LSI Independent College, LSI Educa on, and HLI Data Protec on Policy
1. Purpose and Scope
The policy is designed to ensure LSI complies with the General Data Protec on Regula on. It
is a dynamic document which is to be regularly reviewed and updated. This is to be done
annually. LSI is required to process personal informa on regarding:• employees, volunteers, and applicants.
• host families, when applicable.
• students/clients.
• parents of students/clients aged under 18.
• Educa onal Tour Operators (ETOs), when applicable
In doing so, LSI shall at all mes comply with the Data Protec on Act 1998 and the General
Data and Protec on Regula on (GDPR) EU/2016/679. The GDPR is considered to be the gold
standard of Data Protec on Regula on and shall therefore be applied to all LSI schools andoﬃces. In addi on, any individual living in the EU using LSI services and having theirpersonal data processed by LSI, regardless of the loca on of those services and processing, isprotected by the GDPR. In all cases, when Na onal or State laws, including Visa andImmigra on regula ons diﬀer from the GDPR, the former shall take precedence.
2. Data Protec on Oﬃcer
LSI Deputy Managing Director Roy Immanuel has been appointed as LSI’s Data Protec onOﬃcer (DPO). It is his responsibility to ensure that this policy and a endant procedures areadhered to at all mes. At every LSI school, including LSI Independent College, the “datachampion” is the school director or principal, unless otherwise stated.
3. Deﬁni ons:
a. Personal Data
The deﬁni on of Personal Data is broad. Illustra ve examples include:• Names• Addresses• Passport and visa informa on• Telephone numbers• Medical informa on• Opinions about other people• Financial informa onb. Data Processing
The deﬁni on of data processing is broad. Illustra ve examples include:• Obtaining, recording, viewing, holding or carrying out any opera on on Personal Data. •Organising, altering, drawing reports form Personal Data.
• Searching, retrieving, and disclosing Personal Data

c. Data Subject
The data subject is the individual whose personal data is being processed by LSI
4. General Principles of Personal Data Processing
As far as is reasonably prac cable, LSI will comply with the General Data Principals by
ensuring that all personal data will be:a. Lawful, transparent and fair Data must only be processed for legal and fair purposes andthe processing must be necessary to achieve the purpose for which it has been collected.
Examples include:• Exam entries• Enrolment on courses• Having emergency contact informa on available to staﬀ
• Safer Recruitment
LSI must be transparent in detailing the full extent and processing purposes of Personal
Data. Details must be provided in an intelligible, accessible way and use clear and plain
language which can be understood by the Data Subject. This should be provided in a Privacy
Statement which must include:• The iden ty and contact details of LSI.
• The purpose and legal basis for the data processing• Who will receive the data and with whom it may be shared.
• The subject’s right to access, correct, erase, move or update erroneous data.
• The right to object to the processing of the data.
• Details of safeguards and control applied in transmi ng data, in par cular when moving toother countries.
b. Restricted to a speciﬁc purpose
LSI can only process data for the speciﬁc, legi mate purposes for which it was originallycollected. Should the processing purpose change from the original intent, LSI will seek theexplicit, ac ve consent from the Data Subject.
c. Relevant and Limited
Before processing can begin, it must be conﬁrmed that it is necessary in order to achieve thepurpose. This is to be checked on an ongoing basis and annually as a minimum as part of acomprehensive Data Processing review.
d. Accurate and up-to-date
LSI shall take all reasonable steps to ensure that incorrect details are corrected or erased andreplaced as soon as is prac cable, and within one month of no ﬁca on.
e. Kept for no longer than necessary
Personal Data which can iden fy individuals will only be kept as long as is necessary for thecomple on of the original purpose for which it was collected. This would not necessarily
coincide with the end of the course, as academic, a endance, proﬁciency records et cetera
may be required by either LSI or the Data Subject a er the end of the course.

