What we know about you, and why.
Brightpath Language School is the data controller for the personal information described on this page. We collect and keep as little as we can, we do not sell it, we do not share it for marketing, and we have never bought a list of anybody's details from anyone.
This notice is written to be read. If any of it is unclear, ring the office and somebody will explain it in ordinary words rather than sending you back to the paragraph.
Six things, if you read nothing else
This website sets no cookies
None at all: not necessary ones, not preference ones, not analytics ones. There is no tracking pixel, no advertising tag and nothing embedded from another site. Every page loads from our own server and makes no request anywhere else.
This is why you have not been shown a consent banner. There is nothing to consent to, and a banner on a site that sets no cookies would be theatre. You can check the whole thing in your browser's network panel.
We do not store card numbers
Card payments are handled by our payment provider. We see the amount, the date, the result and the last four digits, which is what appears on our reconciliation and on your receipt. The full number never reaches us.
Nothing is written on paper at reception either. If you pay by card in person, the terminal talks to the provider directly and we see the same four digits everybody else does. We will never ask you to read a card number aloud over the telephone or to send one by email, and if anybody claiming to be us does, it is not us.
Recordings stay in the group
Online lessons are recorded and are visible only to the eight learners in that group and their teacher, for the term plus six weeks, after which they delete automatically on a fixed date printed in your enrolment email.
Breakout rooms are never recorded at all. Nothing is ever used in marketing, shown to another group or kept beyond the term. If you would rather not appear, tell your teacher in week one and it is arranged quietly.
1. What we collect, and when
We collect information at four points: when you first enquire, when you take a placement, when you enrol and pay, and while you are studying with us. Nothing is gathered in the background, and nothing is inferred about you from your behaviour on this website, because this website does not observe your behaviour.
1.1 When you enquire
Whatever you choose to put in an email, a telephone call or the enquiry form on the contact page: typically your name, your email address, the language you are interested in and a sentence about your level. If you telephone, we write your name, number and the language on a note pad; that note is transferred to the enquiry list and then thrown away.
Enquiries that do not become enrolments are deleted after twelve months. We do not add enquirers to any mailing list, and we do not telephone people who have not asked us to.
1.2 When you take a placement
The score from the written placement test, if you took one, and a short note of the teacher's recommendation — usually one line, along the lines of “solid A2, weak on past tenses, would suit Tuesday”. The paper test itself is destroyed once the score has been recorded, normally the same evening. If your placement conversation happened by telephone or by video it is not recorded, and no note is kept beyond that single line.
1.3 When you enrol
- Contact details: name, email address, telephone number, and a postal address only if you want an invoice or a coursebook sent to you.
- Course details: which course, which group, which term, and the level you were placed at.
- Payment records: amount, date, method, and whether an instalment plan applies. For card payments, the last four digits and the transaction reference; for bank transfers, the reference on the payment.
- Employer details, if your employer is paying: the organisation name, the billing address, a purchase order reference and the name of the person who approved it.
- Access requirements: only what you choose to tell us, and only so that we can make the arrangements you have asked for. This is described separately in section 4 because it needs to be.
1.4 While you are studying
- Attendance: a simple present-or-absent register kept by the teacher, so that we know when to offer a catch-up.
- Written work you hand in, and the teacher's comments on it. Returned to you and not retained by us.
- The end-of-term feedback report your teacher writes, and the certificate of attendance.
- Lesson recordings, if you are in an online group. See section 6.
- Correspondence: emails you send us and our replies, kept for as long as the enrolment record lasts.
What we deliberately do not collect
Date of birth, beyond confirming that you are eighteen. Gender. Nationality. Immigration status. Employment details, unless your employer is paying. Income, even for the half-price places, where a simple declaration is enough and we ask for no documents at all. Nothing whatever about your health unless you volunteer it as an access requirement.
2. Why we hold it, and on what basis
Every piece of information above exists for a stated purpose, and each purpose rests on one of three lawful bases. There is no fourth category of “because it might be useful one day”.
| What we do with it | Which information | Lawful basis |
|---|---|---|
| Reply to your enquiry | Name, email, what you asked | Legitimate interest |
| Place you at the right level | Placement score and teacher's note | Steps prior to a contract |
| Enrol you and hold your place | Contact and course details | Performance of a contract |
| Take payment and issue receipts | Payment records | Performance of a contract |
| Keep accounting records | Invoices and payment records | Legal obligation |
| Contact you about your course | Email and telephone | Performance of a contract |
| Make access arrangements | What you told us in section 4 | Explicit consent |
| Record online lessons | Video and audio of the main room | Legitimate interest, with an opt-out |
| Send the termly course list | Name and email | Consent |
| Investigate a complaint | Whatever is relevant to it | Legitimate interest |
Where we rely on legitimate interest, the interest is running a small school competently: replying to people who write to us, teaching a class in a way that works, and keeping enough of a record to place you correctly if you come back in two years. We have considered in each case whether the same thing could be done with less information, and in two cases it could, which is why we stopped asking for a postal address at enrolment in 2019 and stopped keeping placement papers in 2021.
