How we respect privacy when we deal with personal information collected by our organisation
This Privacy Policy applies to information we collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.
If you have any comments or questions about this notice, feel free to contact us at becky.ausenda@ben.bm to reach our Data Privacy Officer, Becky Ausenda. Or by telephone at (441) 707-5020.
1. Personal data that we process
The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.
| Purpose | Data (key elements) | Basis |
| Enquiring about our organisation and its work | Name, email, message, telephone | Legitimate interests – it is necessary for us to read and store your message and/or record your telephone call so that we can respond in the way that you would expect. |
| Subscribing to email updates about our work | Name, email | Consent – you have given your active consent. |
| Subscribing for the Horizons program and expeditions | Name, email, school name, year level | Consent – the school leader provides consent for us to contact teachers directly and enrol them for Horizons expeditions |
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.
For example, we may use your personal information to:
- reply to enquiries you send to us;
- where you have subscribed for a program, to notify you of an upcoming event and to enrol you;
- where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.
3. When we share your data
Our data sharing with third parties is extremely limited and only occurs under the following circumstances:
- we are required by law to share your data.
- with your explicit consent, your data may be shared with our local partners in the Horizons program in order for them to provide you with resources;
- we are required to provide information to our auditors, Deloitte and they have signed a contract promising that any information shared by us about our customers is confidential;
- visitors to our website from overseas may view images of our programs and find information about our organisation and Bermuda’s schools that is publicly available;
We do not conduct any financial transactions with our customers as all our services are provided free of charge. We do not use third party data processors and no data is passed by us to third parties outside of Bermuda. We do not track usage or collect data by using cookies on our website.
4. How long we keep your data
We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
Where data is collected on the basis of consent, we will seek renewal of consent at least every three years, or during the course of regular correspondence. You may revoke consent at any time you cease to use our services.
5. Rights you have over your data
You have a range of rights over your data, which include the following:
- Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
- You have the right to ask for rectification and/or deletion of your information.
- You have the right of access to your information.
- You have the right to lodge a complaint with the Privacy Commissioner if you feel your rights have been infringed.
The rights you have over your data are outlined at https://www.gov.bm/sites/default/files/Personal-Information-Protection-Act-2016.pdf
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
7. Modifications
We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we’ll notify people whose personal data we hold and is affected.