Privacy Notice
Introduction
You have a legal right to be informed about how the Trust uses any personal information that we hold about you. To comply with this, we provide a ‘privacy notice’ to you where we are processing your personal data.
This notice explains how we collect, store and use personal data about pupils at our school.
Our Trust, The Girls’ Learning Trust, Ewell Road, Cheam, Sutton, SM3 8AB, is the ‘data controller’ for the purposes of UK data protection law.
The Personal Data We Hold
This privacy notice explains how and why we collect personal data from the following groups: Pupils, Parents and Carers, Employees, Job Applicants, Visitors, Contractors, Suppliers, Alumni and Trustees and Governors.
A) Pupils
We hold personal information about you to enable you to learn and keep you safe at school. For the same reasons, we get information about you from some other places too – like other schools, the local council and the government.
Personal information that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Your contact details
- Your test results
- Your attendance records
- Details of any behaviour issues or exclusions
We use the data listed above to:
- Get in touch with you and your parents when we need to
- Check how you’re doing in exams and work out whether you or your teachers need any extra help
- Track how well the school as a whole is performing
- Look after your wellbeing
B) Parents and Carers
We hold personal information about you to support our functions of running our schools, including:
- Contact details and contact preferences (such as your name, address, email address and telephone numbers)
- Bank details
- Details of your family circumstances
- Details of any safeguarding information including court orders or professional involvement
- Records of your correspondence and contact with us
- Details of any complaints you have made
We use the data listed above to:
- Report to you on your child’s attainment and progress
- Keep you informed about the running of the school (such as emergency closures) and events
- Process payments for school services and clubs
- Provide appropriate pastoral care
- Protect pupil welfare
- Administer admissions waiting lists
- Assess the quality of our services
- Carry out research
- Comply with our legal and statutory obligations
C) Employees
We hold information about you to facilitate your employment, including:
- 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
- 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
We may also collect, use, store and share (when appropriate) information about you that falls into "special categories" of more sensitive personal data. This includes, but is not restricted to, information about:
- Any health conditions you have that we need to be aware of
- Sickness records
- Photographs and CCTV images captured in school
- Trade union membership
We may also collect, use, store and share (when appropriate) information about criminal convictions and offences.
We may also hold data about you that we have received from other organisations, including other schools and social services, and the Disclosure and Barring Service in respect of criminal offence data.
D) Job Applicants
We may collect, hold, share and otherwise use the following information about you during your application process.
Up to and including shortlisting stage:
- your name and contact details (i.e. address, home and mobile phone numbers, email address);
- details of your qualifications, training, experience, duties, employment history (including job titles, salary, relevant dates and working hours), details of driving licence (if relevant for role), membership of professional bodies and interests;
- your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- information regarding your criminal record;
- details of your referees;
- whether you are related to any member of our workforce; and
- details of any support or assistance you may need to assist you at the interview because of a disability.
Following shortlisting stage, and prior to making a final decision
- information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;*
- confirmation of your academic and professional qualifications (including seeing a copy of certificates);*
- information via the DBS process, regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs), whether you are barred from working in regulated activity;*
- your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;*
- medical check to indicate fitness to work;*
- a report on your social media presence;*
- a copy of your driving licence (or other appropriate documentation as listed on the Home Office list);*
If you are a teacher, we will check the National College of Teaching and Leadership (“NCTL”) Teachers Services about your teacher status, whether you are subject to a prohibition from teaching order and any other relevant checks (for example Section 128 direction for management posts and EEA teacher sanctions);* and
- equal opportunities’ monitoring data.
You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked (*) above to us to enable us to verify your right to work and suitability for the position. Without providing us with this information, or if the information is not satisfactory, then we will not be able to proceed with any offer of employment.
If you are employed by us, the information we collect may be included on our Single Central Record. In this scenario, a further privacy notice in relation to data we collect, process, hold and share about you during your time with us, will be issued to you.
E) Visitors
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Name
- Contact details
- Information relating to the visit, e.g. company or organisation name, arrival and departure time, car number plate
We may also collect, use, store and share (when appropriate) information about you that falls into "special categories" of more sensitive personal data. This includes, but is not restricted to:
- Information about any access arrangements that may be required
We use the data listed above to:
- Identify you and keep you safe while on the school site
- Keep pupils and staff safe
- Maintain accurate records of visits to the school
- Provide appropriate access arrangements
We may also hold data about you that we have received from other organisations, including other schools and social services.
