We treat personal data under the provisions of the Brazilian General Personal Data Protection Law (LGPD) in our operations in Brazil. Also, we apply the UK Data Protection Act (incorporating the EU General Data Protection Regulation - GDPR) to our global operations unless the local equivalent laws are stronger.
The LGPD and the other legal instruments mentioned above confer individual rights over the way how their personal information is used and set out rules for organisations that treat such data.
Our Cookies Policy describes what cookies we use on our website and their purpose.
Exercising your rights concerning the processing of your personal information
To exercise your rights, according to article 18 of the LGPD, you must give us a request in writing, by post or by email. Although you should submit a request in writing, if you would like to speak to someone in person, you may contact us by telephone.
Associação Conselho Britânico - British Council Brazil
Rua Ferreira de Araújo, 741, 3º andar – Pinheiros – São Paulo, SP – CEP 05428-002
Telephone: +55 11 2126-7500 | E-mail: email@example.com
Information Governance Advisor (Disclosures)
British Council - 58 Whitworth Street - Manchester - M1 6BB - United Kingdom
Telephone: +44(0) 161 957 7624 | E-mail: IGDisclosures@britishcouncil.org
Brazilian National Data Protection Authority (ANPD)
Esplanada dos Ministérios, Bloco C, 2º andar, CEP 70297-400 - Brasília – DF
E-mail: firstname.lastname@example.org | Website: www.gov.br/anpd
Information Commissioner’s Office (ICO)
Wycliffe House - Water Lane - Wilmslow - Cheshire - SK9 5AF - United Kingdom
E-mail: email@example.com | Website: www.ico.org.uk
We may need to ask you to provide:
- proof of your identity
- proof of your home address
- any information that we reasonably need to locate the information you have requested (for example details of the British Council offices or staff that you have had contact with and in which period)
We will not start looking for your information until we confirm your identity.
Right to access personal information
Any individual has a right to ask for a copy of the personal information held about them, according to article 18, II, of the LGPD. This means that you can ask for access to the information that the British Council holds about you. This is known as the right to ‘subject access'.
Right to restrict processing of personal information
In some situations, you have the right to require us to restrict the processing of your personal information. We may restrict your personal information by temporarily moving the information to another processing system, making the information unavailable to users, or temporarily removing published information from a website. We may also use technical methods to ensure the personal information is not subject to further processing and cannot be changed. When we have restricted processing of personal information, this will be clearly indicated on our systems.
You can require us to restrict processing in the following circumstances:
- We are processing your personal data unlawfully and you do not want us to delete the information but restrict it instead.
- You are concerned that the information we hold about you is inaccurate. You can ask us to restrict the information until we can determine whether the information is accurate or inaccurate.
- We no longer need the information for the purposes for which we collected it, but they are needed by you for the establishment, exercise or defence of legal claims.
- You have objected to the processing (see below) and we need to decide whether the legitimate interests we have to process the information override your fundamental rights.
Processing you think is unlawful
If you tell us that you think we are processing your personal information unlawfully, but you do not want the information to be erased, you have the right to require us to restrict the processing of that information, according to article 18, IV, of the LGPD.
We will ask you for an explanation about why you think the processing is unlawful and may also ask that you provide evidence to support this view.
Processing of personal information you think is inaccurate
You can tell us if you think the personal information, we are processing about you, is factually inaccurate, according to article 18, III, of the LGPD. You can require us to restrict how we use your personal information until we can verify the accuracy of the information. We will ask you for an explanation about why you think the information is inaccurate and may also ask that you provide some supporting evidence of the alleged inaccuracy.
If we find that the personal information we are processing about you is inaccurate we will take appropriate steps to correct the information.
Personal information no longer needed by the British Council, but needed by you in connection with a legal claim
In most circumstances, we will securely delete or dispose of personal information when we no longer need it for our legitimate business purposes. Our approach to retention is outlined in our corporate retention schedules.
However, if the personal information we no longer need would assist you in establishing, exercising or defending a legal claim, you can require us to keep the information for as long as necessary. We may ask you to provide an explanation and any available supporting evidence that a legal claim is on-going or contemplated.
Right to object to processing
You have the right to object to the British Council processing your personal data in the following circumstances:
- Personal information used for direct marketing
If we are using your personal information to send you direct marketing, you have the right to object at any time. If you exercise this right, we will stop processing your personal information for direct marketing purposes. However, we may keep your information on a “suppression list” to ensure your information is not added to any marketing lists at some point in the future.
- Automated decision making and profiling
‘Profiling’ is the automated use of personal data held on a computer to analyse or predict things which have a legal effect, or other similarly significant effects, on the individual. Examples would include economic situation, health, personal preferences or interests, and location. You have the right not to be subject to a solely automated decision (that is, a decision made electronically, with no human intervention), according to article 20 of the LGPD, including profiling (although there is no general right to object to profiling). If you are concerned the British Council has made a solely automated decision about you, you can object.
Please note, British Council is allowed to carry out automated decisions with no human intervention where you have given your explicit consent to this processing (although you have the right to withdraw your consent), according to article 18, IX, of the LGPD.
We are also permitted to make automated decisions with no human intervention in the following circumstances:
- The automated decision is necessary to enter into, or perform a contract, or complete a contract involving you and the British Council, e.g making an electronic purchase.
- The automated decision is allowed according to article 20 of the LGPD, which provides safeguards to protect your rights and freedoms.
However, you still have a general right to object in both of the above circumstances, providing reasons why you think the processing is having a negative effect on you. If you do object, we will carefully consider your reasons, and decide whether to review the decision-making process in your specific case.
