| Purpose for processing |
Categories of Data |
Lawful basis |
| For business continuity planning |
Any of the categories of personal data detailed in this notice |
Legitimate interest to ensure business continuity. |
| For monitoring and assessing compliance with our policies and standards |
Any of the categories of personal data detailed in this notice: specific category will depend upon the specific activity |
Legitimate interest to conduct business in compliance with applicable law and standards. |
| To protect the security and access of our systems, premises, staff and visitors, platforms and secured websites and applications. |
Monitoring Data primarily but may include other categories such as Technical Data |
Legal obligation to ensure a safe and healthy workplace, and to ensure that all visitors to our premises are kept reasonably safe.
Legitimate interest in ensuring the safety and security of our people, goods, premises and systems, and taking action to mitigate risk and to prevent and detect matters which may put us, or our business or stakeholders, at risk, for processing that goes beyond that strictly required by law.
To the extent that the information processed includes Personal Data relating to actual or alleged criminal offences, we may process this information as necessary to prevent or detect crime. |
| To operate a customer relationship management system (CRM) in which we keep data of customers, suppliers and other business partners for relationship management |
Personal Details
Professional Details |
Legitimate interests in maintaining up to date records, ensuring business continuity and operating our business |
| To comply with our legal and regulatory obligations in the UK, including reporting to and/or being audited by regulatory bodies or other authorities or responding to lawful requests from such authorities (including without limitation under national security or law enforcement requirements). |
Any of the categories of personal data detailed in this notice: specific category will depend upon the specific obligation or request.
We may also process Sensitive Personal Data that may include information about actual or alleged criminal offences (where required or otherwise permitted by law) |
Legal obligation
Legitimate interest to ensure that we conduct our business in compliance with applicable law and standards where we are processing Personal Data. |
| To respond to court orders, exercise and/or defend our legal rights and in connection with complaints or legal claims made by, against, or otherwise involving you |
Any of the categories of personal data detailed in this notice: specific category will depend upon the specific activity.
We may also process Sensitive Personal Data that may include information about health and/or alleged or actual criminal offences (where required or otherwise permitted by law) |
Legal obligation
To the extent that this requires us to process Sensitive Personal Data, we rely on the fact that the processing is necessary for the establishment, exercise or defence of legal claims, or whenever courts are acting in their judicial capacity. |
| In connection with a sale, transfer of assets, investments, acquisition, bankruptcy or similar event |
Any of the categories of personal data detailed in this notice |
Legitimate interests in growing the business and making investment decisions. |
| To aggregate and anonymise Personal Data to create statistical or demographic data, for example to calculate the percentage of users accessing a specific website feature |
Any of the categories of personal data detailed in this notice |
Legitimate interest in improving and developing our services
To the extent this includes any Sensitive Data, we will process such data to the extent necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes |
2. How we collect your Personal Data
We will collect Personal Data from you when you:
- Make an enquiry or contact us during the ordinary course of business, such as an online enquiry, email, phone or other means of communication;
- When you apply to become a member of our clubs (or add family members to your membership) and/or make an application for your child to attend one of our nurseries and as part of managing that membership;
- When you use our services as a member;
- Use our websites (including automatically via technologies such as cookies);
- Interact with our social media accounts; e.g., via Facebook, LinkedIn or Twitter.
3. How long do we keep your Personal Data?
Your Personal Data will be retained for as long as necessary to fulfil the purpose for which it was processed or to comply with legal, regulatory or internal policy requirements.
Further information about our retention periods can be obtained by contacting us at the contact details specified in this Privacy Notice.
4. Who has access to and how we may disclose your Personal Data?
We do not and will not sell, rent or trade your Personal Data.
We will disclose your Personal Data in the ways set out in this Privacy Notice and, specifically, to the following categories of recipients:
- LHG group companies
- our owners and affiliates, including Blackstone, where this helps us to better operate our business;
- our third-party service providers, agents, subcontractors and other organisations that are providing services to us or directly to you on our behalf (such as mobile app services, cloud service providers, security systems providers, administrative service providers, CRM providers);
- any third-party to whom we assign or novate any of our rights or obligations;
- any prospective buyer in the event we sell any part of our business or assets; and/or
- local authorities, in connection with safeguarding reports we are required to make, and other disclosures necessary in connection with the provision of early years education;
- to any other government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.
Depending on your cookie choices, we may share your Personal Data with service providers that are providing analytics, marketing and ad measurement services to us, such as Google Analytics and Meta Business. Please see our Cookies Policy for more details.