3. Retention: when things get deleted
Deletion is done twice a year, in the weeks after the summer block and after the winter term, by the office manager working through the list below. It is a dull afternoon's work and it is the reason our files stay small.
| What | Kept for | Why that long |
|---|---|---|
| Financial records: invoices, payments, refunds | 6 full financial years | Because we are legally required to keep them. This is the one category we cannot delete on request, and it is why a deletion request removes your contact record and correspondence but leaves an invoice with your name on it sitting in the accounts. When you ask us to delete, we tell you exactly what had to remain and when it will go. |
| Online lesson recordings | The term plus 6 weeks | Automatic deletion on a fixed date, printed in your enrolment email so that you know in advance when it will happen. Nothing is archived, nothing is carried into the next term and there is no backup copy that outlives the library. If you enrol again you get a fresh library rather than an accumulating one, partly for storage and mostly because the people in the old recordings have moved on. |
4. Access requirements and anything sensitive
Some learners tell us something about a disability, a health condition or a learning difference so that we can make the classroom work. Dyslexia, hearing loss, a condition that means you need a ground-floor room, an anxiety that makes being called on unexpectedly unbearable — that sort of thing. In data protection terms some of this is special category information, and we treat it accordingly.
How we handle it
- You choose to tell us. Nothing on our enrolment form asks about health, and nobody is required to disclose anything in order to take a course.
- We record the arrangement, not the diagnosis. The file says “ground-floor room, cream handouts, no reading aloud”. It does not need to say why, and usually it does not.
- Only the people who need it see it. Your teacher and the office manager. Not the rest of the teaching team, not other learners, and not a cover teacher unless the arrangement affects the lesson they are covering.
- It is never mentioned in the room. Arrangements are made quietly before the term starts, so that nothing about the first session announces them to anybody.
- You can withdraw it at any moment and it disappears from the file the same day, without a conversation about whether you are sure.
We do not ask for medical evidence, letters, assessments or documents of any kind. If you say a room is too cold or a font is too small, that is sufficient. The half-price and hardship places work the same way: a simple declaration, no proof, and no file note beyond the fee that was actually charged.
5. Who else sees any of this
A short list, and it is the whole list. Each of the organisations below processes information on our behalf under a written agreement, may only use it for the purpose we have specified, and may not use it for their own ends.
Your teacher
Sees your name, your level, your group, the attendance register and any access arrangements that affect the lesson. Does not see what you paid, how you paid it, or whether you are on a half-price place.
Teachers are told about hardship places only in the rare case where the arrangement affects the teaching itself, which in practice means almost never. A cover teacher sees the register and nothing else unless there is an access arrangement they need to honour.
Our accountant
A local firm who prepare our annual accounts and see the payment ledger, which includes names against amounts. They are bound by their own professional confidentiality as well as by our written agreement with them.
They do not see placement notes, access arrangements, attendance registers, correspondence or anything at all to do with teaching. Their access is to the accounting system and stops there.
Our video platform
Carries the live online lessons and stores the recordings for the term plus six weeks. It sees the display name you type when you join, the video and audio of the session, and technical connection data such as your bandwidth and whether the picture dropped.
Recordings are stored encrypted and are deleted on the schedule in section 3. The platform does not use any of it to train anything, advertise anything or build a profile of you.
Nobody else
No advertisers, no data brokers, no other schools, no publishers, no “partners” of any description. There is no analytics company with a view of this website and no agency with a copy of our learner list.
We would disclose something if we were legally required to — a court order, for example — and in seventeen years we never have been. If it ever happened we would tell the person affected, unless we were forbidden to.
Transfers outside the UK
Our email and video providers store data in the United Kingdom and the European Economic Area. Our payment provider may process some transaction data in other countries under the standard contractual safeguards that apply to such transfers. We do not otherwise send personal information abroad, and we do not use any service that would require us to.
6. Lesson recordings and online classes
If you are enrolled in one of our online groups, each ninety-minute session is recorded and placed in a lesson library that you and the seven other learners in your group can watch during the term. This section sets out exactly what that means, because it is the one part of what we do that puts a camera on somebody. The practical side — playback quality, how much data it uses, downloads — is on the online classes page.
6.1 What is recorded
- The main room only: the teacher, the shared board and handouts, and the whole-group discussion, including the video and audio of everybody whose camera is on.
- The text chat from the main room, saved alongside the video because it usually contains spellings the teacher typed out.
6.2 What is not recorded
- Breakout rooms are never recorded. Pair and small-group work is where people are most willing to be wrong out loud, and a camera there would spoil the most valuable twenty-five minutes of the session.
- The five-minute break, when the recording is stopped and restarted.
- The ten minutes after the lesson ends, when the room stays open for private questions.
- Private messages between two people in the chat.
- Anything at all in the classes in the building, which are not recorded under any circumstances, with one narrow exception described in 6.5.
6.3 Who can see a recording, and for how long
The learners enrolled in that specific group, and the teacher who taught it. Not other groups, not other teachers, not the office, not anybody outside the school. Recordings are not public, are not indexed anywhere, cannot be forwarded to somebody who is not in the group, and are never used in marketing, on this website, in a taster session or as an example of anything.
