Privacy Policy

Data Protection Policy (GDPR Update)
1. Rationale
Our programme aims to ensure that all personal data collected about staff, young people, parents, visitors and other individuals is collected, stored and processed in
accordance with the General Data Protection Regulation (GDPR) and the expected
provisions of the Data Protection Act 2018 (DPA 2018) as set out in the Data Protection
Bill.
This policy applies to all personal data, regardless of whether it is in paper or electronic
format.
2. Legislation & Guidance
This policy meets the requirements of the GDPR and the expected provisions of the
DPA 2018. It is based on guidance published by the Information Commissioner’s Office
(ICO) on the GDPR and the ICO’s code of practice for subject access requests.
If the Programme uses CCTV: It also reflects the ICO’s code of practice for the use of
surveillance cameras and personal information.
In addition, this policy complies with regulation 5 of the Education (Pupil Information)
(England) Regulations 2005, which gives parents the right of access to their child’s
educational record.
In addition, this policy complies with our funding agreement and articles of association.
3. Definitions
Personal Data Any information relating to an identified, or identifiable, individual.
This may include the individual’s:
Name (including initials)
Identification number Location data Online identifier, such as a username
It may also include factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural or social identity.
Data Protection Policy (GDPR Update)
Personal data which is more sensitive and so needs more protection, including information about an individual’s:
Racial or ethnic origin Political opinions Religious or philosophical beliefs Trade union membership Genetics Biometrics (such as fingerprints, retina and iris patterns), where used for identification purposes Health – physical or mental Sex life or sexual orientation
1
Processing Anything actioned to personal data, such as collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying. Processing can be automated or manual.
Data subject: The identified or identifiable individual whose personal data is held or processed.
Data controller: A person or organisation that determines the purposes and the means of processing of personal data.
Data processor: A person or other body, other than an employee of the data controller, who processes personal data on behalf of the data controller.
Personal data breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.
4. The Data Controller
Our programme processes personal data relating to parents, young people, staff, governors, visitors
and others, and therefore is a data controller.
The programme is registered as a data controller with the ICO and will renew this registration annually or as otherwise legally required.
5. Roles & Responsibilities
This policy applies to all staff employed by our programme, and to external organisations or individuals working on our behalf. Staff who do not comply with this policy may face disciplinary action.
The Headteacher has overall responsibility for ensuring that our programme complies with all relevant data protection obligations.
Data protection officer
The data protection officer (DPO) is responsible for overseeing the implementation of this policy, monitoring our compliance with data protection law, and developing related policies and guidelines where applicable. They will provide an annual report of their activities directly to the governing board and, where relevant, report to the board their advice and recommendations on programme data protection issues. The DPO is also the first point of contact for individuals whose data the programme processes, and for the ICO.
Our DPO’s contact details are below:
Lisa Smith, Data Protection Officer
8 Brewery Court
Theale High Street
Reading
RG7 5AJ
Email: lisa.smith@csfc.co.uk
1
Headteacher The headteacher supports the data controller on a day-to-day basis.
All staff Staff are responsible for:
● Collecting, storing and processing any personal data in accordance with this policy
● Informing the programme of any changes to their personal data, such as a change of address
● Contacting the DPO in the following circumstances:
o With any questions about the operation of this policy, data protection law, retaining personal data or keeping personal data secure
o If they have any concerns that this policy is not being followed
o If they are unsure whether or not they have a lawful basis to use personal data in a particular way
o If there has been a data breach
o Whenever they are engaging in a new activity that may affect the privacy rights of individuals
o If they need help with any contracts or sharing personal data with third parties
6. Data Protection Principles
The GDPR is based on data protection principles that our programme must comply with.
The principles say that personal data must be:
● Processed lawfully, fairly and in a transparent manner
● Collected for specified, explicit and legitimate purposes
● Adequate, relevant and limited to what is necessary to fulfil the purposes for which it
● is processed
● Accurate and, where necessary, kept up to date
● Kept for no longer than is necessary for the purposes for which it is processed
● Processed in a way that ensures it is appropriately secure
This policy sets out how the programme aims to comply with these principles.
