FAQs

20 lesson programmes (15 hours)

Mornings: 9:00-10:30 – 10:45-12:15

or

Afternoons: 13:00-15:00 – 15:15-17:00

CANCELLATION OF BOOKING and REFUNDS – : Cancellation charge €160 applies in all cases plus the school shall retain a portion of the course fees as follows: notice of receipt of cancellation 21 days before the start of a course, 10%: 14 days before, 20%: 7 days before and up to 7 days after course commencement, 30% No refunds will be made for partial weeks of attendance or an uncompleted course following 7 days after the course begins.

Refunds will be made within a maximum of 2 months following the cancellation date and processed by Patrick Creed [email protected].

If a visa application is refused, the funds will be returned within 20 working days of the decision being received by the provider, less cancellation charge of €160.

Students should be punctual and attend class each day. A student will be recorded as absent is they are more than 5 minutes late to class or depart 5 minutes early. Students more than 15 minutes late will not be allowed to class and will have to return after the following class break. (VISA requiring students must keep an attendance rate of at least 85% for their programme and must not be more than 5 minutes late to each class)

Recording of attendance will be by the teacher in class and checked at the end of each week by the Director of Studies.

In the case of a student being absent for 2 days the school (Director of Studies) will try to make contact with the student by phone or email to seek clarification on the situation. If unsuccessful a letter/email will be sent to the student within 10 days of absence. If the school is unable to make contact with the student or receive good cause for absence then the student will be expelled from the school (by the school Director) within 4 weeks of the initial absence and reported to the local immigration office. This final decision on expulsion for any reason is made by the Director of the School. The school follows the decisions of INIS regarding visa requests and any decision on the renewal of visas or the cancellation of visas will be at the discretion of INIS and the school will respect any decisions INIS make.

All standard correspondence as part of this process will be retained and available on request to relevant internal personnel and external authorities. Absenteeism and expulsion procedures are implemented in a timely manner – the disciplinary action follows immediately after the absenteeism issue has been identified by management. (Non-EEA students will not be expelled towards the end of their programmes in relation to issues identified at an earlier point in the programme)

Students must email ([email protected]) or text (00353861678503) to the school on the first day of sickness and each day subsequently. Students must submit a certificate from a doctor on the first day of return to school. The procedure regarding absenteeism and expulsion is referenced in the requirements as activated in the case of uncertified sick leave beyond the statutory entitlement.

No unscheduled breaks are permitted except in documented cases of illness or close family bereavement. Any queries should be forwarded to Patrick Creed ([email protected]). Student holidays and breaks must comply with the Department of Justice and Equality’s requirements.

External authentication of exam results / grades received by students;

Examinations provided by the school are as follows:

Approved from June 2017 onwards;

EGPET   –  General English/PET  –  Cambridge English Language Assessment

EGTRINITYF – General English/ Trinity Integrated Skills In English Foundation – Trinity College London

EGTRINITYI  – General English/ Trinity Integrated Skills In English 1  – Trinity College London

Visa requiring students are obliged to sign an agreement at the beginning of the programme stating that Bridge Mills Galway Language Centre will enter the student for the appropriate end of programme exams and that the exams are mandatory. The student must sign the agreement stating that they understand the exam is mandatory and agree that they will sit the exam. This document is available for inspection in respect of each student.

Procedure for entering students for the required exams

• The school is a TIE and ETAPP examinations centre and can register students onsite.
• The school is a Cambridge examinations centre (PET/FCE/CAE/CPE) and can register students onsite.
• The school can register students for IELTS examinations – The school will register studenst for IELTS General module (Students must specifically request if they wish to take the Academic module in advance of the start of their course) 
  
• The school can also register students for Trinity examinations.
• The school can register students for TOEIC and TOEFL examinations ( but these do not fulfill Visa requirements for end of course examination programmes )

The person responsible for this is Patrick Creed [email protected]

A record of grades received will be available on request to students, INIS and relevant internal personnel and the relevant data protection permissions are agreed with students accordingly.

Please report complaints or appeals requests to us as soon as possible so we can assist you.

Complaints Procedure:

Informal Complaints 

Note:

Informal complaints should normally be made within 3 working days of the incident, matter or concern being complained about.

Steps:

1. Initial communication is made orally or in writing by the complainant (the person making the complaint) to the person who is the subject of the complaint (the person who is being complained about OR is responsible for the matter being complained about).
2. The subject of the complaint has three working days to acknowledge the complaint and attempt to mediate a satisfactory resolution. Other persons at the nearest level to the issue of concern (for example, team leaders or teachers) may be called upon to assist in this mediation if necessary.
3. If mediation is successful, the complaint is considered resolved.
4. If mediation is unsuccessful, or the complaint is unaddressed, the complainant may choose to (i) escalate to a formal complaint OR (ii) cease the complaint.

Formal Complaints

Note:

Complaints should normally be submitted within 5 working days of the incident, matter or concern being complained about. If the submission of a complaint is delayed, a rationale for this must be provided (for example, due to an informal complaints procedure being followed but unsatisfactorily resolved). If a complaint is made after a period of 4 weeks or more and no informal complaints procedure was followed in the interim, the complaint will not be accepted.

Steps:

1. A formal complaint is made in writing by the complainant to the Academic Coordinator. Complaints should be specific and where possible supported by appropriate evidence.
2. The Academic Coordinator investigates OR (where appropriate) appoints a competent staff member to investigate the complaint.
3. The Academic Coordinator advises the subject of the complaint of the details and nature of the complaint, and invites them to respond.
4. The Academic Coordinator, where appropriate assisted by a competent staff member, considers the complaint, associated evidence and response from the subject of complaint.
5. Where the complaint is not considered valid, the process concludes.
6. Where the complaint leads to recommendations or actions taken as a consequence of the complaint, the Academic Coordinator informs all relevant persons/bodies within the school.
7. The Academic Coordinator informs all parties in writing (complainant, subject of complaint and any other relevant persons) of the outcome of the investigation of the complaint, the findings, any decisions made or actions arising from those decisions.
8. The Academic Coordinator logs the details of the complaint for review by the appropriate body (Academic Committee, Operations Team, Board of Directors or any combination of these).

