ACG Penguins School ELS

197 Whitford Road, Howick
09 537 4970

Penguins School of Early Learning is part of Inspired Education Holdings Limited, which  is a company registered in Europe, United Kingdom, company number 09268120, with registered address as Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom..

Inspired operate numerous affiliated schools globally via its regional offices in Europe, Africa, Middle East, Asia-Pacific and Latin America.


This policy is created according to the Privacy Act 1993 and it aims to give you information on how we, Penguins School of Early Learning, collect and process your personal data.

Our Privacy Officer can be contacted by email at the address if you have any queries regarding the processing of your personal data.


We process personal information from our students and their families and / or competent persons and also from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about Penguins School of Early Learning within the systems controlled by the school.

The personal information processed is mainly the following:

  • Names, addresses, telephone numbers, e-mail addresses and other contact details;
  • Family details;
  • Safeguarding information (such as court orders and professional involvement)
  • Education and employment data;
  • Images, audio and video recordings, including CCTV footage (video images);
  • Financial information;
  • Educational centres previously attended.

Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:

  • Information about health status or provision of health care linked to a specific individual;
  • Behavioural information;
  • Special educational needs
  • Criminal records linked to a specific individual;
  • Biometric information;
  • Ethnicity;
  • Religion;
  • Nationality and location.

Penguins School of Early Learning collects information in several ways, including:

  • Personally and over the phone;
  • Through our webpage, including information received through the following sections: Enrolment (apply online), contact form, Query form (send a message),  Book a Tour,  Career Opportunities (recruitment), ACG’s Web portal and subscription to our newsletters or communications;
  • From email and hand delivery paper documentation: including job applications, emails, invoices, letters, consent forms;
  • Through online tools: such as apps, educational platforms and other software used by our staff;
  • Through any CCTV cameras located at our premises or sites;
  • Through third parties, such as referees, professionals or authorities working with the individual;

We have set out below, in tabular form, the ways in which we may use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests. Please note that we may process your data for more than one lawful ground depending on the circumstances and the specific purpose. Please contact us if you would like more detail about the specific legal ground which we are relying on to process your personal data, where more than one ground has been identified below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
(c) Profile


(d) Financial information

Performance of a contract with you.
To provide educational services (a) Identity
(b) Contact
(c) Profile


(d) Educational records

(e) Health records

(f) Safeguarding information

(g) Family details

(h) Images, audio and video recordings, including CCTV footage (video images);

To ensure that the student meets the school’s admission criteria; To provide educational services including the support of pupil learning, monitor and report on pupil progress; To provide to the students welfare and pastoral care services; To provide to the students medical and nurse attention, catering service and school transportation, among other necessary services; To meet the educational, social, physical and emotional requirements of the student; To comply with the law regarding data sharing; To comply with legislative or administrative requirements; To administer the school’s governing body; To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about school events, etc.; To celebrate school’s achievements and to keep a record of the history of the school, Fulham School may take photographs and recorded images of students to be shared in, e.g. yearbooks, school website, etc, always based on informed consent from parents or students of legal age;
To process and fulfil your contract, including:


·         managing payments, fees and charges; and

·         managing your queries – this may include recording calls or communications with our teams.

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Performance of a contract with you.
To collect and recover money owed to us in respect of your contract. (a) Identity
(b) Contact
(c) Financial
(d) Transaction
Performance of a contract with you.
To carry out fraud assessments (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy (a) Identity
(b) Contact
(c) Profile
Performance of a contract with you.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).
To enable you to partake in one of our awards or a competition (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Performance of a contract with you to fulfil the promotion and run the awards/competition. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.
To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Profile
(d) Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To deliver relevant website content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to you).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about products or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).
CV received through our website, in the section “Career Opportunities” or by other means. It is also referred to employees (a) Identity
(b) Contact
(c) Professional  backgrounds
(d) References
Conducting the selection process, recruitment of staff, position assessment, management of human resources records, administration of payroll, pensions and sick leave, disciplinary actions, staff appraisals.




The personal information may only be shared with other companies in the group, third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way and with the same purposes as set out in this Privacy Policy.

As a school, we may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or on the basis of a specific consent given by the individual concerned.

The parties to whom we may disclose your personal data as above referred may be located in countries outside the school’s location, including countries which may offer a lower level of data protection.

In such cases, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation.

Your personal data shall be neither rented nor sold to third parties.

  1. Conservation of data

Personal information will only be retained for the period of time required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.


Under the Privacy Act 2013, you have the following rights. These rights are, however, subject to certain exemptions and limitations set out in Part 4.

You have the right to:

  • Be informed, at the time when personal information is collected, about the data processing.
  • Access the information we hold as well as to obtain a copy of the personal information considering the legal limitations and exceptions;
  • Ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
  • Obtain the rectification of your personal information providing a supplementary statement;
  • Obtain restriction of processing of your personal information when it is inaccurate, illegal, unnecessary or not verified, considering the legal  limitations and exceptions;
  • Obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another school without  hindrance from the school to which the personal data has been provided;
  • Object to processing for direct marketing purposes;
  • Withdraw consent at any time and freely to the processing of your personal information. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Therefore, individuals will be able to exercise their rights by sending a written specific request, along with a copy of their ID card, to the Privacy Officer’s email address or send their request directly to the Privacy Commissioner by using the online form provided at, to the email address:


You will have the right to withdraw your consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this “Marketing”).

You will receive marketing communications from us if you have requested information from us or purchased products (including publications) or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by contacting us at any time at

Where you opt out of receiving these marketing messages, we will stop sending you marketing messages but we will continue to process your personal data if there are legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.


The school shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.


If you are not satisfied with our response, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Privacy Officer at: or you can address your complaint to the Privacy Commissioner at as indicated above.


Penguins School of Early Learning may need to update this privacy notice periodically so we recommend that you review this information from time to time.

This version was last updated on January 2021