7. Collecting Personal Data
a. Lawfulness, fairness and transparency
We will only process personal data where we have one of 6 ‘lawful bases’ (legal
reasons) to do so under data protection law:
● The data needs to be processed so that the programme can fulfil a contract with the individual, or the individual has asked the programme to take specific steps before entering into a contract
● The data needs to be processed so that the programme can comply with a legal obligation
1
● The data needs to be processed to ensure the vital interests of the individual e.g. to protect someone’s life
● The data needs to be processed so that the programme, as a public authority, can perform a task in the public interest, and carry out its official functions
● The data needs to be processed for the legitimate interests of the programme or a third party (provided the individual’s rights and freedoms are not overridden)
● The individual (or their parent/carer when appropriate in the case of a pupil) has freely given clear consent
For special categories of personal data, we will also meet one of the special category conditions for processing which are set out in the GDPR and Data Protection Act 2018.
Whenever we first collect personal data directly from individuals, we will provide them with the relevant information required by data protection law.
b. Limitation, minimisation and accuracy
We will only collect personal data for specified, explicit and legitimate reasons. We will explain these reasons to the individuals when we first collect their data. If we want to use personal data for reasons other than those given when we first obtained it, we will inform the individuals concerned before we do so, and seek consent where necessary.
Staff must only process personal data where it is necessary in order to do their jobs. When staff no longer need the personal data they hold, they must ensure it is deleted or anonymised. This will be done in accordance with the Information and Records Management Society’s toolkit for programmes.
8. Sharing Personal Data
We will not normally share personal data with anyone else, but may do so where:
● There is an issue with a young person or parent/carer that puts the safety of our staff at risk
● We need to liaise with other agencies – we will seek consent as necessary before doing this
● Our suppliers or contractors need data to enable us to provide services to our staff and young people – for example, IT companies. When doing this, we will:
o Only appoint suppliers or contractors which can provide sufficient guarantees that they comply with data protection law
o Establish a data sharing agreement with the supplier or contractor, either in the contract or as a standalone agreement, to ensure the fair and lawful processing of any personal data we share
o Only share data that the supplier or contractor needs to carry out their service, and information necessary to keep them safe while working with us
We will also share personal data with law enforcement and government bodies where we are legally required to do so, including for:
● The prevention or detection of crime and/or fraud
● The apprehension or prosecution of offenders
● The assessment or collection of tax owed to HMRC
● In connection with legal proceedings
1
● Where the disclosure is required to satisfy our safeguarding obligations
● Research and statistical purposes, as long as personal data is sufficiently anonymised or consent has been provided
We may also share personal data with emergency services and local authorities to help them to respond to an emergency situation that affects any of our young people or staff.
Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
9. Subject Access Requests and other Rights of Individuals
a. Subject access requests
Individuals have a right to make a ‘subject access request’ to gain access to personal information that the programme holds about them. This includes:
● Confirmation that their personal data is being processed
● Access to a copy of the data
● The purposes of the data processing
● The categories of personal data concerned
● Who the data has been, or will be, shared with
● How long the data will be stored for, or if this is not possible, the criteria used to determine this period
● The source of the data, if not the individual
● Whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual
Subject access requests must be submitted in writing, either by letter, email or fax to the DPO. They should include:
● Name of individual
● Correspondence address
● Contact number and email address
● Details of the information requested
If staff receive a subject access request, they must immediately forward it to the DPO.
b. Children and subject access requests
Personal data about a child belongs to that child, and not the child’s parents or carers. For a parent or carer to make a subject access request with respect to their child, the child must either be unable to understand their rights and the implications of a subject access request or have given their consent.
Children below the age of 12 are generally not regarded to be mature enough to understand their rights and the implications of a subject access request. This is not a rule and a pupil’s ability to understand their rights will always be judged on a case-by-case basis.
Children aged 12 and above are generally regarded to be mature enough to understand their rights and the implications of a subject access request. This is not a rule and a pupil’s ability to understand their rights will always be judged on a case-by-case basis.
c. Responding to subject access requests
When responding to requests, we:
● May ask the individual to provide 2 forms of identification
● May contact the individual via phone to confirm the request was made
1
● Will respond without delay and within 1 month of receipt of the request
● Will provide the information free of charge
● May tell the individual we will comply within 3 months of receipt of the request, where a request is complex or numerous. We will inform the individual of this within 1 month, and explain why the extension is necessary
We will not disclose information if it:
● Might cause serious harm to the physical or mental health of the young person or another individual
● Would reveal that the child is at risk of abuse, where the disclosure of that information would not be in the child’s best interests
● Is contained in adoption or parental order records
● Is given to a court in proceedings concerning the child
If the request is unfounded or excessive, we may refuse to act on it, or charge a reasonable fee which takes into account administrative costs.