Appeals:

Procedure

Note:

Appeals should be initiated within 5 working days of the issue of the decision being appealed, subject to extenuating circumstances (for example, serious illness).

Steps:

1. The appellant (person making the appeal) submits the appeal to the Academic Coordinator using the appropriate appeal form (contact us at the office or email us for the form). The appeal submission should include:

• A completed application for appeal form
• Verifiable evidence which addresses the appeal criteria
  
  2. If the appellant seeks to present in person to the Appeals Board this must be indicated on the application for appeal form , alongside a rationale for presenting in person. The External Chairperson of the Appeals Board will decide if there is merit in the appellant attending in person.
  3. The Academic Coordinator assesses the application for appeal to establish if it is complete and meets the grounds for an appeal as per the BMGLC Policy for Appeals.
  4. If the Academic Coordinator deems that there are no valid grounds for appeal, the appeal is rejected and the appellant notified.
  5. If the Academic Coordinator deems that the grounds for appeal are valid and the application is complete, an Appeals Board is convened and the appellant notified.
  6. Where an Appeals Board is convened, the External Chairperson of the Appeals Board draws two persons from a panel established by the Academic Committee for this purpose. These two persons are asked to confirm they have no previous involvement with the matter being appealed, and to declare any conflicts of interest.
  7. The appellant is notified a minimum of three working days in advance of the meeting of the Appeals Board, and is provided with a copy of all material provided to the Appeals Board by the External Chairperson. This communication also responds to any requests by the appellant to present in person to the Appeals Board.
  8. The Appeals Board meets to review evidence, agree findings and determine fair resolution. The Appeals Board may, at its discretion, invite persons who may have evidence or information relevant to the matter being appealed to attend. The appellant is advised of any person the Appeals Board meets by the External Chairperson.
  9. If the Appeals Board upholds the appeal, consideration is given to the implications of this. The Appeals Board may adjourn to consult with the Board of Directors or take legal advice as required. Following a final decision (and any associated recommendations), the External Chairperson will communicate the decision and the rationale for its decision.
  10. If an appeal pertains to assessment or academic matters, the External Chairperson will communicate the decision to the Academic Committee (without providing personal information), the Academic Coordinator and the appellant.
  11. If an appeal pertains to non-academic matters, the External Chairperson will communicate the decision to the Academic Coordinator, the Managing Director and the appellant.
  12. Following notification of the decision, the process concludes. No further appeals process is available.

Procedures for Re-check, Review and Appeal or Complaint of Assessment:

Re-check: This refers to “the administrative operation of checking (again) the recording and combination of component scores for a module and/or stage” (QQI Assessment and Standards, Revised 2013, 4.10.3).

Review: This refers to “the re-consideration of the assessment decision, either by the original assessor or by other competent persons” (QQI Assessment and Standards, Revised 2013, 4.10.3).

Appeal: This refers to “a request to a higher authority for the alteration of the decision or judgement of a lower one” (QQI Assessment and Standards, Revised 2013, 4.10).

Complaint: This refers, in the context of assessment, to “an expression of concern that a particular assessment procedure is unfair or inconsistent or not fit-for-purpose” (QQI Assessment and Standards, Revised 2013, 4.10).

Recheck Procedure As required by Assessment and Standards, Revised 2013, assessment re-checks are managed directly by the responsible academic unit (the Programme team, supported by the Quality Officer).

Grounds for a Re-check :

The learner believes an error has been made in calculating their result

Steps: 1. The learner requests a re-check by emailing the school’s Academic Coordinator ([email protected]). The learner should include any relevant information pertaining to the requested re-check in the email.

2. Requests for re-checks should be submitted by learners within 10 days of being notified of results. BMGLC is not obliged to undertake re-checks requested more than 10 days after results notification.

3. The learner pays the re-check fee of €15 in the school office and is issued with a receipt. In the event of a successful re-check, this fee will be fully refunded.

4. The Quality Assurance Officer is notified of the request, and either undertakes the re-check or arranges for a suitably qualified person to do so. N.B. Re-checks are administrative checks of marks given and totalled, and do not require the exercise of academic judgement. However, persons undertaking a re-check must be able to use the marking scheme/rubric which informs them of how marks have been allocated.

5. The Quality Assurance Officer informs the learner in writing of the outcome of the re-check.

6. BMGLC endeavours to undertake and complete re-checks within 14 days of a request for recheck being received.

7. If a re-check results in a mark being raised or lowered, the Quality Assurance Officer will notify the Programme Leader and Academic Coordinator for the purpose of results amendment.

Review Procedure As required by Assessment and Standards, Revised 2013, assessment reviews are overseen by BMGLC’s Academic Committee. The Academic Committee delegates functional responsibility for handling reviews to the Quality Officer. The Quality Officer reports on all matters associated with reviews to the Academic Committee.

Grounds for a Review QQI’s Assessment and Standards, Revised 2013 states that “Learners are required to state the grounds for the requested review. The grounds for review will normally be that the learner suspects that the assessment was erroneous in some respect”.

The learner identifies that the academic procedures of BMGLC were not correctly implemented or followed, or that the assessment was erroneous in some respect.