They last for the whole of the term and six weeks afterwards, then delete automatically on a fixed date that is printed in your enrolment email. Nothing is archived and there is no backup that outlives the library.
6.4 If you would rather not appear
Tell your teacher in week one, by email or in the ten minutes after a session, and it is arranged quietly. In practice this means the teacher keeps you off the main-room camera during the recorded portions, or pins the shared board so that the gallery is not captured. Nobody else in the group is told, you keep full access to the library yourself, and nobody has ever been asked to justify the request.
6.5 The one exception in the building
The English speaking course records two short spoken tasks per learner, in week one and week nine, so that you can hear the difference between them. These are a few minutes long, are reviewed privately with your teacher, are never played to the group, and are deleted at the end of the term. If you would rather not be recorded, the same task is done as a private conversation and nothing is captured at all. This is stated in the course description and again by the teacher on the first evening.
Watching yourself, and other people
Rewatching a lesson you were in is one of the most useful things the library is for. What it is not for is anything outside your own study: recordings must not be copied, re-uploaded, shared outside the group or shown to anybody who was not in the room. It is in the terms you agree to at enrolment, and it is the only rule about the library that we would take seriously enough to remove somebody from a course over.
7. What you can ask us to do
Write to the office, by email or on paper, and say what you want. There is no form, no identity-verification ordeal and no charge. We respond within one calendar month and in practice usually within a week, because the files are small.
Withdraw consent
For the mailing list, click the unsubscribe link in any email or simply tell reception. For access arrangements, tell your teacher or the office and the note is removed the same day.
Withdrawing consent never affects your place on a course, your fee, or how you are treated in the room, and nobody will ask you to reconsider or send you a message asking whether you are quite sure. It also works in the other direction: if you unsubscribe and later want the termly course list again, just say so.
8. This website
This site is a small number of static pages served from our own hosting. There is no content management system, no login, no shopping basket and no account of any kind.
8.1 Cookies and third-party requests
There are no cookies of any category, and there are no requests to anybody else's server: no fonts loaded from elsewhere, no scripts from a content delivery network, no embedded maps, no social media buttons, no video players, no tracking pixels and no advertising tags. Every page is self-contained, and the illustrations are drawn in the page itself rather than fetched as images. If you open your browser's network panel you will see requests for the pages you clicked on and nothing else at all.
8.2 The enquiry form
The form on the contact page asks for three things: your name, your email address and your message. It does not ask for a telephone number, a postcode, a date of birth or a marketing preference, and there are no hidden fields. If we need something else in order to answer you, we will ask in the reply. You are welcome to use plain email instead, and about two-thirds of people do.
8.3 Server logs
Our web server keeps an ordinary access log: the time of the request, the page requested, the response code, the browser's user-agent string and a truncated network address. It is used to see whether the site is up and to notice a broken link. It is not combined with any other information, is never used to identify an individual, and is deleted after fourteen days.
9. Practical things people ask about
Is there CCTV?
One camera, covering the yard and the car park entrance at the back of the building, installed in 2019 after three bicycles were taken in a fortnight. It does not cover any classroom, the corridor, reception or the entrance hall.
Footage is overwritten after fourteen days. It has been looked at four times in seven years, each time about a bicycle, and on two of those occasions it turned out to have been raining too hard to see anything useful.
Registers and the noticeboard
The board in the entrance hall lists groups, rooms and teachers. It does not list learners. Class registers are held by the teacher and are not left in the room between sessions or pinned up anywhere.
If you would rather your name were not read out at the start of a lesson, tell your teacher and they will take the register by eye instead. Two or three people ask for this every term and nobody in the room notices.
10. Contacting us about any of this
We are a school of thirteen people and we are not required to appoint a data protection officer, so there is no such post. Questions, requests and complaints about personal information all go to the office manager, who handles them personally.
- By post
- The Office Manager
Brightpath Language School
Second Floor, The Old Print Works
Cobbler's Row
Riverbourne RV2 8QT - By email
- hello@brightpath-language.example.com — put “privacy” in the subject line and it is routed straight through
- By telephone
- 01632 960 118, Mon–Thu 16:00–20:30 and Sat 09:00–13:30
- Response time
- Within one calendar month, and usually within one week
- If you are not satisfied
- You may complain to the supervisory authority for data protection, and you do not need our permission or our agreement to do so
11. Changes to this notice
We review this page once a year and whenever we change something that affects it. When we make a change that matters — a new processor, a different retention period, a new category of information — we say so in the weekly summary email to current learners rather than quietly updating a date at the bottom of a page.
The last review was in June 2026, when section 6 was expanded to cover the lesson library and its six-week retention period. Before that: February 2025, adding the video platform to section 5; September 2023, reducing retention of unsuccessful enquiries from three years to twelve months; April 2021, ending retention of paper placement tests; and January 2019, when we stopped asking for a postal address at enrolment.
This notice covers our own website and our own records. The terms of enrolment on the home page cover the contractual side of taking a course, and the two are meant to be read together.