Pupil Privacy Notice - Reception to Lower Third (under 13s)
Privacy Notice for Parents of Reception to Lower Third Pupils
How we use your Child’s information
This Notice is to help you understand how and why we collect your child's personal information and what we do with it. Also explained are the decisions that you can make about your child's information. We are giving you this Notice because you are able to exercise your child's data protection rights on their behalf. When your child is older (usually when they reach the age of 13) they will be considered mature enough to exercise their own data protection rights.
If you have any questions about this Notice, please contact us.
What is "personal information"?
Personal information is what identifies your child and is held by us. This includes information such as their date of birth and address as well as things like exam results, medical details and behaviour records. The College may also record your child's religion or ethnic group. CCTV, photos and video recordings of your child are also personal information.
How and why does the College collect and use personal information?
Below are examples of the different ways in which we use personal information and where this comes from. Our primary reason for using your child's information is to provide them with an education.
The admissions forms which you complete provide us with personal information. We also get information from your child, their teachers and other pupils. In the Prep and Senior School, your child's old school also gives us information about them as we need this to teach and care for them. Likewise in the Pre-Prep, if we know of any nursery school your child is attending, we may ask them for a report.
Sometimes we get information from your child's doctor and other professionals where we need this to look after your child. We collect this information to help the College run properly, safely and to let others know what we do. Here are some examples:
- We need to tell appropriate members of staff if your child is allergic to something or has a health issue.
- We might tell your child's teachers if he or she has educational learning needs or requires extra help with some tasks.
- We may need to share information about your child's health and wellbeing with the College Medical Centre or counsellor.
- We use CCTV to make sure the College is safe. CCTV is not used in private areas such as changing rooms.
- We record your child's attendance and if they have time away from the College we record the reason(s) why.
- We may need to report some of your child's information to the government (e.g. the Department for Education). For example, we may need to tell the local authority that your child attends the College or let them know if we have any concerns about your child's welfare.
- When we are inspected by the Independent Schools Inspectorate we may have to share your child's information with them to assist with the inspection.
- If the College receives a complaint or grievance which involves your child we may need to use their information to deal with this appropriately e.g. if you make a complaint or if another parent complains about an issue which involves your child.
- We may need information about any court orders or criminal petitions which relate to your child. This is so that we can safeguard your child's welfare and the wellbeing of other pupils.
- If your child is from another country we have to make sure that they have the right to study in the UK. We might have to provide their information to UK Visas and Immigration.
- Depending on where your child will go when they leave us, we may need to provide their information to other schools and colleges e.g. we may share information about their exam results and provide references. We may need to pass on information which they need to look after your child.
- We may need to share information with the police or our legal advisors if something goes wrong or to help with an inquiry e.g. if one of your child's classmates is injured at the College or if there is a burglary.
- Occasionally we may use consultants, experts and other advisors to assist the College in fulfilling its obligations and to help run the College properly. We might need to share your child's information with them if this is relevant to their work.
- If your child has misbehaved in a serious way, and the police have become involved, we may need to use information about the action taken by the police.
- We may share some information with our insurance company to make sure that we have the insurance cover that we need.
- We may share your child's academic and (where fair) their behaviour records with you or their education guardian so you can support their schooling.
- We will only share your child's information with other people and organisations when we have a good reason to do so. In exceptional circumstances we may need to share it more widely than we would normally.
- We will monitor your child's use of email, the Internet and mobile electronic devices e.g. iPads. This is to check that your child is not misbehaving when using this technology or putting themselves at risk of harm. If you would like more information about this you can read the Acceptable Use of IT and Email Policy.
- We may take photographs or videos of your child at events to use on social media, on our website, in printed or digital adverts (including social media adverts) or in other marketing communications. This helps us show prospective parents and pupils what we provide and to promote the College. We may seek specific consent before using a photograph or video recording of parents and pupils where we consider that the use is more privacy intrusive. We may continue to use these photographs and videos after your child has left the College.
- Sometimes we use photographs and videos for teaching purposes, for example, to record a drama lesson.
- If you have any concerns about us using photographs or videos of your child, please speak to staff in your child’s School Office.
- We publish sports fixtures and other news on the website and put articles and photographs in the local news to tell people about what we have been doing.
- We may keep details of your child's address when they leave so we can send them Old Stortfordian News and find out how they are getting on. Further information on the alumni association can be found on the College website.
- We sometimes use contractors to handle personal information on our behalf. The following are examples:
- IT consultants who might access information about your child when checking the security of our IT network.
- We use third party "cloud computing" services to store some information rather than the information being stored on hard drives located on the College site.
If you have any concerns about any of the above, please ask us.
Our legal grounds for using your information.
This section contains information about the legal basis that we are relying on when handling your child's information as described above. Legitimate interests.
This means that we are using your child's information when this is necessary for our legitimate interests except where the processing is unfair to your child. We rely on legitimate interests for many of the ways in which it uses your child's information. Specifically, the College has a legitimate interest in:
- Providing your child (and other children) with an education.