The learner identifies that compassionate circumstances exist which have not been considered by BMGLC or may not have been known by BMGLC. Evidence of these compassionate circumstances, clearly dated on or prior to the date of the assessment under consideration should be provided (for example, a medical certificate). Where evidence cannot be provided, BMGLC may consider the review, but is under no obligation to do so.

Steps:

1. The learner requests a review by emailing the school’s Academic Coordinator ([email protected]). The learner should include any relevant information pertaining to the requested review in that email, and attach any appropriate evidence (for example, a medical certificate).

2. Requests for reviews should be submitted by learners within 10 days of being notified of results. BMGLC is not obliged to undertake reviews requested more than 10 days after results notification.

3. The learner pays the review fee of €30 in the school office and is issued with a receipt. In the event of a successful review, this fee will be fully refunded.

4. The Quality Assurance Officer is notified of the request, and decides whether a review will be granted based on the grounds for review. The Quality Assurance Officer may consult with the Programme Leader and/or the Academic Coordinator, and may exercise judgement in relation to compassionate circumstances for which evidence cannot be provided.

5. If the review is granted, the Quality Assurance Officer allocates a qualified assessor who did not undertake the initial assessment to undertake the review.

6. BMGLC endeavours to undertake and complete reviews within 21 days of a request for review being received and granted.

7. The decision of the new assessor will supersede the decision of the original assessor.

8. If the learner is unhappy with the outcome of the review, and grounds for appeal exist, they may appeal the decision using the appeals process.

9. If a review results in a mark being raised or lowered, , the Quality Assurance Officer will notify the Programme Leader and Academic Coordinator for the purpose of results amendment.

10. The Quality Assurance Officer informs the learner in writing of the outcome of the re-check.

11. The Quality Assurance Officer reports the outcome of all reviews to the Academic Committee.

Appeal Procedure

Grounds for an Appeal BMGLC recognizes the right of learners to appeal assessment decisions made by the school where grounds exist. As required by QQI’s Assessment and Standards, Revised 2013, BMGLC has transparent procedures in place for appeals.

Grounds for an appeal are as follows:

1. Evidence that BMGLC did not follow an established procedure in the making of a decision.

2. Circumstances or information of which the original decision-making body was not aware when its decision was taken, and a valid, substantiated reason why that information was not made available by the appellant (the person making the appeal).

3. Evidence of substantive bias by one or more of the decision-makers in arriving at a decision.

The following exclusions do not constitute grounds for an appeal:

1. Disagreement with a decision.

2. Disappointment with the result of an assessment or an opinion that a higher mark should have been obtained.

3. Complaints about persons or procedures, which must be addressed in the first instance under the school’s complaints policy and procedure.

4. Reopening of a matter that has already been decided on in a previous appeals process.

Learners wishing to make an assessment appeal are referred to the BMGLC’s Policy and Procedure for Appeals.

Complaints Procedure As required by QQI’s Assessment and Standards, Revised 2013, BMGLC has processes in place for dealing promptly with complaints made by learners concerning assessment. As per QQI’s guidelines, this process is integrated with BMGLC’s broader complaints policy and procedures.

Learners wishing to make an assessment complaint are referred to the BMGLC’s Policy and Procedure for Complaints.

Eaquals – Complaints Procedures (Staff and Students):

As members of Eaquals you can avail of the Eaquals complaint procedures if you cannot resolve your complaint through the school channels

Eaquals also has an Ombudsman whose role is to be the final and independent arbitrator in the event of a complaint against an Eaquals member that has not been resolved during the Eaquals complaint procedure. Please contact us or Eaquals for more on this.

Eaquals Ombudsman

Appeal of Examination Results (from external bodies)

Grounds for Appeal – An appeal of an external examination result, or academic submission, to an external body shall be considered where it meets the grounds for appeal

These vary depending on the examination /assessment body

• ACELS
• Cambridge Examinations
• TIE Examinations

Please email [email protected]

Appeals carry a cost and students will be informed of this at the time.

Appeals Procedures (external examinations bodies)

• A student who wishes to appeal an external examination result must do so in writing, setting out the grounds for the appeal (as per specific examination appeals process) in full to the Academic Manager.
• Appeal application deadlines are strictly applied as per the Examination board.
• There shall be a fee for an examination appeal
• The school will accommodate the administration of the appeals process once payment is complete

The maximum duration from receipt of a complaint to initial response is 5 working days.

Academic Committee Meetings:

The school has an Academic Committee who meet and guide the school in its decision making. The meetings are chaired by an external chair.

PRIVACY:

Information and Data Management

1.1 Data Protection Policy – Organisation

Everyone has rights with regards to how their personal information is handled. During Bridge Mills Galway Language Centre
activities we may collect, store and process personal information about staff, students, guardians, host families, educational partners, clients and service providers, and recognise the need to treat this data in an appropriate and lawful manner. Bridge Mills Galway Language Centre is committed to complying with its obligations in respect to all personal data it handles.

The school will identify key data that will be used as key performance indicators e.g. minimum and maximum learner numbers per programme, learner progression/learner attrition or drop-out rates, completion rates ,graduation / certification rates including grade analysis and career paths of graduates where appropriate. This data will be analysed appropriately and reviewed by the Academic Committee and reported to the Board as performance indicators.

The types of personal data that Bridge Mills Galway Language Centre may be required to handle includes details of current, past and prospective employees, students, guardians, educational partners, host families, suppliers, customers and others that Bridge Mills Galway Language Centre communicates with. The information, which may be held on paper or on a computer or other media is subject to certain legal safeguards specified in the General Data Protection Regulation (GDPR) (EU) 2016/679 and other regulations. The GDPR impose restrictions on how Bridge Mills Galway Language Centre may collect and process data.

