WHO WE ARE
Reddam House Berkshire is registered as Reddam House (Berkshire) Limited, Bearwood Road, Wokingham, Berkshire, RG41 5BG.
It is part of the Inspired Education Group, Meadows House, 20-22 Queen Street, London, W1 5PR.
Reddam House Berkshire takes data protection, and our responsibility to correctly and lawfully treat personal data as a data controller seriously. We are committed to complying with legal obligations and practising industry standards when collecting, processing and storing personal data. Reddam House Privacy Notice – Last Updated May 2018 by TH 3
WHAT THIS PRIVACY NOTICE IS FOR
This policy is intended to provide information about how the school will use (or "process") personal data about individuals including its staff; its current, past and prospective students; and their parents, carers or guardians (referred to in this policy as "parents").
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents and students 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 the school may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to the school's other relevant terms and conditions and policies, including:
Anyone who works for, or acts on behalf of, the school (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice, which also provides further information about how personal data about those individuals will be used.
RESPONSIBILITY FOR DATA PROTECTION
The School has appointed a Data and Compliance Officer who 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 policy and Data Protection Law.
WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA
To carry out its ordinary duties to staff, students and parents, the school needs to process a wide range of personal data about individuals (including current, past and prospective staff, students or parents) as part of its daily operation.
Some of this activity the school will need to carry out to fulfil its legal rights, duties or obligations – including those under a contract with its staff, or parents of its students.
Other uses of personal data will be made in accordance with the school’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals and provided it does not involve special or sensitive types of data. Reddam House Privacy Notice – Last Updated May 2018 by TH 4
The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
In addition, the school will on occasion need to process special category personal data (concerning health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required. These reasons will include:
Reddam House Privacy Notice – Last Updated May 2018 by TH 5
TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL
This will include by way of example:
HOW THE SCHOOL COLLECTS DATA
Generally, the school receives personal data from the individual directly (including, in the case of students, from their parents); this may be via a form, or in the ordinary course of interaction or communication (such as email or written assessments).
However, in some cases, personal data will be supplied by third parties (for example another school, or other professionals or authorities working with that individual).
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT WITH
Occasionally, the school will need to share personal information relating to its community with third parties, such as:
Reddam House Privacy Notice – Last Updated May 2018 by TH 6
For the most part, personal data collected by the school 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:
However, a certain amount of any SEN student’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the student requires.
Staff, students and parents 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 it, 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. This includes, but is not limited to, Record of Concern forms and Neutral notification Forms. For further information about this, please view the school’s Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of the school’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.
HOW LONG WE KEEP PERSONAL DATA
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary staff and student personnel files is up to 7 years following departure from the school. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements from the IICSA. Further details may be found here - iicsa.org.uk.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Data and Compliance Officer on email@example.com or on the school’s main number 01189 748300. However, please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact to fulfil your wishes (called a "suppression record").
More details can be found in the school’s Retention of Records Policy, available on request. Reddam House Privacy Notice – Last Updated May 2018 by TH 7
KEEPING IN TOUCH AND SUPPORTING THE SCHOOL
The school will use the contact details of parents, alumni and other members of the school community to keep them updated about the activities of the school, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, the school may also:
Rights of access
Individuals have various rights under Data Protection Law to access and understand personal data about them held by the school, and in some cases ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it – subject to specific exemptions and limitations.
Any individual wishing to access or amend their personal data or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Data and Compliance Officer.
The school 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).
The school will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the school may ask you to reconsider or require a proportionate fee (but only where Data Protection Law allows it).
Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include your own children, in particular, limited situations – please see further below), or information which is subject to legal privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).
The school is also not required to disclose any student examination scripts (or other information consisting solely of student test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference given by the school itself for the purposes of the education, training or employment of any individual. Reddam House Privacy Notice – Last Updated May 2018 by TH 8
You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
Students can make subject access requests for their own personal data, provided that, in the reasonable opinion of the school, they have sufficient maturity to understand the request they are making (see section Whose Rights? below). A student of any age may ask a parent or other representative to make a subject access request on his/her behalf.
Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of younger students, the law still considers the information in question to be the child’s: for older students, the parent making the request may need to evidence their child's authority for the specific request.
Middle and Senior Students are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Older Junior children may, however, be sufficiently mature to have a say in this decision, depending on the child and the circumstances.
It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about students without their consent. The school may consider there are lawful grounds for sharing with or without reference to that student.
Parents will, in general, receive educational and pastoral updates about their children. Where parents are separated, the school will in most cases aim to provide the same information to each person with parental responsibility but may need to factor in all the circumstances including the express wishes of the child.
All information requests from, on behalf of, or concerning students – whether made under subject access or simply as an incidental request – will, therefore, be considered on a case by case basis.
Where the school is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Examples, where we do rely on consent, are certain types of uses of images (see taking and Storing of Imagesof Children Policy for more details), and certain types of fundraising activity. Please be aware however that the school may not be relying on consent but 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 otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents' association has been requested). Reddam House Privacy Notice – Last Updated May 2018 by TH 9
The rights under Data Protection Law belong to the individual to whom the data relates. However, the school will often rely on parental authority or notice for the necessary ways it processes personal data relating to students – for example, under the parent contract, or via a form. Parents and students should be aware that this is not necessarily the same as the school relying on strict consent (see section on Consent above).
Where consent is required, it may in some cases be necessary or appropriate – given the nature of the processing in question, and the student's age and understanding – to seek the student'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, the school will assume that students’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. to keep parents informed about the student's activities, progress and behaviour, and in the interests of the student's welfare. That is unless, in the school's opinion, there is a good reason to do otherwise.
However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the school may be under an obligation to maintain confidentiality unless, in the school's opinion, there is a good reason to do otherwise; for example where the school believes disclosure will be in the best interests of the student or other students, or if required by law.
Students are required to respect the personal data and privacy of others, and to comply with the school's Acceptable Use Policy, Telephones and Social Media Policy and the school Code of Conduct. Staff are under professional duties to do the same covered under the Acceptable Use Policy and Staff Code of Conduct.
DATA ACCURACY AND SECURITY
The school will endeavour to ensure that all personal data held about an individual is as up to date and accurate as possible. Individuals must please notify the Data and Compliance Officer of any significant changes to relevant information, such as contact details, held about them.
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the school may need to process your data, of who you may contact if you disagree.
The school will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
The school will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable. Reddam House Privacy Notice – Last Updated May 2018 by TH 10
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to the Data and Compliance Officer on firstname.lastname@example.org or 01189 746300.
If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school Complaints procedure (available on the website).
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 the school before involving the regulator.
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