This Policy sets out the basis on which the American Institute for Foreign Study (UK) Ltd (AIFS) Registered in England No 939488 and its Camp America programme (we / us) process and share personal data we receive. Camp America is a part of the AIFS Group which provides a Cultural Exchange Programme placing individuals on Programmes in the United States. In order to provide the Camp America services to you we need to collect, use and share personal information about you, and we need to be able to share your personal information with entities in the United States of America. Please read this Policy carefully (in particular in relation to our use of Sensitive Personal Data) and contact us if you have any comments, concerns or queries.
We strive to conform with UK and European Data Protection laws and as such we comply with the provisions of the Data Protection Act 1998 (“DPA”) and the BBBOnline (Better Business Bureau Online) Privacy Programme of AIFS.
In the UK, for the purposes of the DPA, the Data Controller is AIFS of 37 Queen's Gate, London, SW7 5HR. AIFS is registered on the UK Data Protection Register with number Z6393161. We will only collect, process or retain any personal information about you, or share such information with third parties, where it is necessary for us to do so in order to provide our services to you, where we have your consent or where we have any other legal basis to do so.
We conform to the requirements of the English & Scottish Criminal Record Bureau and once information is no longer required by us for the purposes of placing people on J1 programmes in the United States, or informing you of other AIFS programmes, any information that we do hold either electronically or on paper is destroyed in secure circumstances.
Our privacy policies will be over ridden when the safety and welfare of the children are at stake or if we are required to do so by law. We give the highest possible priority to the safety and welfare of children and will in all circumstances cooperate with police and government authorities in combating any and every attempt to harm or pursue sexual relations with minors.
1. Information we may collect about you
If you apply to us to be placed on a J1 or other AIFS programme (Programme), we may collect the following information about you at various stages throughout the application and placement process, and during and after the time you are registered on such Programme, which we will use and retain for the purposes set out in this Policy:
- The information contained in your application form when applying to be placed on a Programme, such as your name, address, email address, telephone number, date of birth, gender, national insurance or social security number, photograph, nationality and country of residence, racial or ethnic origin*,next of kin details and your signature;
- The information contained in your Disclosure and Barring Services (DBS) form, medical check documentation, embassy and immigration documentation and insurance documentation or any information which is derived from third parties to which this documentation is submitted, and which may include details of your medical history and condition (including any disabilities)*, the commission or alleged commission by you of any offence* and your immigration status;
- Information received from third parties in relation to your application and continued placement on and participation in a Programme, including law enforcement agencies , governmental authorities, insurance companies, embassies, child protection authorities and referees;
- Copies of your passport, driving licence and/or other identity documents;
- Photographs and videos taken of you and uploaded to the Camp America website or taken at Camp America events or on camp to be used for marketing purposes;
- Any comments made by you about the Programme for publication on the Camp America website or for any other marketing purposes;
- Correspondence you have with us;
- Bank and other financial details;
- Funding and fee related information;
- Complaints that you make, or relating to complaints that others make that involve you;
- Information that enables us to keep in touch with you as an alumni of our Programme or otherwise run alumni communications (you would have the right to opt out of these);
- Other information that we may be given or provided by you or by third parties in connection with your involvement in a Programme;
- Other information that you supply to us for the purpose of organising travel or training or for the sale of merchandise.
*This is “sensitive” personal data, as defined in the DPA. Please see the section on Sensitive Personal Data below for information on how we treat this data. We also collect and use information collected about you through using cookies. Please see our separate Cookies policy for information on this.
To enable us to comply with the DPA and keep accurate information about you, you agree to only provide us with accurate and up to date information and to notify us of any changes to your contact details and circumstances including, but not limited to, any changes to your Programme, particularly when you are at camp and/or if you intend to leave the Programme.
2. How do we use personal information?
We will use your personal information in order to provide our products and services to you. We will only share your information with third parties in accordance with this Policy and any personal information collected about you will be stored securely. We respect the principle under the DPA that personal data should not be kept longer than is necessary for the purpose for which it is kept. We therefore take measures to ensure that your personal data is destroyed or erased from our systems when it is no longer required.