f. Kept secure and conﬁden al.
All personal data will be protected against illegal and unauthorised processing, sharing oraccidental loss, damage and destruc on using technical and physical security measures asappropriate. It should not be passed on or shared with third par es without good reason
and within the parameters of the Privacy No ce as outlined in 4b.
5. Lawful processing
Collec ng and processing of data by LSI is only permi ed when it sa sﬁes one of the legal
condi ons as set out below:
a. To carry out a contract such as but not limited to:i. Course registra ons
ii. Exam entries, both internal and with third par esiii. UCAS applica ons
iv. Employment
v. Accommoda on provision.
b. Consent
i. For data to be processed the Data Subject must provide their express consent. This mustbe:
1. Freely and ac vely given
2. Speciﬁc, clear and an informed decision, based on informa on given in the Privacy
Statement. It must be dis nguishable from other terms and condi ons and consents.
ii. Consent may be withdrawn at any me when requested in wri ng.
iii. A record of when and how consent was given must be kept.
c. Legal obliga on
i. Personal data may be processed as part of a na onal or state statutory requirement,
including for visa and immigra on purposes.
d. Sensi ve datai. Where LSI has a duty or care or in order to comply with its equality policy, it may need toprocess Sensi ve Personal Data
6. The Rights of the Data Subject
a. Access to informa on
The subject has the right to request whether their personal informa on is being processedby LSI and if so, to request the details of that processing and a copy of all informa on in anaccessible and understandable format.
b. Correct informa on.

The subject has the right to have any erroneous data corrected or removed as soon as isprac cable and within one month. In order for a request to be processed, the data subject
must provide iden ﬁca on in line with the Safer Recruitment Policy.
c. Right to be forgo en
The subject has the right to request that all personal data rela ng to them is deleted where
it is no longer needed for the purposes for which it was originally needed. d. Right toprevent processing The subject can request that LSI stop processing personal data where thedata subjects’ interests override those of LSI. This does not apply when LSI has legi matereasons to process the data, such as Na onal and State regula ons, or for Visa andImmigra on purposes.
7. Under 18s
a. Consent
Where client/students are aged under 18, LSI shall only process data when express consent
has been given by the Parent/Guardian**This applies by default to LSI Independent College. For other LSI schools, 16-17 yr oldstudents may have their data processed without communica on from any other persons if
the student has booked independently – this is subject to local and na onal guidelines.
b. LSI shall process Personal Data of the Parent/Guardians of students/clients aged U18 inorder to carry out its Safeguarding du es as per the Safeguarding Policy.
8. Right of refusala. LSI may refuse to provide services to clients/students/ETOs where the refusal of dataprocessing consent may lead to LSI being unable to enforce its Safeguarding, A endance,
Behaviour and Disciplinary Policies or to provide the client/student with the product orservice they wish to book.
9. Transfer of data between LSI companies
LSI language schools, LSI Independent College, and HLI have the same ownership and sharedmarke ng/administra ve channels. Therefore, all data gathered by one school or division
may be shared freely within the group, subject to the terms outlined above.
10. Dura on of data storage
As stated in the LSI Privacy Policy (see link below) all data collected by LSI schools will bedeleted a er seven years. This includes all informa on stored on our databases in digital andprint format, as well as email logs. There may be ﬁnancial informa on that is required to be
kept for longer, in which case this data will be anonymised. Email correspondence of LSI
senior managers may also be archived for longer than seven years, as required.

11. Newsle ers and correspondence
We will endeavour to correspond only with people who s ll ac vely want to be contacted.
As well as oﬀering in every mail for students/partners to unsubscribe, we will regularly
sweep our correspondence lists for those addresses that serially decline to open our mail.

12. Other LSI data policies:
LSI Privacy Policy: h ps://www.lsi.edu/privacy
h ps://www.lsi.edu/documents/LSI_Student_Privacy_Statement.pdf
LSI Cookie Policy: h ps://www.lsi.edu/en/cookies.php

13. Jurisdic on
This policy is based on UK & EU GDPR laws. However, LSI schools will always abide by thelocal and federal laws of the countries in which they operate. In any regions where the local
data protec on laws contradict this policy document, LSI schools will defer to local
guidelines.
14. Updates
This policy has been updated by Roy Immanuel as of March 2024
To be reviewed in March 2025