In accordance with GDPR, Patrick Creed is the designated ‘Data Protection Lead’ (DPL) within Bridge Mills Galway Language Centre and is responsible for all aspects of the Data Protection Policy and implementation of same.

This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action up to and including dismissal.

Purpose and Scope 

This policy sets out Bridge Mills Galway Language Centre’s rules on data protection and the legal conditions that must be satisfied in relation to the collection, obtaining, handling, processing, storage, transportation and destruction of personal and sensitive information.

If an individual considers that the policy has not been followed in respect of personal data about themselves or others, they should raise the matter with the DPL.

Definition of Data Protection Terms

Data – Information which is stored electronically, on a computer, or in certain paper-based filing systems.  This includes IT systems and CCTV systems.

Data Subjects – For the purposes of this document includes all living individuals about whom BridgeMills Galway Language Centre holds personal data.

Personal Data –
Data relating to a living individual who can be identified from the data (or from that data and other information that is in, or likely to come into the possession of the data controller). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).

Data controllers
– The individuals or organisations who control and are responsible for keeping and use of data.

Data users –
Employees whose work involves using personal data. Data users have a duty to protect the information they handle by following Bridge Mills Galway Language Centre’s data protection security policies at all times.

Processing –
Performing any operation or set of operations on data including: –

Obtaining, recording or keeping data

Collecting, organising, storing, altering or adapting the data

Retrieving, consulting or using the data

Disclosing the information or data by transmitting, disseminating or otherwise making it available

Aligning, combining, blacking, erasing or destroying the data

Sensitive personal data – Information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition or sexual life, criminal convictions or the alleged commission of an offence. Sensitive personal data can only be processed under strict conditions and will usually require the express consent of the person concerned.

Data Protection
Principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be: –

Obtained and processed fairly

GDPR’s are intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the DPL is, in this case Patrick Creed, the purpose for which the data is to be processed by Bridge Mills Galway Language Centre and the identities of anyone to whom the data may be disclosed or transferred.

For personal data to be processed lawfully, certain conditions must have been met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.

Kept only for one or more specified, explicit and lawful purposes

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for other purposes specifically permitted by GDPR. This means that personal data must not be collected for one purpose and used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs. Any employee personal data collected by Bridge Mills Galway Language Centre is used for ordinary Human Resources purposes. Where there is a need to collect employee data for another purpose, Bridge Mills Galway Language Centre will notify the employee of this and where it is appropriate will get employee consent to such processing.

Used and disclosed only in ways compatible with these purposes

Personal data should only be collected to the extent that it is required for the specific purposes notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.

Kept safe and secure

Bridge Mills Galway Language Centre and its employees must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

GDPR require Bridge Mills Galway Language Centre to put in place procedures and technologies to maintain the security of all personal data. Personal data may only be transferred to a third-party data processor if the third party has agreed to comply with those procedures and policies or has adequate security measures in place.

The following must be maintained: –

Confidentiality – Only people authorised to use the data can access it. Bridge Mills Galway Language Centre will ensure that only authorised persons have access to an employees’ personal file and any other personal or sensitive data held by Bridge Mills Galway Language Centre .Employees are required to maintain the confidentiality of any data to which they have access.

Integrity – Personal data is accurate and suitable for the purpose for which it is processed.

Availability – Only authorised users should be able to access the data if they need it for authorised purposes

Security Policy / Procedures include: –

Secure lockable desks and cupboards.  – Clear desk policy, all desks and cupboards remain locked when not in use. (Personal information is always considered confidential) and treated with extra precautions ensuring no one can see work that contains the same.

Methods of disposal. – Paper documents must be shredded. All removable media should be wiped and physically destroyed when no longer required.

Equipment – Data users should ensure that individual monitors do not show confidential information to passers-by and that the screen saver starts as soon as their PC is unattended.

ISO 27001 – Compliance is required to all Policies with regards to ISO27001, including the IT Security Policy documents.

Kept accurate, complete and up to date

Personal data must be accurate and kept up to date. Information which is incorrect, or misleading is not accurate, and steps should be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed. Employees should ensure that they notify the DPL and Human Resources of any relevant changes to their personal information so that it can be updated and maintained accurately. Examples of relevant changes to data would include a change of address.

Adequate, relevant and not excessive

Retained for no longer than is necessary for the purpose or purposes for which it was collected

Personal data should not be kept longer than is necessary for the purpose. For guidance in relation to data retention to data retention employees should contact their manager. Bridge Mills Galway Language Centre has various legal obligations to keep certain employee data for a specified period. In addition, Bridge Mills Galway Language Centre may need to retain
personal data for a period to protect its legitimate interests.

Provided to data subjects as requested

Data must be processed in line with data subject’s rights.
Data subjects have a right to: –

Request access to any data held about them by the Data Controller

Prevent the processing of their data for direct marketing purposes

Ask to have inaccurate data amended

Prevent processing that is likely to cause or distress to themselves or anyone else

Dealing with Subject
Access Requests

A formal request from a data subject for information that Bridge Mills Galway Language Centre holds about them must be made in writing. Any employee who receives a written request in respect of data held by Bridge Mills Galway Language Centre should forward it to the Data Controller.

Providing Information
Over the telephone

Any employee dealing with telephone enquiries should be careful disclosing any personal information held by Bridge Mills Galway Language Centre over the phone. The employee should: –

Check the identity of the caller to ensure that information is only given to a person who is entitled to that information

Suggest that the caller put their request in writing if the employee is not sure about the identity of the caller and in circumstances where the identity of the caller cannot be verified

Refer the request to their manager and/or the Data Controller for assistance in difficult situations. No employee should feel
forced into disclosing personal information.

