Thinking Words Academy (TWA), through the course of normal business activities and as a specialist provider of education and learning services, collects and uses personal information (or personal data) relating to individuals. Such individuals may include members of the public and public bodies with whom TWA is directly or indirectly engaged; previous, current and prospective employees; students, customers and suppliers.

The law which governs the identification, treatment and handling of personal data in England and Wales is the Data Protection Act 1998 (“the Act”). It is concerned with the rights of individuals to gain access to personal information held about them by an organisation or individual within it and the right to challenge the accuracy of data held. The terms of the Act relate to data held in any form, including written notes and records, not just to electronic data.

TWA is committed to maintaining high standards of confidentiality and privacy with respect to the processing of personal information.

This Policy sets out the obligations of TWA and its employees when processing personal data about individuals. It is important that all TWA employees understand the rules governing the identification, treatment and handling of personal data. TWA employees may also find the Information Commissioner’s Office website of use in seeking preliminary guidance. The website can be found at the following address:


Personal data is information which relates to a living individual (not companies, although information about a named individual of a company will be personal data) who can be identified from that information, whether or not in conjunction with any other information. Common examples of personal data which may be used by TWA in its day to day business activities include names, addresses, telephone numbers and other contact details, CV’s, performance reviews and salaries.

TWA will be processing personal data if it holds personal data and/or carries out any operation relating to that information such as altering or deleting it, accessing, downloading, reviewing or transferring it.

Any personal data which TWA collects, records or uses in any way, whether it is held on paper, on computer or other media will have appropriate safeguards applied to it to ensure that TWA complies with the Act.

There are 8 Data Protection Principles put in place by the Act to make sure that information is handled properly, the principles state that personal data must be:

  • Fairly and lawfully processed
  • Processed for limited purposes
  • Adequate, relevant and not excessive
  • Accurate
  • Not kept for longer than is necessary
  • Processed in line with the data protection subject rights
  • Secure; and
  • Not transferred to countries where legislation does not provide equivalent or adequate protection

TWA upholds these principles.

TWA intends to collect personal data for the sole purpose or meeting specifically planned, agreed and necessary purposes and to retain that information for as long as those purposes remain valid. Such purposes include:

  • Staff Administration; including but not limited to; appointments or removals, pay, discipline, superannuation, work management or other personal matters in relation to its
  • Advertising Marketing and Public Relations; including but not limited to, advertising or marketing the business of TWA, activity, goods or services and promoting public relations in connection with that business, activity or goods or services.
  • Accounts and Records including but not limited to; keeping accounts related to business and activities carried on by TWA, deciding whether to accept a person as a customer or supplier, keeping records of purchases, sales or other transactions for the purposes of ensuring that the requisite payments and deliveries are made, services provided by TWA or to TWA and financial or management forecast information to assist TWA in the conduct of its business and
  • Education, including but not limited to; the provision of education or training as a primary function or as a business
  • Consultancy and Advisory Services; including but not limited to; the giving of advice or rendering professional services and the provision of services of an advisory, consultancy or intermediary

Any personal data collected must only be passed to a third party where required by law, to comply with a statutory obligation or where TWA has obtained the express written consent of the individual concerned.

In order for TWA to meet the requirements of the Data Protection Principles, TWA will:

  • Observe fully the conditions regarding fair collection and use of personal data;
  • Meet its legal obligations to specify the purpose for which personal data is used;
  • Collect and process appropriate personal data and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
  • Ensure the quality of personal data used;
  • Apply strict checks to determine the length of time personal data is held;
  • Take appropriate technical and organisational security measures to safeguard personal data
  • Ensure that personal data is not transferred abroad without suitable safeguards;
  • Ensure that the rights of people about whom the information is held can be fully exercised under the

Where TWA collects sensitive personal data, it will take appropriate steps to ensure that it has explicit consent to hold, use and retain such data. Sensitive personal data includes personal data about an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sex life, details of the commission or alleged commission of any offence and any court proceedings relating to the commission of an offence.