- Safeguarding and promoting your child's welfare and the welfare of other children.
- Promoting the objects and interests of the College. This includes fundraising e.g. if we want to raise money to build new buildings and using photographs of your child in promotional material such as on our website and in the prospectus.
- Facilitating the efficient operation of the College.
- Helping the College comply with its obligations (for example, when it is inspected).
Additionally, your child's personal information may be processed for the legitimate interests of others e.g. we may use information about your child when investigating a complaint made by another pupil.
If you object to us using your child's information where we are relying on our legitimate interests as explained above please speak to us.
Where we need to use your child's information in order to comply with a legal obligation e.g. to report a concern about their wellbeing to Children's Services. We may also have to disclose your information to third parties such as the courts, the local authority or the police where legally obliged to do so.
In limited circumstances we may use your child's information to protect their vital interests or the vital interests of someone else (e.g. if your child or they are seriously hurt).
Performance of a task carried out in the public interest
The following are examples of when we use your information to perform tasks in the public interest:
• Providing your child with an education.
• Safeguarding and promoting your child’s welfare and those of other children.
• Facilitating the efficient operation of the College.
• Ensuring that we comply with all of our legal obligations.
If you object to us using your information when we are relying on this ground, please speak to us.
The College must also comply with an additional condition where it processes special categories of personal information. These special categories include; personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information, health information, and information about sex life or orientation.
Substantial public interest
We are allowed to use special categories of personal information where doing so is necessary in the substantial public interest. This is similar to "public interest" above e.g. we may use special categories of information about your child to provide them with an education, to look after them and their classmates or when the College is inspected.
Employment and social protection law
There may be times when we need to use your child's information because we are an employer. Also the College may use their information to comply with social protection law (e.g. to look after your child).
In limited circumstances we may use your child's information to protect their vital interests or the vital interests of someone else (e.g. if they are seriously hurt).
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.
This includes medical treatment and the management of healthcare services.
We may ask for your consent to use your child's information in certain ways. If we ask for your consent to use your child's personal information you can take it back at any time. Any use of your child's information before you withdraw your consent remains valid. Please speak to us if you would like to withdraw any consent given.
In some cases we will rely on more than one of the grounds above for a particular use of your child's information e.g. we may rely on legitimate interests and public interest grounds when using your child's information for safeguarding purposes.
Sending information to other countries
We may send your child's information to countries which do not have the same level of protection for personal information as in the UK. For example, we may;
- store your child's information on cloud computer storage based overseas; or
- communicate with you about your child by email when you are overseas (for example, when you are on holiday).
The EU has produced a list of countries which have adequate data protection rules. The list can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. If the country that we are sending your child's information to is not on the list, or is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland), then it might not have the same level of protection for personal information as the UK.
We will provide you with details about the safeguards which we have in place outside of this Privacy Notice. If you have any questions about the safeguards that are in place please ask us.
For how long do we keep your child's information?
We keep your child's information for as long as we need to in order to educate and look after them. We will keep certain information after your child has left the College e.g. so that we can find out what happened if you make a complaint.
In exceptional circumstances we may keep your child's information for a longer time than usual, but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.
We can keep information about your child for a long time or even indefinitely if we need this for historical, research or statistical purposes e.g. if we consider the information might be useful if someone wanted to write a book about the College. This table shows for how long we keep different types of information about your child.
Type of information
Normal retention period or the criteria used to determine the retention period
Accidental and medical treatment records:
Date of birth plus 25 years.
10 years from last entry and then 25 years from date of birth.
25 years from pupil leaving.
Type of information
Normal retention period or the criteria used to determine the retention period
Student files e.g. reports, performance:
25 years from date of birth.
Educational Learning Needs records:
Date of birth plus up to 35 years.
UK Visa records:
25 years from date of birth.
25 years and then reviewed.
What decisions can you make about your child's information?
From May 2018 you will be able to make various decisions about your child's information. Some of these are new whilst others build on existing rights. Your child's rights are as follows:
- If information is incorrect you can ask us to correct it.
- You can also ask what information we hold about your child and be provided with a copy. We will also give you extra information, such as why we use this information about your child, where it came from and what types of people we have sent it to.
- You can ask us to delete the information that we hold in certain circumstances e.g. where we no longer need the information.
- You can ask us to send you, or another organisation, certain types of information about your child in a format that can be read by computer.
- Our use of information about your child may be restricted in some cases. For example, if you tell us that the information is inaccurate, we can only use it for limited purposes while we check its accuracy.
This Notice is to explain how we look after your child's personal information.
Further information and guidance
Please speak to us if;
- you object to us using your child's information for marketing purposes e.g. to send your child information about school events. We will stop using their information for marketing purposes if you tell us not to;
- you would like us to update the information we hold about your child; or
- you would prefer that certain information is kept confidential.
The Assistant Bursar is the Data Protection Lead at the College for managing how we look after personal information and can answer any questions which you may have about how we use your personal information. You can contact us at firstname.lastname@example.org
If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office – ico.org.uk.