Direct Marketing

At Bridge Mills Galway Language Centre, it is our policy not to contact any potential individuals without their permission. To comply with this policy, our pre-sales employees are requested to ensure the following: –

Do not call or email another organisation until it is confirmed that they have a web presence or already in the public domain with their contact details such as address and telephone number published on the same.

When a call is made, permission must be sought to get the correct contact information such as the relevant decision maker with regards to IT purchasing. A record must be kept of whom our employee spoke to and date and time of the call.

All email contact must contain an ‘Opt-Out’ clearly identified options.

We do not market via Postal, Text or Fax.

All Opt-Outs must be respected (telephone or electronic) by deleting the contact permanently.

Policy Review

Bridge Mills Galway Language Centre will continue to review the effectiveness of this policy to ensure it is achieving its stated
objectives on at least an annual basis and more frequently if required considering changes in the law and organisational or security changes.

1.2 Data Protection
Policy – Employees

Bridge Mills Galway Language Centre processes personal data of all employees. Bridge Mills Galway Language Centre
will process all such data in accordance with the General Data Protection Regulation (GDPR) in force from 25^th May 2018.

The purposes for which we process the personal data on employees are: –

To manage the progression of each employee throughout their tenure of employment

To ensure that correct training and development is provided

To ensure employees are correctly rewarded for their service to the appropriate bank accounts

To engage with Revenue for payment of employment taxation

To comply with all relevant law

To ensure contact details of employees are available if required for the purpose of providing our services

To manage any disputes, should they arise

To ensure a next of kin can be contacted if required

Bridge Mills Galway Language Centre share employee details with external bodies such as Revenue, Social Welfare, outsourced Employment Law advisors, auditors, pension brokers & trustees and insurers.

Bridge Mills Galway Language Centre does not transfer any employee personal data to a 3rd country.

Bridge Mills Galway Language Centre ensures all employees personal data is processed subject to sufficient organisational and technical safeguards to protect employee data.

I.I Right to Erasure

When have I the right to all my personal data being deleted by Bridge Mills Galway Language Centre?

You have the right to have your personal data deleted without undue delay if: –

The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed

You are withdrawing consent and where there is no other legal ground for the processing

You object to the processing and there are no overriding legitimate grounds for the processing

The personal data has been unlawfully processed

The personal data must be erased so that we are in compliance with legal obligation

The personal data has been collected in relation to the offer of information society services with a child

What happens if Bridge Mills Galway Language Centre has made my personal data public?
If we have made your personal data public, we, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform those who are processing your personal data that you have requested the erasure.

What happens if Bridge Mills Galway Language Centre has disclosed my personal to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them of your request for erasure where possible.  We will also confirm to you details of relevant third parties to whom the data has been disclosed where appropriate.

I.II  Right to Data Portability

When can I receive my personal data in machine readable format from Bridge Mills Galway Language Centre?
You will receive your personal data concerning you in a structured, commonly used and machine-readable format if: –

processing is based on consent.

processing is carried out by automated means.

Would Bridge Mills Galway Language Centre transfer the personal data to another service provider if I requested this?

We can transfer this data to another company selected by you on your written instruction where it is technically feasible taking account of the available technology and the feasible cost of transfer proportionate to the service we provide to you.

Under what circumstances can Bridge Mills Galway Language Centre refuse?
You will not be able to obtain, or have transferred in machine-readable format, your personal data if we are processing this data in the public interest or in the exercise of official authority vested in us.

Will Bridge Mills Galway Language Centre provide me with my personal data if the file contains the personal data of others?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others.  Where
personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact us at [email protected]

I.III Right for Automated Individual Decision Making including Profiling

What are my rights in respect of Automated Decision making?
Bridge Mills Galway Language Centre does not have any automated decision-making processes.  Where any such processes are introduced, we will provide you with the relevant information required under the “General Data Protection Regulation”.

I.IV Right to Object

Have I already been informed about my right to object?

We have informed you of your right to object prior to us collecting any of your personal data as stated in our privacy notice.

When can I object to Bridge Mills Galway Language Centre processing my personal data?

You can object on grounds relating to your situation.

Bridge Mills Galway Language Centre will stop processing your personal data unless: –

we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms.

the processing is for the establishment, exercise or defence of legal claims.

What are my rights to object for direct marketing purposes?

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, we will no longer process this data for such purposes.

What are my rights to object in the use of information society services?

In the context of the use of information society services, you may exercise your right to object by automated means using technical specifications.

Contact us at [email protected]

I.V Right to Restriction of Processing

When can I restrict processing?
You may have processing of your personal data restricted: –

While we are verifying the accuracy of your personal data which you have contested.

Ifyou choose restricted processing over erasure where processing is unlawful.

If we no longer need the personal data for its original purpose but are required
to hold the personal data for defence of legal claims.

Where you have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override.

What if Bridge Mills Galway Language Centre has provided my personal data to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them about the restriction on the processing, unless it is impossible or involves disproportionate effort to do so.

How will I know if the restriction is lifted by Bridge Mills Galway Language Centre and/or relevant third parties?
We will inform on an individual basis when a restriction on processing has been lifted.

Contact us at [email protected]

I.VI Right of Rectification Policy

What can I do if Bridge Mills Galway Language Centre is holding incorrect personal data about me?
Where you suspect that data we hold about you is inaccurate, we will on demand rectify any inaccuracies without undue delay and provide confirmation of same.

What happens if Bridge Mills Galway Language Centre has disclosed my personal to third parties?
Where we have disclosed inaccurate personal data to third parties, we will inform them and request confirmation that rectification has occurred.  We will also provide you with details of the third parties to whom your personal data has been disclosed.

