INTRODUCTION
Gaia Learning Ltd is committed to protecting the privacy and security of your Personal Data.
This privacy notice describes how we collect and use information about you that could be used to
identify you (“Personal Data”), during and after your working relationship with us, in accordance with
the General Data Protection Regulation (“GDPR”).
This notice does not form part of any contract of employment or other contract to provide services. We
may update this notice at any time but if we do so, we will provide you with an updated copy of this
notice as soon as reasonably practicable. It is important that you read and retain this notice or any
updated version of this notice so that you are aware of how and why we are collecting or processing
Personal Data about you and what your rights are under the data protection legislation.
Gaia Learning Ltd is a "data controller". This means we are responsible for deciding how we hold and
use Personal Data about you. We are required under data protection legislation to notify you of the
information contained in this privacy notice.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the Personal Data we hold about you must be:
1 Used lawfully and in a transparent way;
2 Collected only for valid purposes that we have clearly explained to you and not used in any way
that is incompatible with those purposes;
3 Relevant to the purposes we have told you about and limited only to those purposes;
4 Accurate and kept up to date;
5 Kept only as long as necessary for the purposes we have told you about; and
6 Kept securely
HOW WILL WE USE PERSONAL DATA ABOUT YOU?
We will only use your Personal Data when the law allows us to. The GDPR explains what legal bases data
controllers can rely on to legally process Personal Data. Most commonly, the bases we will rely on to
use your Personal Data are as follows:
1 Where you have consented to us using your Personal Data, such as when you send us your CV
with Personal Data contained in it (“Consent”);
2 Where we need to perform the contract we have entered into with you, such as paying you your
salary (“Contractual Obligation”);
3 Where we need to comply with a legal obligation, such as reporting fraudulent activity or other
illegal actions (“Legal Compliance”); and
4 Where it is necessary for legitimate interests pursued by us or a third party and your interests
and fundamental rights do not override those interests, such as providing a list of our employees
to investors as part of a due diligence process; (“Legitimate Interest”).
WHAT CATEGORIES OF YOUR PERSONAL DATA DO WE COLLECT, STORE AND USE?
Below we list all of the categories of Personal Data we collect, store and use. Not all of the following
types of data will necessarily be collected from you but this is the full scope of team member Personal
Data that we collect:
WHEN DO WE COLLECT YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR COLLECTING
IT?
Under the GDPR you are entitled to understand exactly when we collect different categories of your
Personal Data and what legal justification we rely on in order to use that Personal Data.
Set out below is a table containing the different categories of Personal Data we collect, when we collect
it (e.g. the activity that gives rise to the Personal Data collection) and the lawful basis for collecting,
processing and using that Personal Data. Please refer to the section entitled "How Will We Use Personal
Data About You?" to understand more about the legal basis we rely on.
Examples provided in the table below are indicative in nature and the purposes for which we use your
data may be broader than described, but we will never process your data without a legal basis for doing
so and it is for a related purpose. For further inquiries please contact your manager.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.
Failing to provide Personal Data
If you fail to provide certain information when requested, we may not be able to perform the contract
we have entered into with you (such as paying you or providing a benefit), or we may be prevented
from complying with our legal obligations (such as to ensure the health and safety of our team).
SHARING PERSONAL DATA WITH THIRD PARTIES
We may have to share your data with third parties, including third-party service providers and other
entities in the group. We require third parties to respect the security of your data and to treat it in
accordance with the law.
We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of
protection in respect of your Personal Data.
We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in
the legal justification table above.
”Third parties” include:
Third-party service providers (including contractors and designated agents) and other entities
within our group. Examples of the services we may receive from third-parties that would require
us to share team Personal Data could include: payroll, pension administration, legal services
(such as SeedLegals), IT services, etc.;
Other entities in our group structure (if applicable);
Third parties in the context of a possible sale or restructure. In this situation we will so far as
possible share anonymised data with the other parties before the transaction completes. Once
the transaction is completed, we will share your Personal Data with the other parties if and to the
extent required under the terms of the transaction; and
We may need to share your Personal Data with a regulator or to otherwise comply with the law.
This may include making returns to HMRC or disclosures to shareholders such as directors’
remuneration reporting requirements.
If you would like to know exactly which third parties have been given access to your Personal Data by
us, please contact your manager.
DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your Personal Data to those employees, agents, contractors and other third parties who have
a business need to know. They will only process your Personal Data on our instructions and they are
subject to a duty of confidentiality. Details of these measures may be obtained from your manager. If
any data is shared to third parties they will only process your Personal Data on our instructions and
they are subject to a duty of confidentiality.
DATA RETENTION
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine
the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of
the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal
Data, the purposes for which we process your Personal Data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated
with you, in which case we may use such information without further notice to you.
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RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and current. Please keep us
informed if your Personal Data changes during your working relationship with us.
Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
Request access to your Personal Data (commonly known as a "data subject access request").
