At Gidea Park College we collect and process personal information relating to our employees, pupils and their parents and/or guardians, suppliers and other individuals on a daily basis. However, we only collect personal information necessary to meet specifically planned, agreed and necessary purposes, and do not retain that information for any longer than is necessary. The school takes the confidentiality of all personal information very seriously and is committed to ensuring that we use any personal data that we hold in accordance with the law.
This privacy notice provides detailed information about how we process your personal data which we hope you will find both informative and reassuring. Please read it carefully and, if you have questions regarding your personal data or its use, feel free to contact the school:
- by email on email@example.com;
- by telephone on 01708 740381; or,
- by post to the School Secretary, Gidea Park College, 2 Balgores Lane, Gidea Park, Essex RM2 5JR.
Gidea Park is registered as a limited company with a registered company number of 712900, England. The school has notified the Information Commissioner’s Office of our processing activities – our registration number is Z8300792.
2. types of personal data we process
We use (or “process”) personal data about prospective, current and past: pupils and their parents; staff, suppliers and contractors; donors, friends and supporters; and other individuals connected to or visiting the school. Whilst this covers the general provisions for staff, there is a more specific and detailed Staff Privacy Notice which can be accessed through the school’s intranet.
The personal data we process takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples include:
- Names, addresses, telephone numbers, e-mail addresses and other contact details;
- Family details;
- Admissions, academic, disciplinary and other education related records, information about special educational needs, references, examination scripts and marks;
- Education and employment data;
- Images, audio and video recordings;
- Financial information;
- Courses, meetings or events attended.
This Privacy Notice is provided because Data Protection Law gives you the right to understand how your data is used. Staff, parents and pupils are all encouraged to read this Privacy Notice and understand the school’s obligations to its entire community.
This Privacy Notice applies alongside any other information we may provide about a specific use of personal data, for example when collecting data via an online or paper form (for example the ‘Consent for use of images’ form).
This Privacy Notice also applies in addition to the school's other relevant terms and conditions and policies, including:
- Any contract between the school and you;
- The school's policy on taking, storing and using images of children;
- The school’s CCTV policy;
- The school’s retention of records policy;
- The school's safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
- The school's IT policies, including its Acceptable Use Agreement and eSafety policy.
As a school, we need to process special category personal data (e.g. concerning health, ethnicity or religion) and criminal records information about some individuals (particularly pupils and staff). We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent.
If you work for, or act on behalf of the school (this includes staff, volunteers, directors and service providers), you should be aware of and comply with this Privacy Notice and the school's data protection policy, which provides further information about how your personal data will be used.
3. Responsibility for data privacy
We will deal with all your requests and enquiries concerning the school’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this notice and Data Protection Law. For further assistance the School Secretary can be contacted on 01708 740 381.
4. Collecting and handling personal data
We collect most of the personal data we process directly from you (or in the case of pupils, from their parents). In some cases, we collect data from third parties (for example, referees, previous schools, or professionals or authorities working with the individual) or from publicly available resources.
Personal data held by us is processed by appropriate members of staff for the purposes for which the data was provided. We take appropriate technical and organisational steps to ensure the security of your personal data, including policies around the use of technology and devices, and access to school systems. We do not transfer personal data outside of the European Economic Area unless we are satisfied that the personal data will be afforded an equivalent level of protection.
5. Legal basis for using data
We only collect and use pupils’ personal data when the law allows us to. Most commonly Gidea Park College needs to use your information in order to perform our obligations under our contract with you:
- Providing educational services to your child;
- Safeguarding and promoting the welfare of your child (and other children);
- Promoting the objects and interests of the School;
- Facilitating the efficient operation of the School; and
We also need to comply with legal obligations:
- Performing an official task in the public interest for example, to report a concern to Children’s Services. We may also disclose your information to third parties such as courts, the local authority or the police where legally obliged to do so.
Less commonly, we may also process pupils’ personal data in situations where:
- We have obtained consent to use it in a certain way (e.g. images/trips etc);
- We need to protect the individual’s vital interests (or someone else’s interests) – safeguarding; medical emergencies;
- We have a legitimate interest to use your data for a specific purpose.
