixels, web beacons and gifs, collectively as cookies. This policy explains the different types of cookies used on the Site and how you can control them. We may change this Cookie Policy at any time.

Please take a look at the last effective date at the top of this page to see when this Cookie Policy was last revised. Any changes in this Cookie Policy will become effective when we make the revised Cookie Policy available on or through the Site. Any personal information that we collect through the use of cookies is obtained through transparent notice to you and through your consent. Where applicable, we provide you with the opportunity to opt out. We hope that this Cookie Policy helps you understand, and feel more confident about, our use of cookies.

What is a cookie?

Cookies are small text files that are stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. They can do this because websites can read and write these files, enabling them to recognise you and remember important information that will make your use of a website more convenient (e.g. by remembering your user preferences).

What cookies do we use?

Below we list the different types of cookies we may use on the Site to enable certain functionality:

Performance Cookies
Performance cookies, which are sometimes called analytics cookies, collect information about your use of this Site and enable us to improve the way it works. For example, performance cookies show us which are the most frequently visited pages on the Site, allow us to see the overall patterns of usage on the Site, help us record any difficulties you have with the Site and show us whether our advertising is effective or not.

Functionality Cookies
In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make on our Site and to provide enhanced and more personalized features, such as customising a certain webpage, remembering if we have asked you to participate in a promotion and for other services you request, like watching a video or commenting on a blog. All of these features help us to improve your visit to the Site.

How do I control cookies?

You may refuse to accept cookies from this Site at any time by activating the setting on your browser which allows you to refuse cookies.

Please be aware that if cookies are disabled, not all features of the Site may operate as intended.

Article 17 of the General Data Protection Regulations (GDPR) “The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay….”

Someone may decide that, for whatever reason, they believe the Bell is processing data about them that they don’t want us to, or that they think we shouldn’t be. GDPR provides the right to ask the Bell to delete personal data in some circumstances.

This ‘right to be forgotten’ as it is also known, is not an absolute right, meaning that it might not be possible or required in all situations.

When does it apply?

The right to erasure does not provide an absolute right to have data erased. Under the GDPR, data subjects have the right to have their data erased in the following situations:

• the personal data is no longer necessary in relation to the purpose for which it was originally collected;
• the processing is based on consent and this consent is withdrawn (and there is no other legal ground for the processing);
• the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
• the personal data was unlawfully collected;
• the personal data has to be erased in order to comply with a legal obligation; and

Under the GDPR, the right to erasure exists if one or more of the limitative grounds above apply.

When doesn’t it apply?

The Bell can refuse to comply with a request for erasure where the personal data is processed for the following reasons:

• to exercise the right of freedom of expression and information;
• to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
• for public health purposes in the public interest;
• archiving purposes in the public interest, scientific research historical research or statistical purposes; or
  the exercise or defence of legal claims.
• Without any undue delay and certainly no longer than a month from the date of request.

Can timescales be extended?

Yes – if the request is complicated, we can extend for a further two months, but we will let you know if this is the case within the original timescale
Is there a fee?

In most cases, we can not charge a fee to comply with a request for erasure.

However, we can charge a “reasonable fee” for the administrative costs of complying with the request if it is “manifestly unfounded or excessive”. We will base the reasonable fee on the administrative costs of complying with the request.

If we decide to charge a fee we will contact you promptly and inform you. We do not need to comply with the request until we have received the fee.

Alternatively, we can refuse to comply with a “manifestly unfounded or excessive request”.

What if the Business doesn’t comply?

If the Bell fails to provide a response to your satisfaction, you should raise a complaint with the Bell Data Protection Officer info@bell-school,ch

If you remain dissatisfied, you may request the ICO to undertake the judicial review:

If the ICO does not agree with the Bell, this may result in us being instructed to make the rectification as originally requested, either in full or in part. We will do this within one month of the ICO notifying us.

If the ICO agrees with the Bell, the note will remain on your account but no further action will be taken and no changes will be made to the data.

How do I request for erasure of data?

You may submit a request for erasure to any member of staff in a number of different ways, including via telephone or in-person, but for it to be considered a valid request, it must be clear what data you are requesting

We would encourage you to submit a request in writing wherever possible as this will be as much for your own befit as ours, as it will:

• Provide a clear audit trail as to when you submitted your request.
• Ensure that both you and the Bell have a clear record of what you have requested.
• Requests should clearly state what data you are requesting to be erased along with why you believe it should be erased. If it is unclear what you are requesting, you will be asked to clarify.

Requests can also be submitted to the Bell Data Protection Officer: info@bell-school.ch

Proof of Identity

To make sure that someone doesn’t request us to erase your data illegally, we will ask for proof of your identity. Acceptable proof of identity shall be any of:

• A copy of Photographic ID such as passport, driving licence or Student ID
• Birth Certificate.
• Two utility bills or bank statements (with redacted transactions) containing a full address of less than 3 months old.

Please note that originals are not required, but can be scanned and sent in via email or they will be copied if presented in person.