A request will be deemed to be unfounded or excessive if it is repetitive or asks for further copies of the same information.
When we refuse a request, we will tell the individual why, and tell them they have the right to complain to the ICO.
d. Other data protection rights of the individual
In addition to the right to make a subject access request (see above), and to receive information when we are collecting their data about how we use and process it (see section 7), individuals also have the right to:
● Withdraw their consent to processing at any time
● Ask us to rectify, erase or restrict processing of their personal data, or object to the processing of it (in certain circumstances)
● Prevent use of their personal data for direct marketing
● Challenge processing which has been justified based on public interest
● Request a copy of agreements under which their personal data is transferred outside of the European Economic Area
● Object to decisions based solely on automated decision making or profiling (decisions taken with no human involvement, that might negatively affect them)
● Prevent processing that is likely to cause damage or distress
● Be notified of a data breach in certain circumstances
● Make a complaint to the ICO
● Ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format (in certain circumstances)
● Individuals should submit any request to exercise these rights to the DPO. If staff receive such a request, they must immediately forward it to the DPO.
10. Parental requests to see Educational Record
The policy for independent programmes is that whilst not legally required, in a similar way to maintained programmes, we give the right for parents to have free access to their child’s educational record (which includes most information about a young person ) within 15 programme days of receipt of a written request.
11. Biometric Recognition Systems
1
If and where the Programme uses young people’ biometric data as part of an automated biometric recognition system (for example, young people use finger prints to receive programme dinners instead of paying with cash), we will comply with the requirements of the Protection of Freedoms Act 2012. Parents/carers will be notified before any biometric recognition system is put in place or before their child first takes part in it. The programme will get written consent from at least one parent or carer before we take any biometric data from their child and first process it. Parents/carers and young people have the right to choose not to use the programme’s biometric system(s). If a biometric system is introduced, we will provide alternative means of accessing the relevant services for those young people. For example, young people can pay for programme dinners in cash at each transaction if they wish. Parents/carers and young people can object to participation in a programme’s biometric recognition system(s), or withdraw consent, at any time, and we will make sure that any relevant data already captured is deleted. As required by law, if a young person refuses to participate in, or continue to participate in, the processing of their biometric data, we will not process that data irrespective of any consent given by the young person’s parent(s)/carer(s). Where staff members or other adults use the programme’s biometric system(s), we will also obtain their consent before they first take part in it and provide alternative means of accessing the relevant service if they object. Staff and other adults can also withdraw consent at any time, and the programme will delete any relevant data already captured.
12. CCTV
The Programme may use CCTV in various locations around the programme site to ensure it remains safe. If we use CCTV, we will adhere to the ICO’s code of practice for the use of CCTV. We do not need to ask individuals’ permission to use CCTV, but we make it clear where individuals are being recorded. Security cameras are clearly visible and accompanied by prominent signs explaining that CCTV is in use. Any enquiries about the CCTV system should be directed to the Data Protection Officer (DPO)
13. Photographs & Videos
As part of our programme activities, we may take photographs and record images of individuals within our programme. We will obtain written consent from parents/carers for photographs and videos to be taken of their child for communication, marketing and promotional materials. We will clearly explain how the photograph and/or video will be used to both the parent/carer and pupil.
Uses may include:
● Within programme on notice boards and in programme magazines, brochures, newsletters, etc.
● Outside of programme by external agencies such as the programme photographer, newspapers, campaigns
● Online on our programme website or social media pages
● Consent can be refused or withdrawn at any time. If consent is withdrawn, we will delete the photograph or video and not distribute it further.
● When using photographs and videos in this way we will not accompany them with any other personal information about the child, to ensure they cannot be identified.
14. Data Protection by Design & Default
We will put measures in place to show that we have integrated data protection into all of our data processing activities, including:
1
● Appointing a suitably qualified DPO, and ensuring they have the necessary resources to fulfil their duties and maintain their expert knowledge
● Only processing personal data that is necessary for each specific purpose of processing, and always in line with the data protection principles set out in relevant data protection law (see section 6)
● Completing privacy impact assessments where the programme’s processing of personal data presents a high risk to rights and freedoms of individuals, and when introducing new technologies (the DPO will advise on this process)
● Integrating data protection into internal documents including this policy, any related policies and privacy notices
● Regularly training members of staff on data protection law, this policy, any related policies and any other data protection matters; we will also keep a record of attendance
● Regularly conducting reviews and audits to test our privacy measures and make sure we are compliant
Maintaining records of our processing activities, including:
o For the benefit of data subjects, making available the name and contact details of our programme and DPO and all information we are required to share about how we use and process their personal data (via our privacy notices)
o For all personal data that we hold, maintaining an internal record of the type of data, data subject, how and why we are using the data, any third-party recipients, how and why we are storing the data, retention periods and how we are keeping the data secure.
15. Data Security & Storage of Records
We will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure, and against accidental or unlawful loss, destruction or damage.
In particular:
● Paper-based records and portable electronic devices, such as laptops and hard drives that contain personal data are kept under lock and key when not in use
● Papers containing confidential personal data must not be left on office and classroom desks, on staffroom tables, pinned to notice/display boards, or left anywhere else where there is general access
● Where personal information needs to be taken off site, staff must sign it in and out from the programme office
● Passwords that are at least 8 characters long containing letters and numbers are used to access programme computers, laptops and other electronic devices. Staff and young people are reminded to change their passwords at regular intervals
● Encryption software is used to protect all portable devices and removable media, such as laptops and USB devices where personal information is stored
● Staff, young people or governors who store personal information on their personal devices are expected to follow the same security procedures as for programme-owned equipment
● Where we need to share personal data with a third party, we carry out due diligence and take reasonable steps to ensure it is stored securely and adequately protected (see section 8)
16. Disposal of Records
Personal data that is no longer needed will be disposed of securely. Personal data that has become inaccurate or out of date will also be disposed of securely, where we cannot or do
1
not need to rectify or update it. For example, we will shred or incinerate paper-based records, and overwrite or delete electronic files. We may also use a third party to safely dispose of records on the programme’s behalf. If we do so, we will require the third party to provide sufficient guarantees that it complies with data protection law.
17. Personal Data Breaches
The programme will make all reasonable endeavours to ensure that there are no personal data breaches. In the unlikely event of a suspected data breach, we will follow the procedure set out in appendix 1. When appropriate, we will report the data breach to the ICO within 72 hours. Such breaches in a programme context may include, but are not limited to:
● A non-anonymised dataset being published on the programme website which shows the exam results of young people eligible for the young person’ premium
● Safeguarding information being made available to an unauthorised person
● The theft of a programme laptop containing non-encrypted personal data about young people
18. Training
All staff are provided with data protection training as part of their induction process. Data protection will also form part of continuing professional development, where changes to legislation, guidance or the programme’s processes make it necessary.
19. Monitoring Arrangements
The DPO is responsible for monitoring and reviewing this policy. This policy will be reviewed and updated if necessary when the Data Protection Bill receives royal assent and becomes law (as the Data Protection Act 2018) – if any changes are made to the bill that affect our programme’s practice. Otherwise, or from then on, this policy will be reviewed every 2 years and shared with all staff.
20. Links with Other Policies
This data protection policy is linked to other policies including:
● Freedom of information policy (Including publication scheme)
1
Appendix 1 – Personal Data Breach Procedure
This procedure is based on guidance on personal data breaches produced by the ICO.
● On finding or causing a breach, or potential breach, the staff member or data processor must immediately notify the DPO
● The DPO will investigate the report and determine whether a breach has occurred. To decide, the DPO will consider whether personal data has been accidentally or unlawfully:
o Lost
o Stolen
o Destroyed
o Altered
o Disclosed or made available where it should not have been
o Made available to unauthorised people
● The DPO will alert the headteacher and QA Manager
● The DPO will make all reasonable efforts to contain and minimise the impact of the breach, assisted by relevant staff members or data processors where necessary. (Actions relevant to specific data types are set out at the end of this procedure)
● The DPO will assess the potential consequences, based on how serious they are, and how likely they are to happen
● The DPO will work out whether the breach must be reported to the ICO. This must be judged on a case-by-case basis. To decide, the DPO will consider whether the breach is likely to negatively affect people’s rights and freedoms, and cause them any physical, material or non-material damage (e.g. emotional distress), including through:
o Loss of control over their data
o Discrimination
o Identify theft or fraud
o Financial loss
o Unauthorised reversal of pseudonymisation (for example, key-coding)
o Damage to reputation
o Loss of confidentiality
o Any other significant economic or social disadvantage to the individual(s) concerned
If it’s likely that there will be a risk to people’s rights and freedoms, the DPO must notify the
ICO.
The DPO will document the decision (either way), in case it is challenged at a later date by the ICO or an individual affected by the breach. Documented decisions are stored by the DPO.
● Where the ICO must be notified, the DPO will do this via the ‘report a breach’ page of the ICO website within 72 hours.
1
● As required, the DPO will set out: A description of the nature of the personal data breach including, where possible: The categories and approximate number of individuals concerned The categories and approximate number of personal data records concerned
● The name and contact details of the DPO
● A description of the likely consequences of the personal data breach
● A description of the measures that have been, or will be taken, to deal with the breach and mitigate any possible adverse effects on the individual(s) concerned
If all the above details are not yet known, the DPO will report as much as they can within 72 hours. The report will explain that there is a delay, the reasons why, and when the DPO expects to have further information. The DPO will submit the remaining information as soon as possible.
o The DPO will also assess the risk to individuals, again based on the severity and likelihood
o of potential or actual impact. If the risk is high, the DPO will promptly inform, in writing, all
o individuals whose personal data has been breached. This notification will set out:
o The name and contact details of the DPO
o A description of the likely consequences of the personal data breach
o A description of the measures that have been, or will be, taken to deal with the data breach and mitigate any possible adverse effects on the individual(s) concerned
● The DPO will notify any relevant third parties who can help mitigate the loss to individuals – for example, the police, insurers, banks or credit card companies
● The DPO will document each breach, irrespective of whether it is reported to the ICO. For each breach, this record will include the:
o Facts and cause
o Effects
o Action taken to contain it and ensure it does not happen again (such as establishing more robust processes or providing further training for individuals). Records of all breaches will be stored by the DPO.
The DPO and headteacher will meet to review what happened and how it can be avoided from happening again. This meeting will happen as soon as reasonably possible detailing actions to minimise the impact of data breaches. We will take the actions set out below to mitigate the impact of different types of data breach, focusing especially on breaches involving particularly risky or sensitive information. We will review the effectiveness of these actions and amend them as necessary after any data breach.
Sensitive information being disclosed via email (including safeguarding records)
● If special category data (sensitive information) is accidentally made available via email to unauthorised individuals, the sender must attempt to recall the email as soon as they become aware of the error
● Members of staff who receive personal data sent in error must alert the sender and the DPO as soon as they become aware of the error
1
● In any cases where the recall is unsuccessful, the DPO will contact the relevant unauthorised individuals who received the email, explain that the information was sent in error, and request that those individuals delete the information and do not share, publish, save or replicate it in any way
● The DPO will ensure we receive a written response from all the individuals who received the data, confirming that they have complied with this request
● The DPO will carry out an internet search to check that the information has not been made public; if it has, we will contact the publisher/website owner or administrator to request that the information is removed from their website and deleted
● Other types of breach that you might want to consider could include:
● Details of pupil premium interventions for named children being published on the programme website
● Non-anonymised pupil exam results or staff pay information being shared with QA Manager
● A programme laptop containing non-encrypted sensitive personal data being stolen or hacked
● The programme’s cashless payment provider being hacked and parents’ financial details stolen
1
Appendix 2 – Model Privacy Notices
1. Privacy notice for parents/carers
Under data protection law, individuals have a right to be informed about how the programme uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.
This privacy notice explains how we collect, store and use personal data about young people. The programme is the ‘data controller’ for the purposes of data protection law. Our data protection officer and contact details are below (see ‘Contact us’ below).
