Ethos Education Ltd Customer Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- How to complain
Contact details
Email: info@ethos-education.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Occupation
- Employment details (including salary, sick pay and length of service)
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Account information, including registration details
- Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Profile information
- Marketing preferences
- Purchase or account history
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Client account information
- Health and safety information
- Any other personal information required to comply with legal obligations
- Safeguarding information
- Criminal offence data
We collect or use the following personal information for recruitment purposes:
- Contact details (eg name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Addresses
- Payment details
- Account information
- Purchase or service history
- Call recordings
- Witness statements and contact details
- Photographs
- Relevant information from previous investigations
- Customer or client accounts and records
- Information relating to health and safety (including incident investigation details and reports and accident book records)
- Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We have a legitimate interest in analysing service feedback and candidate\/client usage patterns to improve our recruitment tools and matching processes. This processing is not a legal or contractual requirement, but it allows us to refine our pedagogical selection criteria and provide a more efficient service to both schools and teachers with minimal privacy impact.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- It is in our legitimate interest to keep our active talent pool informed about relevant job opportunities and sector-specific updates that align with their professional experience. This processing is necessary to maintain an engaged workforce for our school clients. We ensure individuals can easily opt-out or manage their preferences at any time to minimise privacy intrusion.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We have a legitimate interest in processing and retaining records of interactions, feedback, and formal complaints to effectively resolve disputes and protect our legal rights in the event of a claim. This ensures we maintain high professional standards, which require a robust and documented complaints procedure to ensure service integrity.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
- Regulatory authorities
- Publicly available sources
- Previous employment
- Providers of marketing lists and other personal information
- Third parties:
- We receive personal information from existing candidates or clients who refer work-seekers to us through our ‘Recommend a Friend’ scheme. In these cases, we expect the referrer to have the individual’s permission to share their contact details with us for recruitment purposes.
How long we keep information
How long we keep information
We do not keep personal data for longer than is necessary. We apply the following standard retention periods to our records to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and UK GDPR.
| Record Type |
Retention Period |
Reason for Retention |
| Work-seeker Records (CVs, application forms, and vetting details) |
1 year from the last date of providing work-finding services. |
Statutory requirement under the Conduct Regulations 2003. |
| Terms of Business (with clients and temporary workers) |
6 years following the termination of the agreement. |
To manage potential contractual claims under the Limitation Act 1980. |
| Right to Work Documentation |
2 years after the candidate’s engagement has ended. |
Home Office and REC compliance. |
| Payroll & Tax Records (if applicable) |
6 from the end of the financial year they relate to. |
HMRC and statutory requirement. |
| DBS Certificates & Update Service Checks |
1 year from the last date of providing work-finding services |
DBS Code of Practice and safeguarding requirements. |
Who we share information with
Data processors
Recruitment Software and CRM Providers
This data processor does the following activities for us: These processors provide our central recruitment database (CRM) and Applicant Tracking System (ATS). They store and organize candidate CVs, contact details, and application history, allowing us to track the recruitment process from initial introduction to placement. This software automates administrative tasks, such as resume parsing and interview scheduling, and serves as a secure central repository for all professional interactions with work-seekers and school clients.
IT and Cloud Storage Providers
This data processor does the following activities for us: These processors provide the digital infrastructure and secure cloud storage (such as Microsoft 365 or Google Workspace) where our business emails and candidate files are hosted. They ensure the ongoing confidentiality, integrity, and availability of our data by providing encrypted storage, regular system backups, and technical security measures that protect against unauthorized access or data loss.
Others we share personal information with
- Professional or legal advisors
- Regulatory authorities
- External auditors
- Organisations we’re legally obliged to share personal information with
- Third parties:
- We share candidate personal information with our Client Schools and Educational Settings for the purpose of introducing candidates for specific vacancies or potential roles.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint