SMS-HEG is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information. SMS-HEG complies with the six principles of the General Data Protection Regulation. Personal data is:
- Processed fairly, lawfully, and transparently.
- Only used for the specified, clearly explained purpose it was collected for.
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- Kept accurate and up-to-date.
- Only kept for as long as it is needed (usually until a project or activity is complete) and is then removed and securely deleted.
- Processed in a manner that ensures appropriate security of the personal data; it is stored in secure systems and only transferred by secure means.
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us by emailing email@example.com telephoning 0207 265 8478.
We will never sell your personal data, and will only ever share it with organizations we work with where necessary and if its privacy and security are guaranteed.
Any questions you have in relation to this policy or how we use your personal data should be sent to Mr Shamim for the attention of SMS-HEG’s.
2. THE INFORMATION WE COLLECT
Data for carrying out the administrative functions of SMS-HEG
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by the SMS-HEG
We collect the data you provide to us. This includes information you give when joining as a member or signing up to our newsletter, placing an order or communicating with us. For example:
- personal details (name, job title, organization, and email). This also includes address and telephone when you join as a member or supporter;
- details of SMS-HEG events you have attended.
Sensitive personal data for carrying out the administrative functions of SMS-HEG
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about members and those signed up to SMS-HEG’s. However, there are some situations where this will occur (e.g. if you have an accident on one of our events). If this does occur, we’ll take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff then we’ll keep a record of this (which may include personal data and sensitive personal data).
3. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter into, or perform, a contract with you;
- comply with a legal duty;
- protect your vital interests;
- for our own (or a third party’s) lawful interests, provided your rights don’t override these.
In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes)
We use personal data for administrative purposes (i.e. for admission purposes). This includes:
- maintaining databases of our members and those signed up to our newsletter;
- fulfilling orders services (whether placed online, over the phone or in-person)
- helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).
4. DISCLOSING AND SHARING DATA
Your personal data that has been collected for the purposes of SMS-HEG’s administrative functions – which include your name, organisation, and email address are held by our mailing list provider. This information is not shared with any other organisation. If you wish to unsubscribe from our mailing list at any time, you can do so by clicking the ‘unsubscribe’ link, found at the bottom of any email we send you – or by sending your name and email firstname.lastname@example.org stating Unsubscribe’ in the email in the subject line or body of the email. Data from third parties that we hold for admission purposes will never be disclosed or shared without the written agreement of the data controller.
We use personal data to communicate with people, to promote SMS-HEG products. This includes keeping you up to date with information from SMS-HEG on our events, news other information relating to our work. You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us emailing email@example.com telephoning 0207 265 8478
6. HOW WE PROTECT DATA
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorized access to, or use or disclosure of your personal information. Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). All staff receive data protection training and we have a set of detailed data protection procedures which personnel is required to follow when handling personal data set out in our policies. Copies of these policies are available on request.
Where we store information
SMS-HEG’s operations are based in England and we store our data within the European Union.
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed). We continually review what information we hold and delete what is no longer required.
8. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- The right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);
- The right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);
- The right to have inaccurate data rectified;
- The right to object to your data being used for marketing or profiling; and
- Where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. This is particularly the case where we receive surveys or administrative data from third parties for admission purposes as this will nearly always be in de-identified or anonymized formats. This means that no directly identifying information is shared with us. In these situations, the data collector will have provided you with a privacy notice that informs you how your data will be used but because we do not know who you are, we are not able to directly provide you with a privacy notice ourselves. In any situation, if you would like further information on your rights or wish to exercise them, please write to SMS-HEG’s email to firstname.lastname@example.org for the attention of Mr. Shamim.
You can complain to SMS-HEG directly by contacting us using the details set out above. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk
9. COOKIES AND LINKS TO OTHER SITES
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or the functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact’ link at the top of the page).
10. MODERN SLAVERY AND HUMAN TRAFFICKING POLICY
This policy and statement is made pursuant to section 54(1) of the Modern Slavery Act (2015) and constitutes SMS Higher Education Group’s formal slavery and human trafficking policy. This policy has been approved by the Director and senior management team of the organisation.
SMS Higher Education Group does not believe there is any place in today’s world for slavery and human trafficking and in making this statement commits to ensuring there is no modern slavery or human trafficking in our staff and student recruitment supply chains or in any part of our businesses.
We are committed to evolving our practices through all our group to combat slavery and human trafficking and to encourage the same principles and standards from our student recruitment and business partners.
No breaches of the Modern Slavery Act 2015 have ever been reported in 2021 or have been previously.
11. OUR COMPANY STRUCTURE
Operating primarily in the London, SMS Higher Education Group employs over 50 people across 2 main locations: London and Bangladesh.
12. OUR SUPPLY CHAIN
SMS Higher Education Group takes its responsibility for ensuring the risk of modern slavery and human trafficking is minimized across both its staff and student recruitment supply chain. It achieves this through a combination of due diligence, transparency and risk mitigation. The SMS Higher Education Group expects its staff to report concerns of non-compliance, no matter how trivial, in line with the established policies and procedures.
13. POLICIES ON MODERN SLAVERY
This policy is regularly updated to reflect best practice methodologies, and subsequently approved at Director level.
Our modern slavery policy reflects the Company’s commitment to acting with maximum integrity and ethical practice in all its relationships and has implemented adequate policies, procedures and systems to ensure that slavery and human trafficking is not taking place.
14. DUE DILIGENCE PROCESSES
In order to identify and mitigate the risks associated with modern slavery and human trafficking, SMS Higher Education Group has adopted the following processes:
- We conduct internal audits on our recruitment process to ensure that we only engage eligible workers for agency work.
- We expect the companies we work with to have anti-slavery and human trafficking policies and processes that cover the subsequent relationships with their suppliers as it is not practical for us to influence and have a direct relationship with all levels of the business relationship.
15. RISK ASSESSMENT
With many of the staff on a temporary, contract or permanent basis, we appreciate the importance of robust operational practices. Through the aforementioned due diligence processes, company audits, and internal policies and staff training, we act to minimise the risk of individuals being placed into any form of slavery.
Checks are also undertaken to verify and identify where workers may be sharing bank accounts, addresses and telephone numbers which may be a risk indicator.
SMS Higher Education Group will continue to assess the risks associated with modern slavery and human trafficking and aim to fully understand other indicators of modern slavery.
16. MEASURING EFFECTIVENESS
Through regular monitoring, audits and assessments we measure the effectiveness of our risk control measures to ensure that slavery and human trafficking is not taking place in our business, our subsidiary businesses or our staff and student recruitment supply chains.
Our key performance indicators (KPIs) in this instance are:
- 100% pass rate when reviewing recruitment activities and their compliance with agreed modern slavery processes.
17. TRAINING FOR SMS HIGHER EDUCATION GROUP STAFF
With such a clear focus on maintaining 100% compliance with modern slavery and human trafficking legislation, it is essential that the people within our business receive adequate training and information. We provide information on this legislation and our policies and processes via the SMS Higher Education Group’s induction process and training updates.
Employees, workers, business partners and customers are encouraged to report any concerns that may give rise to a risk of modern slavery or human trafficking.
Employees are advised on how to report any concerns they have associated with modern slavery and trafficking.