The personal data we hold: Personal data that we may collect, use, store and share (when appropriate) about young people includes, but is not restricted to:
● Contact details, contact preferences, date of birth, identification documents
● Results of internal assessments and externally set tests
● Pupil and curricular records
● Characteristics, such as ethnic background, eligibility for free programme meals, or special educational needs
● Exclusion information
● Details of any medical conditions, including physical and mental health
● Attendance information
● Safeguarding information
● Details of any support received, including care packages, plans and support providers
● Photographs
● CCTV images captured in programme
We may also hold data about young people that we have received from other organisations, including other programmes, local authorities and the Department for Education.
Why we use this data
We use this data to:
● Support pupil learning
● Monitor and report on pupil progress
● Provide appropriate pastoral care
● Protect pupil welfare
● Assess the quality of our services
● Carry out research
● Comply with the law regarding data sharing
● Link with inter-agencies regarding Safeguarding & Welfare Data
Our legal basis for using this data
We only collect and use young people’ personal data when the law allows us to. Most commonly, we process it where:
● We need to comply with a legal obligation
● We need it to perform an official task in the public interest
1
Less commonly, we may also process young people’ personal data in situations where:
● We have obtained consent to use it in a certain way
● We need to protect the individual’s vital interests (or someone else’s interests)
Where we have obtained consent to use young people’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent and explain how consent can be withdrawn. Some of the reasons listed above for collecting and using young people’ personal data overlap, and there may be several grounds which justify our use of this data.
Collecting this information
Whilst the majority of information we collect about young people is mandatory, there is some information that can be provided voluntarily. Whenever we seek to collect information from you or your child, we make it clear whether providing it is mandatory or optional. If it is mandatory, we will explain the possible consequences of not complying.
How we store this data
We keep personal information about young people while they are attending our programme. We may also keep it beyond their attendance at our programme if this is necessary in order to comply with our legal obligations.
Data sharing
We do not share information about young people with any third party without consent unless the law and our policies allow us to do so.
Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about young people with:
● Local authorities – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
● The Department for Education
● The pupil’s family and representatives
● Educators and examining bodies
● Our regulator, e.g. Ofsted, Independent Programmes Inspectorate
● Suppliers and service providers – to enable them to provide the service we have contracted them for
● Financial organisations
● Health and social welfare organisations
● Professional advisers and consultants
● Charities and voluntary organisations
● Police forces, courts, tribunals
● Professional bodies
National Pupil Database
We are required to provide information about young people to the Department for Education as part of statutory data collections such as the programme census if applicable. Some of this information is then stored in the National Pupil Database (NPD), which is owned and managed by the Department and provides evidence on programme performance to inform research. The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including programmes, local authorities and exam boards. The Department for Education may share information from the NPD with other organisations
1
which promote children’s education or wellbeing in England. Such organisations must agree to strict terms and conditions about how they will use the data. For more information, see the Department’s webpage on how it collects and shares research data. You can also contact the Department for Education with any further questions about the NPD.
Transferring data internationally
Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
Parents and young people’ rights regarding personal data
Individuals have a right to make a ‘subject access request’ to gain access to personal information that the programme holds about them. Parents/carers can make a request with respect to their child’s data where the child is not considered mature enough to understand their rights over their own data (usually under the age of 12), or where the child has provided consent. Parents also have the right to make a subject access request with respect to any personal data the programme holds about them. If you make a subject access request, and if we do hold information about you or your child, we will:
● Give you a description of it
● Tell you why we are holding and processing it, and how long we will keep it for
● Explain where we got it from, if not from you or your child
● Tell you who it has been, or will be, shared with
● Let you know whether any automated decision-making is being applied to the data, and any consequences of this
● Give you a copy of the information in an intelligible form
Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances. If you would like to make a request please contact our data protection officer.
Other rights
Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:
● Object to the use of personal data if it would cause, or is causing, damage or distress
● Prevent it being used to send direct marketing
● Object to decisions being taken by automated means (by a computer or machine,
● rather than by a person)
● In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
● Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact our data protection officer.
Complaints
We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concerns about our data processing, please raise this with us in the first instance.
1
To make a complaint, please contact our data protection officer.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
● Report a concern online at https://ico.org.uk/concerns/
● Call 0303 123 1113
● Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
● Cheshire, SK9 5AF
Contact us
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:
Exceed Programme Ms Ludivine Parmentier, Data Protection Officer Woodside Farm
Old Street
Hermitage
Thatcham
RG18 9SG
Email: ludivine.parmentier@csfc.co.uk
Telephone: 01635 202479
This notice is based on the Department for Education’s model privacy notice for young people, amended for parents and to reflect the way we use data in this programme.
