Owner: Privacy Department
Approver: Global Privacy Officer
Version: January 2023
Last Review: December 2022
We are disclosing information about our data processing practices as required by the United Kingdom’s Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR). This DPA/GDPR Addendum supplements the information contained in the Bright Horizons Global Consumer Privacy Notice. This Addendum applies exclusively to Consumers using Services in the United Kingdom, Ireland, the Netherlands and any other country within the European Economic Area.
What legal basis do we rely on to process your personal information?
Bright Horizons relies on the following legal basis for processing your personal information.
- Performance under a Contract: For Consumers, most of the personal information we process is necessary for us to perform our obligations under a contract we have with you, and, if applicable, your employer when you receive the Service as an employee benefit.
- Legal Obligations: For Consumers, there are many laws that require us to process your personal information. Examples include law and regulations for child/adult care, safeguarding, health and safety, tax and government funding.
- Legitimate Interest: For Consumers, we have a legitimate interest in processing some of your personal information in some circumstances. We will only process your personal information if our legitimate interests do not override your fundamental rights, freedoms and interests. For any questions regarding this legal basis, please contact our Global Privacy Officer at email@example.com. Some examples of our legitimate interests include:
- Use of your email address to send you newsletters, invitations to webinars, or information about your services or new/enhanced Service updates.
- In some locations, we use Closed Circuit (CCTV) for security/safety of our consumers, staff and premises; to help prevent and detect crime; to support learning and training; and/or to defend legal claims.
- Recording your contact center calls to assist us with monitoring our policies and procedures; identifying opportunities for training and development; and improving Services to you.
- For consumers receiving our services as an employee benefit, we will use the information provided to us from your employer and you to create reporting and analytics information that inform us and your employer of registration for and use of the services, as well as for quality improvement of services (including as necessary anonymization of your personal information for these purposes).
- Special Categories of Personal Information: Depending upon our relationship with you, (consumer, staff or supplier), we may need to process special categories of personal information in order to employee you or evaluate whether Services are suitable for the care requested and/or to provide the Services safely and/or effectively. In some locations, government regulations/laws require us to process special categories of personal information. Special categories of personal information that we may process include information relating to:
- Health data:
- when receiving adult/child care services, in order for us to provide the Services safely and/or in compliance with applicable law, you may need to provide us with health data of the dependent we care for (for example to inform us of allergies, medicines, special physical or educational requirements, health conditions).In addition, this type of information may be provided to us by a government body;
- when receiving personal or family coaching or special educational needs services, you may voluntarily provide us with health data about you / your dependents to enable us to provide the advice services; and your employment.
- Race/ethnic origin: you may provide this information to us voluntarily when receiving College Coach services (for example to assist with identifying schools, scholarships, etc.).
- Trade union membership: your employer may provide this information to us to assist with determining levels of employee’s eligibility for our EdAssist services;