Purpose of this document
At Travel Counsellors we respect the privacy of individuals and are committed to protecting the privacy and security of your personal information. In this privacy notice, we explain how we collect and use information about you, or the individuals that work with you, in connection with your journey to becoming a travel counsellor (a “TC”).
Travel Counsellors Limited (“Travel Counsellors”, “we”, “us”, “our”) is a “controller” under data protection legislation. This means that we are responsible for deciding how we hold and use personal information about you.
If you have any questions about this notice, or our use of personal data, please contact the data protection team at DPO@travelcounsellors.com.
Data protection principles
We comply with data protection law, which says that the personal information that we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely
Personal information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include any data where the person’s identity has been removed (anonymous data). Some types of more sensitive personal data require a higher level of protection such as information about an individual’s health or criminal convictions and we call this special category data.
We need to collect and process certain information about you in order for us to discuss with you and assess whether a Travel Counsellors franchise is right for you.
You are not required to provide personal information to us. However, we will need to collect certain personal information about you, or individuals at your business, to progress your application for a Travel Counsellors franchise. If you express an interest in applying for a Travel Counsellors franchise, the information that we may collect from you, or about individuals who work with you, includes:
- Your Identity Data including name, marital status, title, date of birth and gender. Where you progress to meeting with our franchise sales team (either in person or remotely), this will also include any ID documentation such as passport or driving licence and proof of address such as a copy utility bill and any username or similar identifier.
- Your Contact Data including your postal address and previous addresses, telephone numbers and email address. Where you become a TC, this may also include the details of any emergency contact, next of kin, spouse, dependent or TC buddy and any contact details where you provide these to us during our business relationship.
- Details of your previous experience whether in employment or as a business owner, including details about your skills, qualifications and evidence of qualifications, employment or business ownership experience, start and end dates of your previous experience, reasons for leaving and copies of relevant previous employment contracts (Experience Data).
- Records of our interviews with you and any communications or interactions between us, including your progression through the franchise application process, such as any correspondence and your responses on our application forms and business plan assessment and any other correspondence between us by post, email, phone, social media, instant message and chat bot (Correspondence Data).
- Results of your digital skills survey, personality evaluation assessment, information that we may require from you to carry out background checks including DBS (Disclosure and Barring System), credit and director disqualification checks and the results of those checks (Background Data).
- CCTV footage where you meet with us at our premises.
Special Category Personal Data and Criminal Offence Data
- We may also collect, store and use the following more sensitive types of personal information:
- Information you voluntarily choose to disclose to us, including in respect of disabilities, marriage/civil partnership status, sex, gender, ethnic origin, sexual orientation, health and religion or belief.
- Information that you disclose to us which relates to your health (for example, if you have access requirements when visiting our premises or attending one of our events) (health data).
- Information that you disclose to us which relates to a religious or philosophical belief (for example, dietary requirements where you are attending one of our events) (religious belief data).
- Information contained in your ID documentation which may reveal your racial or ethnic origin, for example your nationality or photo (racial or ethnic origin data).
- Information about criminal convictions and offences, including details of any DBS (Disclosure and Barring Service) checks (criminal offence data).
Collection of personal data
How is your personal data collected
We may collect personal data from you directly in a variety of ways throughout the franchise application process and during the term of your relationship with us.
In addition to information you provide (directly or through the use of our systems), we may collect information about you from third parties such as TC referrers, your former employer(s) or referees (references only) and service providers (including our personality evaluation provider and the Criminal Records Bureau in connection with DBS checks).
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the course of our relationship.
How will we use information about you
We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal data for the following purposes:
- Where we need to in connection with the contract we are contemplating entering into with you (the franchise agreement).
- 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.
We may also use your personal information based on your consent, although this will be in limited circumstances only, for example, where you would like us to keep in touch by sending you marketing information from time to time or in order to process more sensitive data.
We use the information that we collect about you to discuss with you franchise opportunities at Travel Counsellors and to assess your suitability for a Travel Counsellors franchise. It is necessary for us to process information about you in this context in order to take steps towards potentially entering into a franchise agreement with you.
|Purpose/Activity||Type of data||Lawful basis for processing|
|The administration of the franchise sales process, to assess your suitability for
a franchise and set you up as a TC.
(a) Identity (including racial or ethnic origin data, if applicable)
(e) Background (including criminal offence data where applicable)
(a) Performance of a contract with you
(b) Necessary for a legitimate interest (assessing your suitability as a Travel Counsellors franchisee and to protect our business)
(c) Consent from you
The administration of an event organised by us, whether on our premises or on third party premises.
(e) Health (if relevant)
(f) Religious belief (if relevant)
(a) Performance of contract with you
(b) Necessary for our legitimate interests (to manage and organise events, to develop our business relationships and grow our business, to protect our staff and property, and to the security of our business)
(c) Consent from you
Where you attend at our premises, to enable access to the building, parking and to ensure the health and safety of visitors.