We may use the information we hold about you for some or all of the following purposes:
- Provide the Camp America and AIFS products and services to you;
- Correspondence with you in connection with your application and/or your placement on a Programme, whilst you are on placement and after you have left;
- Correspondence with you about other goods and services of AIFS that may be of interest to you;
- To notify you of any changes to our products and services;
- Performing background checks on you, including but not limited to DBS, medical and immigration checks;
- Providing any necessary training for your placement;
- Booking and securing of services in conjunction with a Programme, including but not limited to travel, accommodation and insurance;
- Applying for visas and immigration papers on your behalf;
- Providing you with information for administration, health and safety, welfare and security reasons;
- Payment of costs, fees and expenses associated with your placement on a Programme;
- monitoring of your performance whilst placed on a Programme;
- Dealing with any complaints, issues and/or disciplinary matters;
- Arranging your repatriation;
- Confirming and/or obtaining references on your behalf;
- Monitoring and promoting equality of opportunities;
- Marketing purposes;
- Crime prevention and prosecution of offenders;
- Complying with Home Office checks;
- Co-operation with law enforcement authorities;
- Running an alumni programme;
- Sale of merchandise and travel services;
3. Third Parties
Where we engage third party contractors to perform services for us, we may need to disclose your personal information to those third party contractors in order to facilitate the provision of our services to you. Under these circumstances, we take steps in compliance with the DPA to ensure that those third party contractors who process personal data on our behalf do so in a way which safeguards the information, ensures that it is used for the purposes for which it was supplied and is processed in accordance with the DPA. .
We will not disclose your personal information to any third parties unless we have your consent or we have a legal basis to do so (for example to progress our legitimate interests or to fulfil a contract we have with you) or disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
We may share information about you with the following parties:
- Third parties for confirming the accuracy of the information you provide to us as part of your application and during your placement on a Programme;
- Our employees, agents or contractors who need your information for administrative purposes associated with securing and managing your placement on a Programme;
- Third parties associated with performing background checks, including but not limited to the DBS, medical practitioners and immigration authorities;
- Third parties and agents for the booking and securing of services with third party suppliers in conjunction with your attendance on a Programme, including but not limited to travel, accommodation and insurance;
- Governmental departments associated with accrediting us to provide the products and services to you;
- The Home Office, embassies and other third parties concerning the application and granting of visas;
- Camps with which we place applicants on Programmes (including their management and personnel);
- Financial and payment providers to facilitate the payment of costs and fees to suppliers, applicants and other third parties and the receipt of monies from applicants and other third parties;
- Third parties engaged to monitor and report on your performance whilst placed on a Programme by us and to deal with any complaints, issues or disciplinary matters;
- Referees provided by you;
- your next of kin should you be hospitalised, taken ill or for any other issue of significant concern whilst you are on a Programme;
- third parties if it is necessary to protect the vital interests of you or others;
- third parties if we are legally required to do so (for example if you commit a criminal offence or are a witness to any commission of an offence). We may need to provide information to the Home Office, governmental authorities, law enforcement agencies, the police and child protection agencies and in some circumstances we may be required to disclose information relating to you in response to third party requests made to us under the DPA);
- our insurers and legal and professional advisors;
4. Sensitive Personal Data
Some of your personal data processed by us may be classified as "sensitive" under the DPA. This includes your racial or ethnic origin, any disabilities and any associated medical conditions that you have chosen to declare to us. It also includes any criminal convictions you may hold either before or during the time you are placed on a Programme, and the commission or alleged commission by you of any offences during the time you are placed on a Programme.
We may also collect sensitive information from you in relation to any applications you submit for a Programme, any immigration, DBS or medical checks required as part of your application, and whilst on a Programme, and for any complaints or disciplinary cases. Sensitive personal information about you may also be provided to us in some circumstances by others (for example, camp directors or personnel who may be concerned about you).
If you disclose sensitive personal information to us, we will use that information for the purpose(s) given to you at the time the information was collected. We will also collect and use your sensitive personal information where there is a legal basis to do so without your consent (such as for protection of your or another’s vital interests or to comply with court or law enforcement orders compelling disclosure)).
- use information you provide to us relating to a medical condition, disability or special needs you may have for the purposes of evaluating what suitable support may be available to you and may be required, or whether you may be required to obtain additional insurance to participate in a Programme, and to share this information with our employees, camp employees and third parties who are directly involved in the application process or the provision of our services to you.
- use information relating to any criminal conviction you may have for the purposes of evaluating your admission to a Programme, or for evaluating whether to allow you to continue on a Programme, and to share this information with camp employees and third parties for such purposes.
We will only share your sensitive personal data with other third parties without your consent if we have a legal basis to do so.
Other disclosures of sensitive personal data without your consent will be rare and include circumstances where it is vital to protect the interests of you or others (for example, where you or another person is perceived to be at significant risk, particularly in the case of children), it is necessary for the prevention of fraud or the exercise of legal rights or if we are under a legal obligation.
