Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
enquiries@compassedu.co.uk  
Compass Culture and Education Ltd.  
Privacy Notice 2026  
Students • Parents • Homestays • Schools • Agents • Other Contacts  
1 ABOUT THIS NOTICE AND WHO IS RESPONSIBLE  
This Privacy Notice explains how Compass Culture and Education Ltd ("Compass", "we", "us") collects, uses, shares,  
protects and retains personal data when providing UK guardianship, homestay coordination, travel, welfare and related  
education support services. It also explains the rights of individuals whose information we handle.  
Compass Culture and Education Ltd is the data controller when it decides the purposes and means of processing personal  
data for its own services. Employees acting under Compass instructions are not separate external data processors simply  
because they access records.  
Registered address: 66 Paul Street, London EC2A 4NA, United Kingdom. Company number: 9024815.  
Privacy contact: enquiries@compassedu.co.uk | Office telephone: 020 8449 0119 | Website: www.compassedu.co.uk  
This notice covers prospective and current students (including children under 18), parents and carers, homestays, school  
contacts, agents, contractors and people who contact us. Where appropriate, separate recruitment or employment notices  
may provide further detail for staff and applicants.  
2 PERSONAL INFORMATION AND WHERE IT COMES FROM  
Depending on the services required, we may process:  
• Names, dates of birth, addresses, telephone numbers, email addresses, parental and emergency contacts, and relevant  
identity and travel information.  
• Guardianship agreements, authorisations, school and course details, term dates, attendance, welfare contacts, routine  
visits, accommodation and transport arrangements, and communications.  
• Relevant medical conditions, allergies, medication, dietary needs, disabilities or other support requirements;  
safeguarding and wellbeing information where necessary.  
• Invoices, payment and accounting records; enquiries, complaints and the steps taken to respond.  
• Appropriate staff or homestay recruitment, safer-recruitment and vetting information, subject to separate access and  
handling rules.  
• Photographs or other images only where necessary and lawful, with appropriate permission before use in publicity or  
on the website.  
Information may be provided directly by individuals, parents or carers, schools, homestays, approved agents, drivers and  
relevant service providers. We may also receive necessary information from healthcare professionals, emergency services,  
children’s social care or other safeguarding agencies. We seek only information relevant to the stated purpose.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
enquiries@compassedu.co.uk  
3 WHY WE USE INFORMATION AND LAWFUL BASES  
We use different lawful bases for different purposes; consent is not a universal basis for every guardianship activity. Where  
we rely on legitimate interests, we consider and balance the interests and rights of the people concerned, especially  
children.  
Purpose  
Typical UK GDPR Article 6 basis (as applicable)  
Responding to enquiries, assessing applications and arranging  
requested services  
Steps towards a contract with an individual; legitimate  
interests  
Contract where the individual is a contracting party;  
otherwise legitimate interests and/or applicable legal  
obligations  
Delivering guardianship, homestay support, transfers and routine  
communications  
Legitimate interests and/or applicable legal obligations; vital  
interests in urgent life-threatening situations  
Student welfare, emergency support and safeguarding referrals  
Payments, accounts and regulatory compliance  
Complaints, incidents and legal claims  
Contract, legal obligation and/or legitimate interests  
Legitimate interests and/or legal obligation  
Consent or another appropriate lawful basis, with additional  
permissions where required  
Optional publicity, marketing and student photographs  
Sensitive information: medical, disability, religion and other special-category data are processed only where necessary and an  
additional Article 9 condition is available. This may include valid explicit consent, vital interests in an emergency, or a  
safeguarding-related substantial-public-interest condition where the statutory safeguards apply. Criminal-offence or DBS  
information is subject to its own legal conditions and restricted handling. The particular conditions used must be recorded in  
Compass’s data protection documentation.  
4 SAFEGUARDING AND CHILDREN’S PRIVACY  
The safety and best interests of a child are central to our decisions. Where a concern arises, relevant information may be  
shared promptly with Compass’s Designated Safeguarding Lead (DSL), Deputy DSL, the student’s school, children’s social  
care, the police, healthcare professionals or emergency services when necessary and lawful.  
Data protection legislation does not prevent necessary safeguarding information sharing. Consent is not always required  
where another lawful basis applies; we consider whether telling a parent or another party beforehand would place the  
child at increased risk. We aim to share no more information than is necessary, record important decisions, and keep  
safeguarding records separately and securely.  
We provide age-appropriate explanations and, where practical, language assistance for students whose first language is  
not English. Students may raise privacy or safeguarding concerns directly with the relevant Compass guardian or  
designated safeguarding contacts.  
5 SHARING INFORMATION AND AEGIS INSPECTIONS  
Depending on the service and the circumstances, necessary information may be shared with:  
• Parents, legal carers and authorised representatives, where appropriate and safe.  
• Partner schools, vetted homestays, approved transport providers, emergency accommodation providers and medical  
services.  
• Local authorities, safeguarding partnerships, LADO services, police, emergency services and other statutory agencies.  
• Accountants, professional advisers, insurers, appropriate regulators and IT/cloud service providers acting under  
suitable agreements.  