(d) Health (if relevant)
(e) Religious belief (if relevant)
(a) Performance of contract with you
(b) Necessary for our legitimate interests (protection of staff and property, and security of our business)
(c) Consent from you
To keep in touch with you from time to time and keep you informed about our franchise opportunities.
|(a) Contact||(a) Consent from you|
We may also need to process your personal information for the purposes of responding to and defending legal claims.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Special Category Personal Data
We will only process special category personal data in limited circumstances. The situations in which we will process particularly sensitive personal information are listed below:
- In order to check and verify your identity, we will process the details of your ID document which may reveal your racial or ethnic origin.
- In order to assist with any access issues where you attend an event or our premises, we will process information relating to your health where you provide these to us. You may, at your discretion, also provide us with health data in connection with your application for a Travel Counsellors franchise, for example if you have had a period away from work.
- We may also hold information relating to criminal convictions. Although this data is not special category data, it is considered sensitive under data protection law. We may collect information about criminal convictions as part of our franchise sales process, for example by carrying out credit checks or a DBS (Disclosure and Barring Service) check. We rely on your consent in order to carry out these checks.
Note that where we do require your consent to allow us to process particularly sensitive data, and you do not provide that consent, then we may not be able to progress our discussions with you.
If you have any questions about any of the reasons for which we process your personal information, please contact the data protection team at DPO@travelcounsellors.com.
Change of Purpose
We may use your personal information for other purposes provided that they are reasonable, proportionate and compatible with the purposes set out in this notice. If we need to use personal information about you in any ways that are not set out in this policy, we will notify you first (this may be in relation to a specific matter, or we may notify you by circulating an updated version of this notice).
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who we share your personal information with
We will share your personal information with colleagues at Travel Counsellors, which may include members of our group and our shareholders, where this is necessary or required for the purposes for which we process your information (as set out in this notice).
We will also share your personal information with third parties where required by law, where it is necessary in connection with the franchise application and assessment process or where we have another legitimate interest in doing so, for the purposes set out in this notice. For example:
- We will share your personal information with third parties where required by law, for example the ICO or other regulators for compliance purposes.
- We will share your personal information with service providers who support our systems and business in the provision of our services, for example software and other IT service providers in connection with software applications and equipment that we use in connection with our franchise sales (including, for example, our email and other communication systems).
- We may also share your personal information with a third party in the context of a possible sale or restructuring of the business.
We may share your personal information with other third parties in exceptional circumstances but only where it is proportionate and lawful to do so. For example, we may share your personal information with other entities in our group as part of our reporting activities, in the context of a business reorganisation or restructure, for system maintenance or reporting, or where a group company provides us with administrative support.
Transferring information outside the UK
We may transfer the personal information we collect about you outside of the UK in order to fulfil the purposes set out in this notice. Where we do so, we will ensure that your personal information receives an adequate level of protection and will put in place appropriate measures to ensure that your personal information is treated in a way that is consistent with, and which respects, UK law on data protection.
We have put in place appropriate security measures to protect the security of your information and to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Details of the measures we have in place are available from the data protection team by contacting DPO@travelcounsellors.com.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. In most cases, this will be a period of 2 years from the date of your last interaction with us, after which all personal information we hold about you will be erased or destroyed.
If you enter into a franchise agreement with us, the information we hold about you will be retained throughout your relationship with us and we will provide you with a separate TC Privacy Notice which explains how we process your personal data as a TC.
You have a number of rights in respect of your personal data. If you would like any further information or to exercise any of your rights, please contact DPO@travelcounsellors.com.
- You have the right to be informed about our use of your personal data.
- You have the right to access and receive a copy of the personal data that we hold about you.
- You have the right to ask us to rectify any incorrect or incomplete data we hold about you.
- In certain circumstances, you may have the right to ask us to erase data we hold about you.
- You may have the right to ask us to transfer your data to you or a third party in a common electronic format.
- You have the right to object to our use of your data for direct marketing purposes, or in reliance on our legitimate interests. Our legitimate interests are explained in this notice.
- In certain circumstances, you may have the right to ask us to restrict how we use your data.
- You have the right not to be subject to significant decisions made based purely on automated decision-making
Fees and Charges
You will not have to pay a fee to access your personal information (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 these 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 information 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 information 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 DPO@travelcounsellors.com or the franchise sales team or, where you have given your consent to receiving marketing communications from us, an unsubscribe link can be found in marketing emails we send you. 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.
If you have any questions about this privacy notice or how we handle your personal information, please contact the data protection team at DPO@travelcounsellors.com. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) with respect to data protection issues. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact the data protection team in the first instance.
We reserve the right to update this privacy notice at any time, please visit our website at https://people.travelcounsellors.com/gb/become-a-travel-counsellor/ to access the latest version.