Privacy Policy

This policy has been developed collaboratively by the five schools belonging to the BeSkilled Trust.
It ensures a consistency and compliance across the Trust in how data is stored, managed and
accessed.
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 notice explains how we collect, store and use personal data about pupils.
We, the Schools belonging to the BeSkilled Trust are the ‘data controller’ for the purposes of data protection law.
Our data protection officer will be the Headteacher of each school until a DPO is appointed..
The personal data we hold
Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted
to:
● Contact details, contact preferences, date of birth, identification documents
● Results of internal assessments and externally set tests
● Pupil and curricular records
● Characteristics, such as ethnic background, eligibility for free school meals, 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
● CCTV images captured in school (applies only to schools with CCTV)
We may also hold data about pupils 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 pupil learning
● Monitor and report on pupil progress
● Provide appropriate pastoral care
● Protect pupil 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 pupils’ per
National Pupil Database
We are required to provide information about pupils to the Department for Education as part of statutory data
collections such as the school census.
Some of this information is then stored in the National Pupil 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.
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.
Parents and pupils’ 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 12), 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 our data protection officer.
Parents/carers also have a legal right to access to their child’s educational record. To request access, please contact
the Headteacher of your child’s school.
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 our data protection officer.
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 our data protection officer.
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 our Headteacher until a DPO has been appointed.
● This notice is based on the Department for Education’s model privacy notice for pupils, amended for parents
and to reflect the way we use data in this school.
Privacy notice for pupils
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.
We, the group of schools known as The BeSkilled Trust are the ‘data controller’ for the purposes of data protection
law.
Our data protection officer will be the Headteacher until a DPO has been appointed. (see ‘Contact us’ below).
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 (only applies to schools with CCTV)
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 what might happen if you don’t.
How we store this data
We will keep personal information about you while you are a pupil at our school. We may also keep it after you have
left the school, where we are required to by law.
We have a Retention Schedule, which sets out how long we must keep information about pupils, as an appendix to
the GDPR policy.
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 pupils’
safety and exclusions
● The Department for Education (a government department)
● Your family and representatives
● Educators and examining bodies
● Ofsted
● Central and local government
● Health authorities
● Health and social welfare organisations
● Professional advisers and consultants
● Police forces, courts, tribunals
● Professional bodies
National Pupil 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 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 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 our data protection officer.
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 our data protection officer.
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
● If you have any questions, concerns or would like more information about anything mentioned in this privacy
notice, please contact our Headteacher until a DPO has been appointed.
3. Privacy notice for staff (including volunteers) and governors
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 notice explains how we collect, store and use personal data about individuals we employ, or otherwise
engage, to work at our school.
We, The schools know as the BeSkilled Trust are the ‘data controller’ for the purposes of data protection law.
Our data protection officer will be appointed soon.
The personal data we hold
NB – only the items marked with an asterisk (*) denote data that applies to Governors. 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 and CCTV footage (only schools with CCTV)*
● Copy of driving licence*
● 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
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)
● We have legitimate interests in processing the data.
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 can choose
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
retention schedule, within the GPDR policy (which is available on your school’s website).
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 information about headteacher performance and staff dismissals
● The Department for Education
● Your family or representatives
● Educators and examining bodies
● Ofsted
● 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
● Trade unions and associations
● Health authorities
● Security organisations
● Health and social welfare organisations
● Professional advisers and consultants
● Police forces, courts, tribunals
● Professional bodies
● Employment and recruitment agencies
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 our data protection officer.
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 our data protection officer.
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 our data protection officer.
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 our Headteacher until a DPO has been appointed.
This notice is based on the Department for Education’s model privacy notice for the school workforce, amended to
reflect the way we use data in this school.