Contact us at [email protected]

I.VII Right to withdraw Consent

Under what circumstances could I withdraw consent?
You can withdraw consent if we are processing your personal data based on your consent.

When can I withdraw consent?
You can withdraw consent at any time.

If I withdraw consent what happens to my current data?
Any processing based on your consent will cease upon the withdrawal of that consent.  Your withdrawal will not affect
any processing of personal data prior to your withdrawal of consent, or any processing which is not based on your consent.

Contact us at [email protected]

I.VIII Right to lodge a complaint

Can I lodge a complaint with the Data Protection Commissioner?
You can lodge a complaint with the Data Protection Commissioner in respect of any processing by or on behalf of Bridge Mills Galway Language Centre of personal data relating to you.

How do I lodge a complaint?
Making a complaint is simple and free.  All you need to do is write to the Data Protection Commissioner giving details about the matter.  You should clearly identify the organisation or individual you are complaining about.  You should also outline the steps you have taken to have your concerns dealt with by the organisation, and what sort of response you received from them.  Please also provide copies of any letters between you and the organisation, as well as supporting evidence/material.

What happens after I make the complaint?
The Data Protection Commissioner will then take the matter up with Bridge Mills Galway Language Centre on your behalf.

I.IX   Right of Access Policy

When do I have the right to access my personal data from Bridge Mills Galway Language Centre
Where Bridge Mills Galway Language Centre process any personal data relating to you, you have the right to obtain confirmation of same from us, and to have access to your data.

What information will Bridge Mills Galway Language Centre  provide to me?
If we are processing your personal data you are entitled to access a copy of all such personal data processed by us.  We will
also provide the following information including your full rights under Data Protection: –

why we are processing your personal data

the types of personal data concerned

the third parties or categories of third parties to whom the personal data have been or will be disclosed.  We will
inform you if any of the third parties are outside the European Economic Area (EEA)or international organisations

how your personal data is safeguarded where we provide your personal data outside the European Economic Area or to an international organisation

the length of time we will hold your data or if not possible, the criteria used to determine that period

your rights to: –

request any changes to inaccurate personal data held by us.

have your personal data deleted on all our systems.

restriction of processing of personal data concerning you.

to object to such processing.

data portability.

your right to lodge a complaint with the Data Protection Commission [email protected]

where we have collected your personal data from a third party, we will provide you with the information as to our source of your personal data.

any automated decision-making, including profiling which includes your personal data.  We will provide you with
meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

How long will it take to receive my personal data from Bridge Mills Galway Language Centre?
We will provide you with a copy of the personal data we are currently processing within 30 days of request. In rare situations if we are unable to provide you with the data within 30 days we will notify you, within 10 days of your request, explaining the reason for the delay and will commit to delivery within a further 60 days. i.e. 90 days in total.

How much will it cost me to receive my personal data?
We will not charge for providing your personal data unless we believe the request is excessive and the cost of providing your data is disproportionate to your services provided.

Can I request additional copies of my personal data?
If you require additional copies we will charge €20 to cover our administrative costs.

Can I receive my personal data electronically?
You can request your personal data by electronic means and we will provide your personal data in a commonly used electronic form if technically feasible.

What will Bridge Mills Galway Language Centre do if another person’s personal data is shared with my personal data?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others.  Where personal
data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact us at [email protected]

Bridge Mills Galway Language Centre will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives on at least an annual basis and more frequently if required considering changes in the law and organisational or security changes.

Signed: Patrick Creed

Date: 28/05/2019

ISMS Policy Owner: Bridge
Mills Galway Language Centre

1.3 Data Protection Governance Framework

Purpose

GDPR places onerous accountability obligations on controllers and processors to demonstrate compliance.

The purpose of the Data Protection Governance Framework is to ensure Bridge Mills Galway Language Centre has good governance in the management of personal data processed as a controller and a processor.

Objective

To ensure personal data processed as a controller and/or a processer is monitored, controlled and recorded by the appropriate members of Bridge Mills Galway Language Centre throughout the lifecycle from creation, processing, storage, transmission, deletion and destruction of personal data. Privacy by design and data protection by default must be standard practice for processing all personal data within Bridge Mills Galway Language Centre.

To provide an accountability approach by: –

Documenting policies and procedures to be implemented by all staff

Building a culture of data protection in the office, on client site and while transferring data

Educating all staff to ensure data protection encompasses the whole lifecycle of data in use, in transit and in rest whether physical or logical 

Providing the infrastructure for ongoing, efficient data protection management

Developing a data protection risk mitigation strategy (specifically for the individual)

Embedding data protection risk management throughout Bridge Mills Galway Language Centre

Empowering Partners and Managers to assume responsibility for ensuring maintenance of Accountability Framework.

Scope

The scope of this policy is to cover all categories of personal data held on various data subjects including but not limited to: –

Students

Guardians

Teachers

Educational Partners

Host Families

Potential candidates for employment

Employees

Contractors

Sole Traders/Partnerships personal data

Sole Traders/Partnerships business personal data

Companies

Suppliers

Personal data is information relating to an identified or identifiable natural person (‘data subject’). Identifiable natural person is one who can be identified, directly or indirectly, name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that
natural person.

Data Protection Management

Bridge Mills Galway Language Centre will assign the management of personal data to [email protected].
The role will include: –

Provide external training providers to inform Bridge Mills Galway Language Centre of their obligations under GDPR

Coordinate the monitoring of compliance to GDPR with the assistance of external consultants
and management

Alert management when Data Protection Privacy Impact Assessments are required 

Report to management

Being a member of the Data Breach committee

Training

Bridge Mills Galway Language Centre will implement a training programme covering data protection generally and the areas that are specifically relevant to their schools or colleges.