Where we have obtained consent to use pupils’ 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 pupils’ personal data overlap, and there may be several grounds which justify our use of this data.
6. Sharing personal data
Occasionally, the school will need to share your personal information with third parties, such as:
- Professional advisers (e.g. lawyers, insurers, marketing advisers and accountants);
- Government authorities (e.g. HMRC, DfE, police or the local authority, the Local Children Safeguarding Board, DBS, NCTL, UK Visas and Immigration, Department for Work and Pensions);
- Appropriate regulatory bodies, such as the Teaching Regulation Agency, Independent Schools Inspectorate, the Information Commissioner);
- Examination boards.
For the most part, your personal data held by us will remain within the school and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
- Medical records held and accessed only by the welfare team, or otherwise in accordance with express consent; and
- Pastoral or safeguarding files.
However, a certain amount of any SEN pupil’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires.
You are reminded that the school is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to us, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the LADO or police. For further information about this, please see the school’s Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of the school’s processing activity is carried out on our behalf by third parties, such as IT systems, hosted website or cloud storage providers. This is subject to assurances that personal data will be kept securely and only in accordance with the school’s specific requirements.
We do not share or sell your personal data to other organisations for their own purposes.
7. Purposes for which we process personal data
We process your personal data to support the School’s operation as an independent preparatory school for children aged 3-11, and in particular for:
- The selection and admission of pupils;
- The provision of education to pupils including the administration of the school curriculum and timetable; monitoring pupil progress and educational needs; reporting on the same internally and to parents; administration of pupils’ entries to public examinations, reporting upon and publishing the results; providing references for pupils (including after a pupil has left);
- The provision of educational support and related services to pupils (and parents) including the maintenance of discipline; provision of library services; administration of sports fixtures and teams, school trips; provision of the school’s IT and communications system and learning environment (and monitoring the same) all in accordance with our IT policies;
- The safeguarding of pupils’ welfare and provision of pastoral care, welfare, health care services by school staff;
- Compliance with legislation and regulation including the preparation of information for inspections by the Independent Schools Inspectorate, submission of annual census information to each of the Independent Schools Council and Department for Education;
- Operational management including the compilation of pupil records; the administration of invoices, fees and accounts; the management of the College’s property; the management of security and safety arrangements (including the use of CCTV in accordance with our CCTV Policies and monitoring of the school’s IT and communications systems in accordance with our Acceptable Use Policy); management planning and forecasting; research and statistical analysis; the administration and implementation of the School’s rules and policies for pupils and staff; the maintenance of historic archives and other operational purposes;
- Staff administration including the recruitment of staff/ engagement of contractors (including compliance with DBS procedures); administration of payroll, pensions and sick leave; review and appraisal of staff performance; conduct of any grievance, capability or disciplinary procedures; and the maintenance of appropriate human resources records for current and former staff; and providing references;
- The promotion of the School through its own websites, the prospectus and other publications and communications (including through our social media channels);
- Maintaining relationships with alumni pupils and the wider school community by communicating with the body of current and former pupils and/or their parents or guardians and organising events;
- Monitoring (as appropriate) the use of the school's IT and communications systems in accordance with the school's E Safety policy;
- Use of photographic images of pupils in school publications, on the school website and (where appropriate) on the school's social media channels in accordance with the school's policy on taking, storing and using images of children;
- Security management, including CCTV in accordance with the school’s CCTV policy;
- Provision of educational services in the context of any special educational needs of a pupil;
- Support of spiritual education in the context of any religious beliefs.
The processing set out above is carried out to fulfil our legal obligations (including those under our parent contract and staff employment contracts). We also expect these purposes to form our legitimate interests.
8. Keeping in touch
We keep in touch with alumni pupils, current or former parents or other members of the school community. We will use your contact details to keep you updated about our activities and invite you to events of interest by email and by post. We ask you to let us know your data preferences so that we can ensure our communications are relevant to you. You can update your data preferences at any time. Your data preferences will not affect our contact with you as a current parent.