F) Contractors and Suppliers
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Names, characteristics and contact details
- References, CVs and details of an individual’s employment history, if collected as part of a bidding, tendering or engagement process
- Bank details and other financial information where it relates to an individual, such as if you’re operating as a sole trader
- Any other personal information necessary to fulfil the terms of a contract we have with you
Information relating to visits to the school, e.g. the individual’s company or organisation name, arrival and departure time, car number plate
If our contract with you requires you to visit or carry out any work at the school site, our privacy notice for visitors to the school will also apply.
We use the data listed above to:
- Decide whether to engage you
- Fulfil the terms of our contract with you, including payment
- Keep accurate records of the suppliers that we use
- Identify you while on the school site, and keep all individuals safe
- Keep pupils and staff safe while you are on the school site
- Keep accurate records of visits to the school
G) Alumni
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Name
- Contact details
- Details about your time at the school, including records of your achievements and interests
- Records of contributions you have made to the school since leaving, such as your time, expertise or money
- Records of how you have engaged with our alumni network, including emails you have opened, events attended, mailing lists you have signed up to and any other interactions
- Bank details and other financial information, if you make any payments to the school
- Records associated with Gift Aid claims on donations
H) Trustees and Governors
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Contact details
- References
- Evidence of qualifications
- Employment details
- Information about business and pecuniary interests
We use the data listed above to:
- Establish and maintain effective governance
- Meet statutory obligations for publishing and sharing members’/trustees’ details
- Facilitate safe recruitment, as part of our safeguarding obligations towards pupils
- Undertake equalities monitoring
- Ensure that appropriate access arrangements can be provided for volunteers who require them
Special Category Data
We may also collect, use, store and share (when appropriate) information about you that falls into "special categories" of more sensitive personal data. This includes, but is not restricted to:
- Information about your characteristics, like your ethnic background or any special educational needs
- Information about any medical conditions you have
- Photographs and CCTV images
- Trade Union membership (Workforce only)
Use of your personal data for marketing purposes
Where you have given us consent to do so, we may send you messages by email or text promoting school events, campaigns, charitable causes or services that you might be interested in.
You can take back this consent or ‘opt out’ of receiving these emails and/or texts at any time by clicking on the ‘Unsubscribe’ link at the bottom of any such communication, or by contacting us (see ‘Contact us’ below).
Use of your personal data in automated decision making and profiling
We don’t currently put your personal information through any automated decision making or profiling process. This means we don’t make decisions about you using only computers without any human involvement.
If this changes in the future, we will update this notice in order to explain the processing to you, including your right to object to it.
Our lawful basis for using your data
We will only collect and use your information when the law allows us to. We need to establish a ‘lawful basis’ to do this.
Our lawful bases for processing your personal information for the reasons listed above are:
- In accordance with the ‘public task’ basis – we need to process data to fulfil our statutory function as a school as set out here:
To provide education and to comply with the Education Act 2011
- In accordance with the ‘legal obligation’ basis – we need to process data to meet our responsibilities under law as set out here:
Education Act 2011 and Health and Safety at Work Act 1972
- In accordance with the ‘consent’ basis – we will obtain consent from you to use your child’s personal data
- In accordance with the ‘vital interests’ basis – we will use this personal data in a life-or-death situation
- In accordance with the ‘contract’ basis – we need to process personal data to fulfil a contract with your child or to help them enter into a contract with us
- In accordance with the ‘legitimate interests’ basis – where there’s a minimal privacy impact and we have a compelling reason, including:
To provide a lunch service
Where you’ve provided us with consent to use your information, you may take back this consent at any time. We’ll make this clear when requesting your consent, and explain how you’d go about withdrawing consent if you want to.
Our lawful basis for using special category data
For ‘special category’ data (more sensitive personal information), we only collect and use it when we have both a lawful basis, as set out above, and one of the following conditions for processing as set out in UK data protection law:
- We have obtained your explicit consent to use your information in a certain way
- We need to use your information under employment, social security or social protection law
- We need to protect an individual’s vital interests (i.e. protect your life or someone else’s life), in situations where you’re physically or legally incapable of giving consent
- The information has already been made obviously public by you
- We need to use it to make or defend against legal claims
- We need to use it for reasons of substantial public interest as defined in legislation
- We need to use it for health or social care purposes, and it’s used by, or under the direction of, a professional obliged to confidentiality under law
- We need to use it for public health reasons, and it’s used by, or under the direction of, a professional obliged to confidentiality under law
- We need to use it for archiving purposes, scientific or historical research purposes, or for statistical purposes, and the use is in the public interest
- For criminal offence data, we will only collect and use it when we have both a lawful basis, as set out above, and a condition for processing as set out in UK data protection law. Conditions include:
- We have obtained your consent to use it in a specific way
- We need to protect an individual’s vital interests (i.e. protect your life or someone else’s life), in situations where you’re physically or legally incapable of giving consent
- The data concerned has already been made obviously public by you
- We need to use it as part of legal proceedings, to obtain legal advice, or to make or defend against legal claims
- We need to use it for reasons of substantial public interest as defined in legislation
Collecting this data
While most of the information we collect about you is mandatory, there is some information that can be provided voluntarily.