Right to erasure of personal data ('the right to be forgotten')
According to article 18, items IV and VI, of the LGPD, you have the right to require that British Council securely deletes or destroys your personal information, if:
- The personal information we hold about you is no longer necessary for the purposes for which we originally collected it.
- The processing is based on consent - if you have previously given your consent to British Council collecting and processing your personal information, and you notify us that you withdraw your consent. Please note: withdrawing your consent does not mean the processing of your personal data which occurred before the withdrawal was unlawful.
- We are processing your personal information for direct marketing purposes, and you want us to stop.
- If you think the British Council has processed your personal information unlawfully.
If you think any of the above situations apply, we may ask you for an explanation and further information to verify this.
Right to data portability
If you have provided your information to British Council, you have the right to request and receive a copy of that information in a structured, commonly used and machine-readable format, according to article 18, V, of the LGPD.
You also have the right to ask us to send the information we hold about you to another organisation.
There are some situations in which the right to data portability does not apply. For further information, please contact us at firstname.lastname@example.org or IGDisclosures@britishcouncil.org
Your right to complain to a national data protection regulator (data protection supervisory authority)
If you think we have processed your personal information unfairly or unlawfully, or we have not complied with your rights under LGPD, you have the right to complain to a national data protection regulator, according to article 18, paragraph 1st of the LGPD.
Complaints about how we process your personal information can be considered by the National Data Protection Authority (ANPD).
If you have a concern about how we have processed your personal data, the ANPD will request that you contact us first, outlining your concerns, allowing us to try and put the issue right, before contacting them with your complaint or concern.
British Council processing of personal information
British Council shares personal information within the wider British Council group of entities situated both within and outside Brazil. We do this under a data-sharing agreement that includes the appropriate international data transfer clauses to make sure your personal information is protected, no matter which entity in the British Council group holds that information.
Where British Council makes transfers of personal information outside the British Council Group to another organisation, we rely on the use of the EU model international data transfer clauses, if the country the organisation is situated in has not received an adequacy decision from the ANPD, under article 33, I of the LGPD.
We also use other organisations to process your personal information to carry out services on our behalf. We use them to:
- Provide customer service, surveys, and marketing;
- Personalise our services;
- Process payments; and
- Carry out fraud and other legal investigations.
Where we use another organisation, we make sure that your personal information is protected and remains in our control.
We also, in certain situations, share personal information to government bodies and law enforcement bodies. Where we do share personal information with these types of organisations, we’ll make sure it’s protected, as far as it is reasonably possible.
With your consent, we’ll use your personal information to send you direct marketing and to better identify products and services that interest you. We do that if you’re one of our customers or if you’ve been in touch with us another way (such as registering to attend a British Council event or entering a competition).
This means we’ll:
- better understand you as a customer and tailor the marketing communications we send you
- tell you about other products and services you might be interested in
- try to identify the products and services you’re interested in.
The information processed consists of:
- your contact details - this includes your name, gender, address, phone number, date of birth and email address
- information from cookies and tags placed on your connected devices
- information from other organisations such as aggregated demographic data and publicly available sources like the business directories
- details of the products and services you’ve bought and how you use them.
We'll send you information about the products and services we provide by phone, post, email, text message, online banner advertising according to the communications channels you prefer. We also use the information we have about you to personalise these messages wherever we can as we believe it is important to make them relevant to you. We do this because we have a legitimate business interest in keeping you up to date with our products and services. We also check that you are happy for us to send you marketing messages before we do so. In each message we send, you also have the option to opt-out.
We’ll only market other organisations’ products and services if you have said it is OK for us to do so.
You can ask us to stop sending you marketing information or withdraw your permission at any time.
British Council retains personal information in line with our corporate retention requirements. Further details of our corporate retention schedule are available on request via the contact details, please contact us at email@example.com or IGDisclosures@britishcouncil.org
We undertake fraud checks on all customers because this is necessary for us to perform our contracted services to customers, by ensuring that the services we provide are duly paid for, and so that individuals themselves are protected from fraudulent transactions on their cards. Where we believe we may detect fraudulent activity we may block you from purchasing a product.
Given the volumes of transactions we deal with, we use automated systems including third-party systems for fraud detection purposes which analyses each sale to make automated decisions as to whether or not we will accept a sale. We find this is a fairer, more accurate and more efficient way of conducting fraud checks since human checks would simply not be possible in the timeframes and given the volumes of customers that we deal with.
The checks and decisions that are made look at various components including known industry indicators of fraud which our expert fraud detection provider makes available to us, as well as fraud patterns we have detected on our Sites. When combined, these generate an automated score indicating the likelihood of a fraudulent transaction. If our systems indicate a high score for you, then we may decline an order or even block you from our services. The specific fraud indicators are dynamic so will change depending on what types of fraud are being detected in the wider world, country and our sites at any time.
You have certain rights in respect of this activity. Our fraud detection is in place to protect all our customers as well as the British Council. You have the right to contest any fraud decision made about you and to be given more information about why any such decision was made by exercising your rights as noted above, please contact us at firstname.lastname@example.org or IGDisclosures@britishcouncil.org
General Data Protection Queries
If you wish to communicate with us about this privacy notice, or any issue relating to information governance or data protection, please contact the British Council's Data Protection Officer, using the following channels:
Associação Conselho Britânico - Brazil
Rua Ferreira de Araújo, 741, 3º andar – Pinheiros – São Paulo, SP – CEP 05428-002
Telephone: +55 11 2126-7500 | E-mail: email@example.com
British Council - Information Governance & Risk Management Team
10 Spring Gardens - London - SW1A 2BN - United Kingdom
Telephone: (0)20 7389 4385 | E-mail: InfoGovernance@britishcouncil.org