2. Privacy notice for staff
Under data protection law, individuals have a right to be informed about how the programme uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data. This privacy notice explains how we collect, store and use personal data about individuals we employ, or otherwise engage, to work at our programme. We, the programme, are the ‘data controller’ for the purposes of data protection law. Our data protection officer is listed below (see ‘Contact us’ below).
The personal data we hold
We process data relating to those we employ, or otherwise engage, to work at our programme. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
● Contact details
● Date of birth, marital status and gender
● Next of kin and emergency contact numbers
● Salary, annual leave, pension and benefits information
● Bank account details, payroll records, National Insurance number and tax status information
1
● Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process
● Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships
● Performance information
● Outcomes of any disciplinary and/or grievance procedures
● Absence data
● Copy of driving licence
● Photographs
● CCTV footage
● Data about our use of the programme’s information and communications system
We may also collect, store and use information about you that falls into “special categories” of more sensitive personal data. This includes information about (where applicable):
● Race, ethnicity, religious beliefs, sexual orientation and political opinions
● Health, including any medical conditions, and sickness records
Why we use this data
The purpose of processing this data is to help us run the programme, including to:
● Enable you to be paid
● Facilitate safe recruitment, as part of our safeguarding obligations towards young people
● Support effective performance management
● Inform our recruitment and retention policies
● Allow better financial modelling and planning
● Enable ethnicity and disability monitoring
● Improve the management of workforce data across the programme
Our lawful basis for using this data
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:
● Fulfil a contract we have entered into with you
● Comply with a legal obligation
● Carry out a task in the public interest
Less commonly, we may also use personal information about you where:
● You have given us consent to use it in a certain way
● We need to protect your vital interests (or someone else’s interests)
● We have legitimate interests in processing the data
Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so.
Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the programme’s use of your data.
Collecting this information
While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us.
1
Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.
How we store this data
We create and maintain an employment file for each staff member. The information contained in this file is kept secure and is only used for purposes directly relevant to your employment. Once your employment with us has ended, we will retain this file and delete the information in it in accordance with legislation.
Data sharing
We do not share information about you with any third party without your consent unless the law and our policies allow us to do so. Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about you with:
● Local authorities – to meet our legal obligations to share certain information with it, such as safeguarding concerns
● Information about headteacher performance and staff dismissals
● The Department for Education
● Your family or representatives
● Educators and examining bodies
● Our regulator [specify as appropriate e.g. Ofsted, Independent Programmes Inspectorate]
● Suppliers and service providers – to enable them to provide the service we have contracted them for, such as payroll
● Financial organisations
● Central and local government
● Our auditors
● Survey and research organisations
● Trade unions and associations
● Health authorities
● Security organisations
● Health and social welfare organisations
● Professional advisers and consultants
● Charities and voluntary organisations
● Police forces, courts, tribunals
● Professional bodies
● Employment and recruitment agencies
Transferring data internationally
Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
Your rights
a. How to access personal information we hold about you
Individuals have a right to make a ‘subject access request’ to gain access to personal information that the programme holds about them. If you make a subject access request, and if we do hold information about you, we will:
1
● Give you a description of it
● Tell you why we are holding and processing it, and how long we will keep it for
● Explain where we got it from, if not from you
● Tell you who it has been, or will be, shared with
● Let you know whether any automated decision-making is being applied to the data, and any consequences of this
● Give you a copy of the information in an intelligible form
You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances. If you would like to make a request, please contact our data protection officer.
b. Your other rights regarding your data
Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:
● Object to the use of your personal data if it would cause, or is causing, damage or distress
● Prevent your data being used to send direct marketing
● Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person)
● In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
● Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact our data protection officer.
Complaints
We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concerns about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our data protection officer.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
● Report a concern online at https://ico.org.uk/concerns/
● Call 0303 123 1113
● Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Contact us
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:
Exceed Programme Data Protection Officer Ms Ludivine Parmentier
Email: ludivine.parmentier@csfc.co.uk
This notice is based on the Department for Education’s model privacy notice for the programme workforce, amended to reflect the way we use data in this programme.

Loading
Scroll to Top