Whenever we want to collect information from you, we make it clear if you have to give us this information (and if so, what the possible consequences are of not doing that), or if you have a choice.
Most of the data we hold about you will come from you, but we may also hold data about you from:
- Local councils
- Government departments or agencies
- Police forces, courts, tribunals
How we store this data
We keep personal information about you while you’re attending our school. We may also keep it beyond your attendance at our school if this is necessary. Our record retention schedule sets out how long we keep information about pupils.
We have security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We’ll dispose of your personal data securely when we no longer need it.
Who we share data with
We don’t share information about you with any third party without your consent unless the law and our policies allow us to do so.
Where it’s legally required, or necessary (and it complies with UK data protection law), we may share personal information about you with:
- Our local authority London Borough of Sutton – to meet our legal obligations to share certain information with it, such as safeguarding concerns and information about exclusions
- Government departments or agencies
- Our youth support services provider
- Our regulator, Ofsted,
- Suppliers and service providers:
- Catering
- Uniform
- Financial organisations
- Our auditors
- Survey and research organisations
- Health authorities
- Security organisations
- Health and social welfare organisations
- Professional advisers and consultants
- Charities and voluntary organisations
- Police forces, courts, tribunals
- National Pupil Database
We have to provide information about pupils to the Department for Education (a government department) as part of data collections such as the school census. Some of this information is then stored in the National Pupil Database, which is managed by the Department for Education and provides evidence on how schools are performing. This, in turn, supports research.
The database is held electronically so it can easily be turned into statistics. The information it holds is collected securely from schools, local authorities, exam boards and others.
The Department for Education may share information from the database with other organisations, such as organisations that promote children’s education or wellbeing in England. These organisations must agree to strict terms and conditions about how they will use your data.
You can find more information about this on the Department for Education’s webpage on how it collects and shares research data.
You can also contact the Department for Education if you have any questions about the database.
Transferring data internationally
We may share personal information about you with the following international third parties, where different data protection legislation applies. This would normally be in support of a university application or to provide an employment reference.
Where we transfer your personal data to a third-party country or territory, we will do so in accordance with UK data protection law.
In cases where we have to set up safeguarding arrangements to complete this transfer, you can get a copy of these arrangements by contacting us.
Your rights
How to access personal information that we hold about you
You have a right to make a ‘subject access request’ to gain access to personal information that we hold about you.
If you make a subject access request, and if we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding and using 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 (decisions made by a computer or machine, rather than by a person), and any consequences of this
- Give you a copy of the information in an understandable form
You may also have the right for your personal information to be shared with another organisation in certain circumstances.
If you would like to make a request, please contact us (see ‘Contact us’ below).
Your other rights regarding your data
Under UK data protection law, you have certain rights regarding how your personal information is used and kept safe. For example, you have the right to:
- Say that you don’t want your personal information to be used
- Stop it being used to send you marketing materials
- Say that you don’t want it to be used for automated decisions (decisions made by a computer or machine, rather than by a person)
- In some cases, have it corrected if it’s inaccurate
- In some cases, have it deleted or destroyed, or restrict its use
- Withdraw your consent, where you previously provided consent for your personal information to be collected, processed and transferred for a particular reason
- In some cases, be notified of a data breach
- Make a complaint to the Information Commissioner’s Office
- Claim compensation if the data protection rules are broken and this harms you in some way
To exercise any of these rights, please contact us (see ‘Contact us’ below).
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 concern about our data processing, please raise this with us in the first instance by contacting governance@girlslearningtrust.org.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
Report a concern online at https://ico.org.uk/make-a-complaint/
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 us below:
By Post: Girls' Learning Trust, Ewell Road, Cheam, Sutton, Surrey, SM3 8AB, GB
By Telephone: 020 8394 3400
By Email: dataprotection@girlslearningtrust.org
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