High Fliers Academy (HFA) Privacy Notice

High Fliers Academy www.highfliersacademy.org (HFA) is a Beacon Changemakers programme, operated by The Beacon Equity Trust. Commercial applications are provided by ARLLStar Ltd, a not-for-profit related company.

The Beacon Equity Trust is registered in England and Wales No. 06952392, and is a UK registered charity No. 1132994. ARLLStar Ltd  is registered in England and Wales No. 15409391.

For Students

HFA holds personal information about students who are enrolled on HFA courses, events and other programmes. We use personal information about students to deliver courses and content to enrolees, and with their consent share information with university partners.

If at any point you have questions about our privacy notice, or how we are using student data, please contact us (details below).

Contact details

Post: HIGH FLIERS ACADEMY Sandells House, Cliftons Lane, Reigate, Surrey, RH2 9RA, GB

Email: info@highfliersacademy.org

1. About this Privacy Notice

    The purpose of this privacy notice is to explain how High Fliers Academy (“HFA”, “we”, “our”, “us”) processes personal data of students enrolled on HFA courses, events and programmes and how it will be used, distributed, stored, and destroyed. HFA includes the central offices at Reigate, Surrey UK, and any HFA staff located in countries in which we operate.

    What information we collect, use, and why

    a) Student data

      All the personal data we process is provided by students when they enrol on HFA courses, events and programmes. It may also be that students share personal information with us directly or via client organisations (see 5. Client organisations below). Students may also provide feedback and commentary within HFA courses, events and programmes or workshops which is then held in our systems. We collect or use the following information, all for student education and development, in particular informing students of university pathways:

      • Names and contact details for students
      • Date of birth
      • School information and address details
      • University plans
      • Primary parent or guardian name and contact details

      b) Marketing data

      We research and collect business-to-business marketing data from publicly available sources and third parties. This is contact information which enables us to appropriately target our HFA products and offers. We collect a variety of information. Examples include:

      • Contact information such as name, address, phone number, or email address
      • Purchase information such as items clients have purchased, payment method and payment information, billing address, and contact information
      • Preference information such as contact and marketing preferences
      • Profile and account information which may include name, organisation, job role, phone number, email address, and account password

      We and third parties may collect information from the computer, tablet, phone or other device that clients or prospective clients use to access HFA material, or that clients or prospects use to open an email or click on a promotion or advertisement from us. This collection includes automatically collected information, and generally does not include personal information unless clients or prospects provide it through a mobile application or they choose to share it with us.  Methods we use include:

      • Cookies (which may be session-based or persistent, and are typically small data files that are stored on your hard drive or in connection with your internet browser
      • Web beacons or tags (small images embedded into websites or emails that send information about your computer, tablet, phone or other device when you visit our website, or open an email we send you)
      • Website and mobile application log files (which we tend to create automatically in connection with access to and use of our website and any mobile application)
      • Other technologies which may be similar to or different than the methods noted above

      Clients or prospects can opt out of marketing or advertising emails by utilising the ‘unsubscribe’ link or mechanism noted in the footer of our marketing or advertising emails they receive from us. They may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified our emails or website, and sharing the email address at which they are receiving marketing or advertising emails.

      3. Lawful bases and data protection rights

      Under UK data protection law, we must have a “lawful basis” for collecting and using personal information of students. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

      Which lawful basis we rely on may affect student data protection rights which are in brief set out below. More about the data protection rights of students and the exemptions which may apply can be found on the ICO’s website:

      • Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
      • Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
      • Your right to erasure – You have the right to ask us to delete your personal information.
      • Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
      • Your right to object to processing – You have the right to object to the processing of your personal data.
      • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
      • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

      If you make a request, we must respond to you without undue delay and in any event within one month. Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop.

      If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact us using the contact details above. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

      If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office on the ICO website.

      4. Our lawful bases for the collection and use of student data

      Our lawful bases for collecting or using personal information for student education and welfare are:

      • Contract – we have to collect or use the information so we can enter into or carry out our obligations with you. All of your data protection rights may apply except the right to object.
      • Legitimate interests – we’re collecting or using your information because it benefits you, the client organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

      5. Client organisations

      We may use email addresses and other contact information about students from organisations such as schools who may become clients through a bulk purchase. We do this in order to be able to enrol students, contact them to deliver the HFA courses, events and programme. Any feedback data provided by students and client organisations is used by us to improve our own products and services. We send client organisations emails and updates about HFA programme updates and developments including information about the students they have enrolled on the HFA programme through courses, events and other programmes.

      6. Where we get personal information from

      • Directly from students.
      • Client organisations who are acting on behalf of students and in their interest.

      7. How long we keep relevant information

      Commercial contracts:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Contracts with clients5 years after last actionInternal Shared Cloud DriveSupply contract and delivery of programmeDelete computer record
      Purchase orders and invoices7 years after last actionInternal Shared Cloud DriveClient Documents to fulfil supply contractsDelete computer record

      Marketing records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Mailing list contact information1 year after last actionInternal Shared Cloud DriveFor contact mailing where appropriateDelete computer record
      Preference information1 year after last actionInternal Shared Cloud DriveFor contact mailing where appropriateDelete computer record

      Client records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Contact information3 years after last actionInternal Shared Cloud Drive/MoodleFor client contact where appropriateDelete computer record
      Profile and account information3 years after last actionInternal Shared Cloud DriveFor contact where appropriateDelete computer record

      Operational records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Policies/Procedures7 yearsInternal Shared Cloud DriveLegal requirementDelete computer record
      Complaints5 years from end of fiscal yearInternal Shared Cloud DriveLegal requirementDelete computer record

      Intellectual property records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Copyright material50 years from expiryInternal Shared Cloud Drive/MoodleRe-use/ Protection of CopyrightDeletion

      Email records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Email correspondenceArchive emails after 6 monthsStaff email accountsRelevant referenceOutlook – Archive deletion

      Student records:

      Type of recordRetention periodWhere is it stored?ReasonMethod of deletion
      Contact details6 months after the end of a Client ContractMoodle/
      Course  Information System
      Student contact and course useDeletion
      Course completion details6 months after the end of a Client ContractMoodle/ Course Information SystemCourse delivery and performance managementDeletion

      8. Who we share information with

      1. University partners
      2. Organisations we need to share information with for safeguarding reasons
      3. External auditors or inspectors
      4. Organisations we’re legally obliged to share personal information with
      5. Contractual staff and service providers

      9. Data security

      HFA takes the security of student data and any data provided by a client organisation very seriously and we have appropriate security measures in place to prevent personal data from being accidentally lost or misused. Access to student personal data is limited to those employees, contractors and other third parties who have a need to know. They will only process student personal data on our instructions and they are subject to a duty of confidentiality.

      10. How to complain

      If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

      If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

      The ICO’s address:           

      Information Commissioner’s Office
      Wycliffe House
      Water Lane
      Wilmslow
      Cheshire
      SK9 5AF

      Helpline number: 0303 123 1113

      Website: https://www.ico.org.uk/make-a-complaint

      Last updated

      May 2026