Senior Staff

Bridge Mills Galway Language Centre will ensure all management and teachers are educated about their requirements under GDPR and the possible impact of non-compliance for Bridge Mills Galway Language Centre

Bridge Mills Galway Language Centre will identify key senior management to support the data protection compliance programme.

General Staff

Bridge Mills Galway Language Centre will ensure all staff and teachers are provided with a training programme covering data protection generally. Also, the areas that are specifically relevant to their jobs, providing the new policies setting out to comply.

Bridge Mills Galway Language Centre has a policy that all staff and teachers should be trained on Data Protection and will also ensure refresher training is provided when required.

Attendance at all training courses is recorded.

Privacy by Design

Bridge Mills Galway Language Centre will adopt internal policies, Technical and Organisational Measures (TOM) to meet the principles of privacy by design and data protection by default. Bridge Mills Galway Language Centre will adopt internal policies and implement technical and organisational measures by: –

Implementing pseudonymisation and encryption where feasible

Data Minimisation

Risk Management

Integrating data privacy into IT policies, Data Retention and Deletion Policy

Providing data subject transparency and access

By developing access controls for confidentiality which provide that only personal data which isnecessary for each specific purpose of the processing is processed during the retention period as informed to the data subject

By developing access controls (roles-based) which provide that personal data is not made accessible
to more individuals than necessary for the purpose

Providing an audit trail of the access controls

Ability to restore availability of and access to data in the event of an incident

Regular test of the effectiveness of security measures

Data Privacy Impact Assessment (DPIA)

Bridge Mills Galway Language Centre will carry out privacy impact assessments where a type of processing is likely to result in a high risk for the rights and freedoms of data subjects in the following cases but not limited to this list: –

·       in the event of a systematic monitoring of a publicly accessible area

·       in the context of profiling on which decisions are based that produce legal effects

·       in the event of implementing new IT which infringes on the data subject’s rights

·       in the event there is a change to the risks posed by the processing operations to personal data

Bridge Mills Galway Language Centre will have in place a process for determining whether a Data Privacy Impact Assessment (DPIA) is required. A DPIA will be embedded in all Business Cases presented to management for any proposed new projects.

If a DPIA is required, the following process will be conducted: –

·       a systematic description of the processing operations and purposes of the processing

·       an assessment of the necessity and proportionality of the processing operations

·       an assessment of the risks to the rights and freedoms of data subjects

·       if appropriate may seek the views of the affected data subjects measures envisaged to address the risks

Bridge Mills Galway Language Centre will consult the Supervisory Authority if a DPIA result is of a high level of risk where Bridge Mills Galway Language Centre cannot take measures to mitigate this risk.

Demonstrating Consent

Bridge Mills Galway Language Centre will have an audit trail for consent.  This will demonstrate that consent was given when relying on consent as a ground for processing personal data. Given the nature of the services offered consent is predominately relied on prior to engagement letters signed by the student or parent/guardian at the
enrolment stage.

Consent is recorded from all data with a clear record of what each individual data subject consented to: –

Demonstrating Compliance to the data protection principles

Bridge Mills Galway Language Centre will document all the current processing activities to provide a Personal Data Register Data Protection Register identifying: –

·      
Service Department and Service line

·      
Data Class and Data Category

·      
Process Name

·      
Purpose for processing

·      
Data category and Data class

·      
Controller/Processor/Both/Joint Controller

·      
Data Owners

·      
Lawful basis

·      
Data Accuracy Process

·      
Process Map where available

·      
Format of Data

·      
Recipients of Data

·      
Data shares internally and lawful bases provided

·      
Transfer methods

·      
Location of Data storage

·      
Retention Periods

·      
Data Access Controls

·      
Risk Management

·      
Transfers to Third Countries

·      
External Processor 

Bridge Mills Galway Language Centre will update its current policies and procedures to ensure compliance to the principles. See Section Policy Section.

Records to be maintained as a Data Controller 

Bridge Mills Galway Language Centre will: –

·      
clearly identify where personal data is
processed within the company, including by third party processors

·      
provide the name and address details of the
Bridge Mills Galway Language Centre and any joint controller

·      
use the Personal Data Register to record
details of

·      
the purposes of the processing

·      
a description of categories of data subjects
and personal data

·      
the categories of recipients of personal data

·      
the details of transfers to third countries

·      
the time limits for erasure of different
categories of data

·      
a general description of technical and organisational security measures taken

Records to be maintained as a Processor Bridge Mills Galway Language Centre as a Processor for many of its clients will
maintain a record of all categories of personal data processing activities carried out on behalf of its clients (controllers).

Bridge Mills Galway Language Centre will use the Personal Data Register to record the following details in respect of each Client (controller)

·      
name and contact details of the client
(controller) on behalf of which it is processing

·      
categories of processing

·      
transfers of data to a third country or international organisation

·      
general description of the technical and organisational security measures

As part of data accuracy Bridge Mills Galway Language Centre will keep information relating to the contracts that they are responsible for up-to-date and accurate.

Export of Personal Data

Bridge Mills Galway Language Centre will review and map the international data flows, including:

·      
data flows where Bridge Mills Galway Language Centre is exporting to a controller or processor outside of the EEA

·      
data flows Bridge Mills Galway Language Centre is importing as a processor or controller

·      
consider what existing data transfer mechanisms are in place and whether these continue to be appropriate.

Countries that are currently white listed remain so until a Commission review finds otherwise

Andorra, Argentina, Canada, Switzerland, Faeroe Islands, Guernsey, Israel, Isle of Man, Jersey, Uruguay and New Zealand

Standard Contract Clauses remain a valid mechanism for non-EEA
transfers

·      
ensure that export obligations are flowed down through subcontractor chains and across to other controllers where required

Joint Controller Agreements

In circumstances where Bridge Mills Galway Language Centre and another organisation determine the purposes for which and the way the personal data is processed, each party will be a controller and will be liable for the entirety of any damage to a data subject, unless they can prove they were not in any way responsible for the event giving rise to the damage.