5. International transfers of Personal Data
All LHG group companies are based in the UK and process personal data in the UK.
However, your Personal Data may be transferred to third parties (e.g. service providers providing services to LHG group companies) who may have systems or suppliers located outside of the UK. This means that such third parties will be processing your Personal Data outside of the UK. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by applicable data protection law, in particular the Standard Contractual Clauses approved by the European Commission, with the UK addendum thereto as appropriate, and supplemented by additional contractual, organisational and security measures as necessary.
You have a right to request a copy of the appropriate measures we put in place. Please note that any data transfer agreement made available to you may be redacted for reasons of commercial sensitivity.
6. Third-party information
When you give us information about another person, you confirm that they have agreed that you can share their information with us and have given them a copy of this Privacy Notice.
7. Your Rights
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any information changes during your working relationship with us.
You have several rights in relation to your Personal Data. In certain circumstances these rights may not be absolute, which we can discuss with you further where relevant. You are not required to pay a charge in most circumstances for exercising your rights and we generally have one month to respond to your request.
We ask for proof of ID where we need to confirm the identity of the individual making the request to comply with our security obligations and prevent unauthorised disclosure of data.
You can make such a request to exercise any of your data subject rights by sending us an email to katy@littlehousesgroup.co.uk or the contact detailed in the table at the end of this Privacy Notice.
(a) Right to access and rectify Personal Data
You may request a copy of your Personal Data from any LHG group company which may hold Personal Data about you. You can also ask us to correct any inaccuracies in your Personal Data though we may need to verify the accuracy of the new data you provide to us.
We may refuse to provide you with a copy of your data in certain circumstances, for example, if your request is manifestly unfounded. If we refuse your request, we will explain the reason for refusing it.
(b) Right to erase Personal Data
You have the right to ask us to delete or remove Personal Data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your Personal Data to comply with applicable law.
If you ask us to delete your information, we may not be able to do so, for example due to regulatory and contractual constraints which will be notified to you, if applicable, at the time of your request. For example, we may need to retain certain Personal Data about you if required for us to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
(c) Right to object to processing of your Personal Data
You have the right to object to processing where we are relying on our 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 as you feel it impacts on your fundamental rights and freedoms. In such case, we must stop that processing unless we can either demonstrate legitimate grounds for the processing that override your interests, rights, and freedoms or where we need to process your Personal Data for the establishment, exercise, or defence of legal claims. You also have the right to object to receiving any direct marketing to which you previously opted in.
(d) Right to restrict the processing of your Personal Data
This enables you to ask us to restrict (i.e., retain without using) the processing of your Personal Data in the following scenarios:
(i) if you want us to establish the data’s accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(e) Right to data portability
You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.
(f) Right to withdraw consent to processing
You have the right to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
(g) Right to complain
We welcome the opportunity to attend to any of your concerns or complaints about the way in which we handle your Personal Data, however you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues: https://ico.org.uk/global/contact-us/
8. Protecting your Personal Data
We are committed to keeping secure the Personal Data you provide to us. We take all reasonable precautions to protect the Personal Data we hold about you from misuse and loss and from unauthorised access, modification or disclosure. Such measures include using industry-standard administrative, technical, and physical safeguards to protect your Personal Data against loss, theft, misuse, unauthorized access, modification, disclosure, and destruction.
9. Automated decision making
We do not carry out any automated decision making (including profiling) of you that produces a legal effect or similarly affects you. If this changes, we will inform you of this.
10. Links to other websites
We may provide links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website, and we are not responsible for the privacy policies or the content of any third-party website. If you visit these websites, they will be governed by their own terms of use (including privacy policies).
11. Our Marketing
We may Process your preferences to receive marketing information directly from us by email and text in the following way:
- If you are a prospective member and have signed-up on our websites, or if you are an existing customer of our family member’s clubs and/or nurseries we may send you marketing communications and targeted advertising to promote our clubs and nurseries provided we have your consent to do so;
- If you are an existing member, we may also communicate with you via mobile applications that we make available via third party providers or that are otherwise used in connection with our services (e.g., FamlyApp, CoursePro and WhatsApp) – you can adjust the amount of communications received from us directly in such mobile applications.
- From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you want to continue receiving marketing information from us.
You can amend your marketing preferences at any time by contacting us via the contact details below.
12. Changes to our Privacy Notice
This notice will be reviewed periodically and as a result may be updated. All information held by us will be governed by the most recently updated notice.
13. Who to contact
If you have any questions or concerns concerning this Privacy Notice, please contact us using the relevant contact details below.