5. On-line application
On-line applications for some of our Programmes may request personal and financial information. Required fields are indicated and acceptance to a Programme will depend on this information. We have a secure server to handle credit card information and have implemented appropriate physical, electronic and managerial security procedures in order to protect personal information from loss, misuse, alteration or destruction.
6. Security of information
Personal information collected by us and our websites is stored in secure operating environments that are not available to the public. We will protect your personal information no matter where we process or store your data.
7. Trans-Border Data flows
The information that we collect from you may be transferred to, and stored at, a destination both inside and outside the European Economic Area ("EEA"), including the United States of America. This will include the transfer of data between Camp America and AIFS and other overseas operations and relevant entities.
8. Policy Statement On the Recruitment of Ex-offenders
- As an organisation using the DBS and Access NI service to assess applicants' suitability for positions of trust, AIFS complies fully with the DBS Code of Practice and undertakes to treat all applicants for positions fairly. It undertakes not to discriminate unfairly against any subject of a Disclosure on the basis of conviction or other information revealed.
- AIFS is committed to the fair treatment of its staff, potential staff or users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical/mental disability or offending background.
- We have a written policy on the recruitment of ex-offenders. Please see below.
- We actively promote equality of opportunity for all with the right mix of talent, skills and potential and welcome applications from a wide range of candidates, including those with criminal records. We select all candidates for interview based on their skills, qualifications and experience.
- As Camp America meets the requirements in respect of exempted questions under the Rehabilitation of Offenders Act 1974 all applicants who are offered employment will be subject to an enhanced criminal record check before the appointment is confirmed. This will include details for cautions, reprimands or final warnings, as well as convictions
- Where a Disclosure is to form part of the recruitment process, we encourage all applicants called for interview to provide details of their criminal record at an early stage in the application process. We request that this information is sent under separate, confidential cover, to a designated person within AIFS and we guarantee that this information is only seen by those who need to see it as part of the recruitment process.
- We ensure that all those in AIFS who are involved in the recruitment process have been suitably trained to identify and assess the relevance and circumstances of offences. We also ensure that they have received appropriate guidance and training in the relevant legislation relating to the employment of ex-offenders, e.g. the Rehabilitation of Offenders Act 1974.
- At interview, or in a separate discussion, we ensure that an open and measured discussion takes place on the subject of any offences or other matter that might be relevant to the position. Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an offer of employment.
- We make every subject of a DBS and Access NI Disclosure aware of the existence of the DBS and Access NI Code of Practice and make a copy available on request.
- We undertake to discuss any matter revealed in a Disclosure with the person seeking the position before withdrawing a conditional offer of employment.
Having a criminal record will not necessarily bar you from working with us. This will depend on the nature of the position and the circumstances and background of your offences.
9. Applicants with Criminal Records - Our Recruitment Policy
If a Police Check reveals something about a person’s history that is of concern, Camp America staff in our recruitment offices will make a decision about whether or not to accept that person as a programme participant.
We will assess such information taking into account:
- The nature of the offence and its level of seriousness
- The relevance of the offence to the position applied for
- The age of the person at the time of the offence
- The age of the victim involved and whether the offence was violent or sexual in nature
- The length of time since the offence took place
- Whether the applicant has a pattern of offending behaviour
- The possibility of the participant successfully securing a visa
When the offence detailed is serious in nature the applicant will not be considered suitable for the programme.
If the revealed information had not been detailed on the participants’ initial online application form the Recruitment Office staff will bring this to the attention of U.S Account Representatives.
10. Changes to our Policy
From time to time, it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time and should this occur, the amendment would be posted on our website. Please check back frequently to see any updates or changes to this Policy.
11. Access to your information
The DPA gives you the right to access information held about you. Your right of access can be exercised in accordance with the DPA. Any access request will be subject to a fee of GBP £10 to meet our costs in providing you with details of the information we hold about you.
12. Status of this Policy
For some of the uses of your information described above there is a basis under the DPA for us to use the information without your consent. Where this is the case, this notice fulfils our duty to process information fairly, which includes giving you appropriate notice and explanation of the way in which your information will be used.
In particular, where your consent is required, you agree that the information we collect from you may be transferred to, and stored at, a destination outside the EEA including the United States of America and to the use of your Sensitive Personal Data as described above.
As explained elsewhere in the Policy, you can request access to any personal information held by us and ask for more information about the basis on which we collect and use that information by writing to our Data Protection Officer (see contact details below).
13. Contacting us