Bridge Mills Galway Language Centre will ensure that there is a clear attribution of data protection responsibilities between joint controllers and that this information is made available to data subjects through privacy notices or other means so that a controller will be able to show it was in no way responsible for the event giving rise to the damage if this is the case.

Bridge Mills Galway Language Centre will ensure that contract negotiators are aware of the default position of each controller being liable for the entire damage to a data subject if it is in any way responsible for the event giving rise to the damage and include appropriate cross indemnification.

Processors

Bridge Mills Galway Language Centre is processors for all their Clients who are legal entities. Bridge Mills Galway Language Centre as a processor will ensure: –

·      
to implement Technical and Organisational Measures (TOM) to safeguard the personal data:

·      
not to appoint sub- processors without the consent of the controller

·      
to notify breaches to the controller

·      
to cooperate directly with the Supervisory Authority

·      
to assess any intra-group processor agreements and make amendments to include minimum requirements and if necessary to keep liability limited towards the group’s main establishment or service companies

Budget

Bridge Mills Galway Language Centre will allocate an annual budget for data protection compliance.

Reporting

Staff are required to report any data breaches to [email protected] as soon as the data
breach is discovering (regardless of the timing of the discovering any day of the week and any time of the day).

The Office Manager will report to all staff any new changes to GDPR and of any cyber treats or attacks as this information becomes known, also providing steps to take to avoid this occurring to[Bridge Mills Galway Language Centre

The Office Manager will report to management monthly of: –

·       Internal incidences reported

·       Internal breaches

·       GDPR improvements implemented

·       Status of current projects on GDPR

·       Awareness and training process

·       Relevant external breaches reported

·       Updates to compliance

·       DPIA’s

The DPL will assess all data breaches reported in line with the data breach policy and if such a breach requires reporting to the Supervisory Authority, this will be approved by management.

Appendix A Right to lodge a complaint with supervisory authority

Every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy.

Appendix B
   Right to an effective judicial remedy against a supervisory authority

Each Client will have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

Each data subject shall have the right to an effective judicial remedy where the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of thecomplaint lodged.

Appendix C       

Right to an effective judicial remedy against a controller or processor

Each data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with this Regulation.

Proceedings against a Client as a controller or a processor may be brought before the courts of the Member State where the controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the controller or processor is a public
authority of a Member State acting in the exercise of its public powers.

Appendix D        

Representation of data subjects

The data subject has the right to mandate a not-for-profit body, organisation or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects’ rights and freedoms with regard to the protection of their personal data to lodge the complaint on his or her behalf.

Member States may provide that anybody, organisation or association as described in previous paragraph, independently of a data subject’s mandate, has the right to lodge, in that Member State, a complaint with the supervisory authority if it considers that the rights of a data subject under this Regulation have been infringed as a result of the processing.

Appendix E                      

 Right to compensation and liability

Any person who has suffered material or non-material damage as a result of an infringement of this Regulation has the right to receive compensation from the controller or processor for the damage suffered.

Any controller involved in processing shall be liable for the damage caused by processing which infringes this Regulation. A processor shall be liable for the damage caused by processing only where it has not complied with obligations of this

Regulation specifically directed to processors or where it has acted outside or contrary to lawful instructions of the
controller.

A controller or processor shall be exempt from liability if it proves that it is not in any way responsible for the event giving rise to the damage.

Where more than one controller or processor, or both a controller and a processor, are involved in the same processing and where they are, responsible for any damage caused by processing, each controller or processor
shall be held liable for the entire damage in order to ensure effective compensation of the data subject.

Where a controller or processor has paid full compensation for the damage suffered, that controller or processor shall be entitled to claim back from the other controllers or processors involved in the same processing that part of the compensation corresponding to their part of responsibility for the damage.

Court proceedings for exercising the right to receive compensation shall be brought before the courts.

Appendix F                       

General conditions for imposing administrative fines

Each supervisory authority shall ensure that the imposition of administrative fines pursuant to this in respect of infringements of this Regulation shall in each individual case be effective, proportionate and dissuasive.

Administrative fines shall, depending on the circumstances of each individual case, be imposed. When deciding whether to impose an administrative fine and deciding on the amount of the administrative fine in each individual
case due regard shall be given to the following: –

If a controller or processor intentionally or negligently, for the same or linked processing operations, infringes several provisions of this Regulation, the total amount of the administrative fine shall not exceed the amount specified for the gravest infringement.

Infringements of the following provisions shall, be subject to administrative fines up to 10 000 000 EUR, or in the case of an
undertaking, up to 2 % of the total worldwide annual turnover of the preceding financial year, whichever is higher: –

Infringements of the following provisions shall, be subject to
administrative fines up to 20 000 000 EUR, or in the case of an
undertaking, up to 4 % of the total worldwide annual turnover of the preceding
financial year, whichever is higher:

Non-compliance with an order by the supervisory authority as referred to in corrective action, be subject to administrative fines up to 20,000,000 EUR, or in the case of an undertaking, up to 4 % of the total worldwide annual turnover of the preceding financial year, whichever is higher.

If required the school has arrangements in place for the protection of students in the event that a programme ceases prematurely i.e. arrangements for a student to complete the programme with another provider(s). Student protection arrangements cover the period from when a student enrols on a programme until the time the student has successfully completed the programme and the end-of-programme exams. It can be purchased when students enrol on a programme.