• AEGIS and its inspectors in connection with accreditation, inspections or appropriate regulatory and safeguarding  
enquiries.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
enquiries@compassedu.co.uk  
AEGIS: where contact details or other personal data are proposed to be supplied for an AEGIS inspection, Compass will  
explain the purpose and seek the relevant permissions required by the applicable AEGIS standard. Information shared is  
restricted to what the inspection requires. Disclosure of safeguarding information to statutory agencies may follow a  
different lawful basis.  
We do not sell student or family personal data. A third-party cloud provider or contractor processing data for us is not the  
same as a Compass employee accessing company records.  
6 STORAGE, SECURITY AND INTERNATIONAL TRANSFERS  
Compass maintains student records in centrally managed electronic systems or cloud folders. Access is restricted to  
authorised personnel with a legitimate need. Safeguarding and sensitive medical information receive additional  
confidentiality controls. We take appropriate steps to limit unauthorised access, loss, inappropriate disclosure and other  
security risks, and review incidents under our Data Protection Policy.  
Some parents, guardians or agents are overseas. Necessary communications and any use of overseas technology providers  
may involve access to or transfers of personal data outside the United Kingdom. Where the UK GDPR restricted-transfer  
regime applies, Compass will establish and document an appropriate transfer mechanism or permitted exception before  
carrying out the restricted transfer. For information about a particular transfer and safeguards, contact us using the  
address above.  
7 HOW LONG WE KEEP PERSONAL INFORMATION  
Data retention follows Compass's approved Data Retention Schedule 2026, based on legal, safeguarding and operational
requirements. Retention periods are reviewed regularly and adjusted where necessary. Records may be retained longer
where required for safeguarding, legal or regulatory purposes.
Category  
Retention Period / Review Criteria  
Routine guardianship agreements, authorisations and  
correspondence  
Normally 6 years after guardianship ends.  
Routine student wellbeing and visit logs  
Medical forms and routine health information  
Safeguarding and child protection records  
Serious or historic child sexual abuse records  
Financial/accounting records  
Normally 6 years after guardianship ends; safeguarding material is  
separated.  
Review at closure; normally no longer than 6 years after  
guardianship ends and delete earlier where no longer needed.  
Individual case-by-case retention; age 25 may be a reference point  
where justified, not an automatic deletion date.  
Specialist case review; potentially much longer retention where  
lawful and necessary.  
Normally 6 years from the relevant financial year end, subject to  
legal exceptions.  
Unsuccessful applications and routine enquiries  
Formal complaint records  
Typically 6–12 months after closure, subject to necessity.  
At least 3 years under the Complaints Policy, with longer retention if  
a safeguarding or legal need applies.  
Staff, host and DBS-related vetting records  
Retained according to role-specific legal and safeguarding  
requirements; a separate schedule is being verified.  
At the end of the applicable period, records are reviewed and securely deleted, anonymised or retained for a further  
documented and justified period. Legal holds, investigations and safeguarding requirements may override routine deletion. You  
may contact Compass for the specific retention criteria applicable to your information.  
8 YOUR RIGHTS  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
enquiries@compassedu.co.uk  
Depending on the circumstances and legal exemptions, you may have the right to be informed; request access, correction,  
deletion or restricted processing; object to certain processing; and request portability of eligible personal data. Where we  
rely on consent, you may withdraw it without affecting processing already carried out lawfully. Rights in relation to solely  
automated decisions and profiling also apply where relevant.  
To exercise a right, contact enquiries@compassedu.co.uk and mark the subject “Data Protection Request”. We may ask for  
reasonable identity verification. We normally respond within one calendar month of receiving a valid request, subject to  
lawful extensions or exceptions. When responding to a request about a child, we consider their age, understanding,  
welfare and confidentiality.  
Routine guardianship admission, safeguarding and welfare decisions are subject to human involvement. If we introduce  
automated decisions with significant effects, we will provide additional privacy information and safeguards as required.  
9 RAISING A CONCERN OR COMPLAINT  
If you have concerns about how Compass uses personal data, please contact enquiries@compassedu.co.uk so that we can  
investigate. This privacy route is separate from the AEGIS guardianship service complaints procedure.  
You can also contact the Information Commissioner’s Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire SK9  
5AF; telephone 0303 123 1113; website www.ico.org.uk/make-a-complaint.  
10 PUBLICATION AND ANNUAL REVIEW  
This notice is intended to be made publicly available on the Compass website as required by AEGIS Standard 2.7.3. We will  
review it at least annually and sooner when our services, legal responsibilities, information systems or processing activities  
change. It should be read alongside the current Data Protection Policy and the approved Data Retention Schedule.  
Version: 2026 – Version 1.0  
Previous Review Date: 3 September 2025  
Review Date: 3 September 2026  
Effective Date: 3 September 2026  
Next Review Date: 3 September 2027  
Approved by: Lu Jin (Lucy), Director  
Signature: _______Lu Jin__________________  
Date Approved: 3 September 2026  
Registered in England No. 9024815