Wynstones / Privacy Policy

Privacy Policy

W024 Version: 1.0

Board of Trustees Approved: December 2020

Date of next review: December 2021

Contents

Privacy notice for Parents/Carers
Privacy notice for Students
Privacy notice for Staff
Privacy notice for Volunteers

1. Privacy notice for parents/carers

Under data protection law, individuals have a right to be informed about how the school 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 policy explains how we collect, store and use personal data about Students and their families. Wynstones is the ‘data controller’ for the purposes of data protection law.

The personal data we hold

Personal data that we may collect, use, store and share (when appropriate) about Students includes, but is not restricted to:

Contact details, contact preferences, date of birth, identification documents Results of internal assessments and externally set tests
Student and curricular records
Characteristics, such as ethnic background, 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
Banking details and financial information

We may also hold data about Students that we have received from other organisations, including other schools, local authorities and the Department for Education.

Why we use this data

We use this data to:

Support Student learning
Monitor and report on Student progress
Provide appropriate pastoral care
Protect Student welfare
Assess the quality of our services
Administer admissions waiting lists
Carry out research
Comply with the law regarding data sharing

Our legal basis for using this data

We only collect and use Students’ 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
Less commonly, we may also process Students’ 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Where we have obtained consent to use Students’ personal data, this consent can be withdrawn at any time.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 Students’ personal data overlap, and there may be several grounds which justify our use of this data.

Collecting this information

While the majority of information we collect about Students 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 Students while they are attending our school. We will also keep it beyond their attendance at our school if this is necessary in order to comply with our legal obligations.

For prospective Students and their families, who have applied to but are not admitted to the school we will only hold your data for a maximum of one year should you wish to reapply during that time.

Our data retention schedule sets out how long we keep information about Students. This is available on request.

Data sharing

We do not share information about Students 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 Students with:

Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
The Department for Education – for various Census information detailed below and in regards to safeguarding and school attendance.
The Student’s family and representatives – when requested
Educators and examining bodies – to register Students for external examinations and obtain/publish their results
Our regulator [specify as appropriate, e.g. Ofsted, School Inspection Service, Charities Commission)
Suppliers and service providers – to enable them to provide the service we have contracted them for Financial organisations – for the collection of school fees
Central and local government
Our auditors – upon inspection Health authorities –
Health and social welfare organisations – when reporting incidents, accidents
Professional advisers and consultants
Police forces, courts, tribunals – upon request
Professional bodies
School Management System – Providers

National Student Database

We are required to provide information about Students to the Department for Education as part of statutory data collections such as the School Census, the Early Years Census, Additional Provision Census and when reporting Children Missing in Education

Some of this information is then stored in the National Student Database (NPD), which is owned and managed by the Department and provides evidence on school 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 schools, local authorities and exam boards.

The Department for Education may share information from the NPD with other organisations 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.

Parents and Students’ rights regarding personal data

Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school 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 13), 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 school 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 the Director of Finance and Resources via email at awelsh@wynstones.com

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 the Director of Finance and Resources via email at awelsh@wynstones.com

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.

To make a complaint, please contact the Director of Finance and Resources via email at awelsh@wynstones.com

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 the Director of Finance and Resources via email at awelsh@wynstones.com

2. Privacy notice for Students

You have a legal right to be informed about how our school 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 privacy notice explains how we collect, store and use personal data about you. Wynstones is the ‘data controller’ for the purposes of data protection law.

The personal data we hold

We hold some personal information about you to make sure we can help you learn and look after you 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.

This information includes:

Your contact details
Your test results
Your attendance records
Your characteristics, like your ethnic background or any special educational needs
Any medical conditions you have
Details of any behaviour issues or exclusions
Photographs
CCTV images

Why we use this data

We use this data to help run the school, including 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

Our legal basis for using this data

We will only collect and use your information when the law allows us to. Most often, we will use your information where:

We need to comply with the law
We need to use it to carry out a task in the public interest (in order to provide you with an education)

Sometimes, we may also use your personal information where:

You, or your parents/carers have given us permission to use it in a certain way
We need to protect your interests (or someone else’s interest)

Where we have got permission to use your data, you or your parents/carers may withdraw this at any time. We will make this clear when we ask for permission, and explain how to go about withdrawing consent.

Some of the reasons listed above for collecting and using your information overlap, and there may be several grounds which mean we can use your data.

Collecting this information

While in most cases you, or your parents/carers, must provide the personal information we need to collect, there are some occasions when you can choose whether or not to provide the data.

We will always tell you if it’s optional. If you must provide the data, we will explain why it is needed what might happen if you don’t. (ie: if we don’t have you email address we can’t keep you informed about school trips)

How we store this data

We will keep personal information about you while you are a Student at our school. We may also keep it after you have left the school, where we are required to by law.

We have a record retention schedule which sets out how long we must keep information about Students.

Data sharing

We do not share personal information about you with anyone outside the school without permission from you or your parents/carers, unless the law and our policies allow us to do so.

Where it is legally required, or necessary for another reason allowed under data protection law, we may share personal information about you with:

Our local authority – to meet our legal duties to share certain information with it, such as concerns about Students’ safety and exclusions
The Department for Education (a government department)
Your family and representatives
Educators and examining bodies
Our regulator (the organisation or “watchdog” that supervises us), (e.g. Ofsted, School’s Inspection Service]
Suppliers and service providers – so that they can provide the services we have contracted them for
Financial organisations
Central and local government
Our auditors
Survey and research organisations
Health authorities
Security organisations
Health and social welfare organisations
Professional advisors and consultants
Charities and voluntary organisations
Police forces, courts and tribunals
Professional bodies
School Management System Providers

National Student Database

We are required to provide information about you 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 Student 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 which 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

Where we share data with an organisation that is based outside the European Economic Area, we will protect your data by following data protection law.

Your rights

How to access personal information we hold about you

You can find out if we hold any personal information about you, and how we use it, by making a ‘subject access request’, as long as we judge that you can properly understand your rights and what they mean.

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 or your parents
Tell you who it has been, or will be, shared with
Let you know if we are using your data to make any automated decisions (decisions being taken by a computer or machine, rather than by a person)
Give you a copy of the information

You may also ask us to send your personal information to another organisation electronically in certain circumstances.

If you want to make a request please contact the Director of Finance and Resources via email at awelsh@wynstones.com

Your other rights over your data

You have other rights over how your personal data is used and kept safe, including the right to:

Say that you don’t want it to be used if this would cause, or is causing, harm or distress.
Stop it being used to send you marketing materials
Say that you don’t want it used to make automated decisions(decisions made by a computer or machine, rather than by a person)
Have it corrected, deleted or destroyed if it is wrong, or restrict our use of it
Claim compensation if the data protection rules are broken and this harms you in some way

Complaints

We take any complaints about how we collect and use your personal data very seriously, so please let us know if you think we’ve done something wrong.

You can make a complaint at any time by contacting the Director of Finance and Resources via email at awelsh@wynstones.com

You can also complain to the Information Commissioner’s Office in one of the following ways:

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

This notice is based on the Department for Education’s model privacy notice for Students, amended to reflect the way we use data in this school.

3. Privacy notice for staff

This privacy notice explains how we collect, store and use personal data about individuals we employ, or otherwise engage, to work at our school.

Wynstones is the ‘data controller’ for the purposes of data protection law.

The personal data we hold

We process data relating to those we employ, or otherwise engage, to work at our school. 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
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 and other forms ID provided by you for the purpose of obtaining per-employment vetting checks
Photographs
Data about your use of the school’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
Trade union membership
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 school, including to:

Enable you to be paid
Facilitate safe recruitment, as part of our safeguarding obligations towards Students
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 sector

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)

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 school’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 canchoose whether or not to provide to us.

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 our record retention schedule.

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:

Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and [maintained schools only] information about headteacher performance and staff dismissals
The Department for Education Your family or representatives Educators and examining bodies
Our regulator [e.g. Ofsted, Independent Schools Inspection Service]
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
Medical declarations (including right to contact doctors)
School Management System Providers

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

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 school holds about them.

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 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 the Director of Finance and Resources via email at awelsh@wynstones.com

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 via email to the Director of Finance and Resources via email at awelsh@wynstones.com

To exercise any of these rights, please contact the Director of Finance and Resources via email at awelsh@wynstones.com

Complaints

We take any complaints about our collection and use of personal information very seriously.

To make a complaint, please contact the Director of Finance and Resources via email at awelsh@wynstones.com

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

4. Privacy notice for Volunteers

This privacy notice explains how we collect, store and use personal data about individuals we employ, or otherwise engage, to work at our school.

Wynstones is the ‘data controller’ for the purposes of data protection law.

The personal data we hold

We process data relating to those that we have on our volunteer database. 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
Recruitment information, including copies of right to work documentation, references and other information included in your application form.
Copy of driving licence and other forms of ID provided by you for the purpose of obtaining pre-volunteering vetting checks

Why we use this data

The purpose of processing this data is to help us run the school, including to:

Facilitate safe recruitment of volunteers , as part of our safeguarding obligations towards Students

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)

Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the school’s use of your data.

Collecting this information

How we store this data

We create and maintain a Volunteer file for each staff member. The information contained in this file is kept secure and is only used for purposes directly relevant to your volunteer status.

Your data is also stored on our Single Central Register which is a legal obligation and is subject to inspection periodically by Council members and our regulator [e.g. Ofsted, Independent Schools Inspection Service]

Once you’re volunteering with us has ended, we will retain this file and delete the information in it in accordance with our record retention schedule.

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 personalinformation about you with:

Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns
The Department for Education
Our regulator [e.g. Ofsted, Independent Schools Inspection Service]
Central and local government
Police forces, courts, tribunals
Professional bodies

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

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 school holds about them.

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 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 the Director of Finance and Resources via email at awelsh@wynstones.com

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 the Director of Finance and Resources via email at awelsh@wynstones.com

Complaints

We take any complaints about our collection and use of personal information very seriously.

To make a complaint, please contact the Director of Finance and Resources via email at awelsh@wynstones.com

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