This enables you to receive a copy of the Personal Data we hold about you and to check that we
are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any
incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal
Data where there is no good reason for us continuing to process it. You also have the right to ask
us to delete or remove your Personal Data where you have exercised your right to object to
processing (see below).
Object to processing of your Personal Data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you
want to object to processing on this ground. You also have the right to object where we are
processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to
suspend the processing of Personal Data about you, for example if you want us to establish its
accuracy or the reason for processing it.
Request the transfer of your Personal Data to another party.
If you want to review, verify, correct or request erasure of your Personal Data, object to the processing
of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please
contact your manager in writing.
No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your
right to access the information (or to exercise any of your other rights). This is another appropriate
security measure to ensure that Personal Data is not disclosed to any person who has no right to
receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing
and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent
for that specific processing at any time. To withdraw your consent, please contact your manager. Once
we have received notification that you have withdrawn your consent, we will no longer process your
information for the purpose or purposes you originally agreed to, unless we have another legitimate
basis for doing so in law.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new
privacy notice when we make any substantial updates. We may also notify you in other ways from time
to time about the processing of your Personal Data.
Staff Behavior Policy & Code of Conduct
Introduction:
At Gaia Learning Online School, our commitment revolves around our core values of inclusion, innovation, and inspiration. This policy sets the expected behaviour and conduct of our staff, consistently promoting these values in all interactions and operations.
1. Core Values & Principles:
a. Inclusion: Ensure that every student feels recognised, valued, and integrated into the learning journey.
b. Innovation: Continuously seek and incorporate cutting-edge techniques, tools, and teaching methods.
c. Inspiration: Aim to motivate, uplift, and stimulate each student, nurturing a persistent passion for learning.
2. Data Ethics & Analytics:
a. Agency: Prioritise granting students authority over their learning and futures.
b. Transparency: Ensure students comprehend how their data is used and for which purposes.
c. Protection: Safeguard student data, guaranteeing its privacy and security.
d. Beneficial Use: Harness data analytics for enhancing learning outcomes while respecting students' dignity and rights.
3. Professional Behaviour:
a. Respect: Treat students, parents, colleagues, and stakeholders with dignity and respect.
b. Confidentiality: Uphold the confidentiality of student data, communications, and sensitive information.
c. Continuous Learning: Pursue consistent professional development to stay updated with educational advancements.
4. Student Interaction:
a. Positive Encouragement: Cultivate a welcoming online learning atmosphere, encouraging active student participation.
b. Feedback: Offer constructive feedback, highlighting growth areas while appreciating accomplishments.
c. Empowerment: Emphasise student control over their educational trajectory, ensuring they can retrieve their personal data when needed.
5. Collaboration:
a. Teamwork: Collaborate seamlessly with peers, sharing insights and diverse teaching strategies.
b. Open Communication: Foster transparent communication across the school community.
c. Conflict Resolution: Address disputes professionally, seeking mediation if necessary and always striving for solutions that echo our core values.
6. Digital Footprint & Social Media:
a. Professional Boundaries: Staff should not befriend any minor on social media platforms.
b. Online Representation: All staff members will undergo a social media check and should be conscientious of how their online presence reflects on the school's reputation.
7. Continuous Reflection:
Engage in regular introspection regarding teaching practices, ensuring they align with our core values and prioritise students' well-being.
8. Compliance:
All staff members must comply with this code of conduct. Non-adherence will be addressed following the school’s disciplinary procedures, potentially leading to corrective actions or termination.
Our Promise to You:
At Gaia Learning, we passionately collaborate with educators resonating with our vision and values. We guarantee:
Equal Opportunity: Every hour between educator and learner holds equal significance, regardless of the subject or age group.
Resource Availability: Access to contemporary, high-quality curriculum resources, supplemented by training.
Innovative Collaboration: Work in a progressive, co-curricular, holistic setting with a dynamic team.
Flexibility: Freedom to determine your availability, harmonising with personal commitments and interests.
Active Marketing: We promise to actively recruit students via community involvement, partnerships, and genuine representation on social media.
Expectations from You:
Engage in our training, understanding your pivotal role in fostering student success through independent learning and skills development for the 21st century.
Strictly adhere to the Tutor’s Code of Ethics. Ensure lesson recordings and communicate exclusively via FlexiSchool for safeguarding and training reasons.
Promote holistic well-being by utilising technology and the provided curriculum, reducing extraneous work for everyone involved.
Bolster our online presence by engaging on social media, inviting potential tutors, parents, and others to our community groups.
Enrich Gaia Learning by contributing your expertise, continually elevating the teaching quality.
Process:
Our emphasis on self-directed learning aspires for tutors to evolve into student coaches over time, driving them towards independent learning. Your role is to facilitate learning goal setting, adapting learning plans reflecting student progression. By following our lesson guidelines, create a consistent, secure environment. Regularly update FlexiSchool courses with pertinent material catering to diverse learning styles.