9. How long we keep personal data
We retain personal data only for a legitimate and lawful reason and only for so long as necessary or required by law. We have a Data Retention Policy which sets out the time period for which different categories of data are kept.
However incident reports and safeguarding files will be kept much longer, in accordance with specific legal requirements. The Independent Inquiry on Child Sexual Abuse has issued retention instructions requesting the preservation of all records relating to the care of children so that they remain available for inspection by the Inquiry. Under Section 21 of the Inquiries Act 2005, the Inquiry has the power to order the production of documents. Failure to comply with such an order without reasonable excuse is an offence punishable by imprisonment (Section 35 of the Inquiries Act 2005).
It is also an offence for a person, during the course of an Inquiry, to destroy, alter or tamper with evidence that may be relevant to an Inquiry, or deliberately to do an act with the intention of suppressing evidence or preventing it being disclosed to the Inquiry. The School therefore has an obligation to preserve records for the Inquiry for as long as necessary to assist the Inquiry.
If you have any specific queries about our record retention periods or wish to request that your personal data is considered for erasure, please contact the School Secretary on 01708 740381.
10. Your rights
You have various rights under Data Protection Law to access and understand the personal data we hold about you, and in some cases to ask for it to be erased or amended or for us to stop processing it, but subject to certain exemptions and limitations.
You always have the right to withdraw consent, where given, or otherwise object to receiving generic or fundraising communications. Please be aware however that the school may have another lawful reason to process the personal data in question even without your consent. That reason will usually have been asserted under this Privacy Notice or may exist under some form of contract or agreement with you (e.g. an employment or parent contract, or because a purchase of goods or services).
If you would like to access or amend your personal data or would like it to be transferred to another person or organisation or have some other objection to how your personal data is used, please make your request in writing to the Chief Privacy Officer.
We will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is one month in the case of requests for access to information. We will be better able to respond quickly to smaller, targeted requests for information. If the request is manifestly excessive or similar to previous requests, we may ask you to reconsider or charge a proportionate fee, but only where Data Protection Law allows it.
You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal privilege. We are also not required to disclose any pupil examination scripts, nor any confidential reference given by the school for the purposes of the education, training or employment of any individual.
11. Pupil data
The rights under Data Protection legislation belong to the individual to whom the data relates. However, we will often rely on parental consent to process personal data relating to pupils (if consent is required) unless, given the nature of the processing in question, and the pupil's age and understanding, it is more appropriate to rely on the pupil's consent.
Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances.
In general, we will assume that pupils’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare, unless, in the school's opinion, there is a good reason to do otherwise.
However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example, where the school believes disclosure will be in the best interests of the pupil or other pupils or is required by law.
Pupils can make subject access requests for their own personal data, provided that they have sufficient maturity to understand the request they are making. Our pupils are generally assumed not to have this level of maturity being under the age of 13. A person with parental responsibility will generally be entitled to make a subject access request on behalf of pupils, but the information in question is always considered to be the child’s at law. A pupil of any age may ask a parent or other representative to make a subject access request on their behalf. Moreover (if of sufficient maturity) their consent or authority may need to be sought by the parent making such a request.
12. Change of details
We try to ensure that all personal data held in relation to you/your child is as up to date and accurate as possible. Please notify the School Secretary via firstname.lastname@example.org of any significant changes to important information, such as contact details, held about you.
13. This notice
Our privacy notice should be read in conjunction with our other policies and terms and conditions which make reference to personal data, including our Parent Contract, our Safeguarding Policy, Health & Safety Policies, Acceptable Use Policies and IT Policies.
We will update this Privacy Notice from time to time. Any substantial changes that affect how we process your personal data will be notified on our website and to you directly, as far as practicable.
If you believe that we have not complied with this policy or have acted otherwise than in accordance with Data Protection Law, you should notify the Chief Privacy Officer and follow the school’s Complaints Procedure.
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with us before involving them.
14. Relevant legislation
This Privacy Notice is covered by the relevant Data Protection Legislation, as follows: