Privacy Notice
1. Introduction
Under UK data protection law, individuals have a right to be informed about how Futures-Essex Ltd 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 parents and carers of pupils at our provision.
We, Futures-Essex Ltd Registered Office: 10 Josephs Barn, Woodend Farm, Hatfield Road, Witham, Essex, England, CM8 1EH Registered Number: 15564318 are the ‘data controller’ for the purposes of UK data protection law.
Our data protection officer is Mr Nicholas Price (see ‘Contact us’ below).
2. The personal data we hold
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
- Contact details and contact preferences (such as your name, address, email address and telephone numbers)
- 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
- Information about your use of our information and communication systems, equipment and facilities (e.g. school computers)
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
- Photographs and CCTV images captured
We may also hold data about you that we have received from other organisations, including other schools and social services.
3. Why we use this data
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 provision (such as emergency closures) and events
- Provide appropriate pastoral care
- Protect pupil welfare
- Assess the quality of our services
- Carry out research
- Comply with our legal and statutory obligations
- Make sure our information and communication systems, equipment and facilities (e.g. computers) are used appropriately, legally and safely
3.1 Use of your personal data for marketing purposes
Where you have given us consent to do so, we may send you marketing information by email or text promoting events, campaigns, charitable causes or services that may be of interest to you.
You can withdraw 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).
3.2 Use of your personal data in automated decision making and profiling
We do not currently process any parents’ or carers’ personal data through automated decision making or profiling. If this changes in the future, we will amend any relevant privacy notices in order to explain the processing to you, including your right to object to it.
3.3 Use of your personal data for filtering and monitoring purposes
While you’re in Futures-Essex Ltd, we may monitor your use of our information and communication systems, equipment and facilities (e.g. computers). We do this so that we can:
- Complying with health and safety and other legal obligations
- Complying with our policies (e.g. child protection policy, IT acceptable use policy) and our legal obligations
- Keep our network(s) and devices safe from unauthorised access, and prevent malicious software from harming our network(s)
4. Our lawful basis for using this data
ICO’s guidance on the lawful basis for processing.
Our lawful bases for processing your personal data for the purposes listed in section 3 above are as follows:
- For the purposes of complying with health and safety and other legal obligations in accordance with the ‘legal obligation’ basis – we need to process data to meet our responsibilities under law as set out here:
- For the purposes of complying with health and safety and other legal obligations in accordance with the ‘consent’ basis – we will obtain consent from you to use your personal data
- For the purposes of complying with our policies (e.g. child protection policy, IT acceptable use policy) and our legal obligations in accordance with the ‘vital interests’ basis – we will use this personal data in a life-or-death situation
- For the purposes of complying with our policies (e.g. child protection policy, IT acceptable use policy) and our legal obligations in accordance with the ‘contract’ basis – we need to process personal data to fulfil a contract with you or to help you enter into a contract with us
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 would go about withdrawing consent if you wish to do so.
4.1 Our basis for using special category data
For ‘special category’ data, we only collect and use it when we have both a lawful basis, as set out above, and 1 of the following conditions for processing as set out in UK data protection law:
- We have obtained your explicit consent to use your personal data in a certain way
- We need to perform or exercise an obligation or right in relation to 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 data concerned has already been made manifestly public by you
- We need to process it for the establishment, exercise or defence of legal claims
- We need to process it for reasons of substantial public interest as defined in legislation
- We need to process it for health or social care purposes, and the processing is done by, or under the direction of, a health or social work professional or by any other person obliged to confidentiality under law
- We need to process it for public health reasons, and the processing is done by, or under the direction of, a health professional or by any other person obliged to confidentiality under law
- We need to process it for archiving purposes, scientific or historical research purposes, or for statistical purposes, and the processing 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 manifestly public by you
- We need to process it for, or in connection with, legal proceedings, to obtain legal advice, or for the establishment, exercise or defence of legal rights
- We need to process it for reasons of substantial public interest as defined in legislation
5. Collecting this data
While the majority of information we collect about you is mandatory, there is some information that can be provided voluntarily.
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.
Most of the data we hold about you will come from you, but we may also hold data about you from:
- Local authorities
- Government departments or agencies
- Your children
- Police forces, courts or tribunals
6. How we store this data
We keep personal information about you while your child is attending Futures-Essex Ltd. We have put in place appropriate security measures to prevent your personal information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We will dispose of your personal data securely when we no longer need it.
7. Who we share data with
We do not share information about you 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 UK data protection law), we may share personal information about you with:
- Our local authority, Essex County Council - to meet our legal obligations to share certain information with it, such as safeguarding concerns and information about exclusions
- Government departments or agencies
- Suppliers and service providers:
- HR, filtering and monitoring
- Financial organisations
- Our auditors / Quality Assurance
- Health authorities
- Security organisations
- Health and social welfare organisations
- Professional advisers and consultants
- Charities and voluntary organisations
- Police forces, courts, tribunals
7.1 Transferring data internationally
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 must set up safeguarding arrangements to complete this transfer, you can get a copy of these arrangements by contacting us.
8. Your rights
8.1 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 (subject to any exemptions that may apply):
- 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 us (see ‘Contact us’ below).
8.2 Your other rights regarding your data
Under data protection law, you have certain rights regarding how your personal data is used and kept safe. For example, you have the right to:
- Object to our use of your personal data
- Prevent your data being used to send direct marketing
- Object to and challenge 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
- In certain circumstances, have the personal data we hold about you deleted or destroyed, or restrict its processing
- Withdraw your consent, where you previously provided it for the collection, processing and transfer of your personal data for a specific purpose
- In certain circumstances, be notified of a data breach
- Make a complaint to the Information Commissioner’s Office
- Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact us (see ‘Contact us’ below).
9. 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.
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
10. Contact us
If you have any questions or concerns, or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:
- Mr Nicholas Price. Email: nsp@futures-essex.co.uk. Telephone: 01245982888
However, our data protection lead has day-to-day responsibility for data protection issues in our school.
If you have any questions or concerns, or would like more information about anything mentioned in this privacy notice, please contact them:
- Mrs Lauren Collin. Email: lauren.collin@futures-essex.co.uk Telephone: 01245982888