The Granville

WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA 

In order to carry out its ordinary duties to pupils and parents, the school needs to process a wide range of personal data about individuals (including current, past and prospective pupils or parents) as part of its daily operation. 

Some of this activity the school will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with parents of its pupils. 

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.  

The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:  

• For the purposes of pupil selection, to confirm the identity of prospective pupils and their parents, and retain a record if appropriate for the purposes of future applications or openings; 

• To provide education services, including musical education, physical training or spiritual development, career services, and extra-curricular activities to pupils, and monitoring pupils' progress and educational needs, including where such services are provided remotely (either temporarily or permanently)   

• Maintaining relationships with alumni and the school community, including direct marketing or fundraising activity; 

• For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests;  

• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis); 

• To enable relevant authorities to monitor the school's performance and to intervene or assist with incidents as appropriate; 

• To give and receive information and references about past and current pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils; 

• To enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the school; 

• To safeguard pupils' health and welfare and provide appropriate pastoral care; 

• To monitor (as appropriate) use of the school's IT and communications systems in accordance with the school's IT: acceptable use policy; 

• To make use of photographic images of pupils in school publications, on the school website and (where appropriate) and with specific consent on the school's social media channels in accordance with the school's policy on taking, storing and using images of children; 

• For security purposes, including biometrics (where applicable) and CCTV in accordance with the school’s CCTV policy;  

• For regulatory record keeping / compliance purposes in respect of immigration requirements, as an employer and/or visa sponsor where applicable;  

• To carry out or cooperate with any school or external complaints, disciplinary or investigation process; and 

• Where otherwise reasonably necessary for the school's purposes, including to obtain appropriate professional advice and insurance for the school. 

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: 

• To safeguard pupils' welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition or other relevant information where it is in the individual's interests to do so: for example for medical advice, for social protection, safeguarding, and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs; 

• To comply with public health requirements in respect of any pandemic, local, regional or national virus outbreak (or similar) testing: including managing on-site testing and/or processing the results of tests taken by pupils or other members of the School community, and sharing this information with relevant health authorities;  

• To provide educational services in the context of any special educational needs of a pupil; 

• To run any of its systems that operate on biometric data, such as for security and other forms of pupil identification (lockers, lunch etc.);  

• As part of any school or external complaints, disciplinary or investigation process that involves such data, for example if there are SEND, health or safeguarding elements; or 

• For legal and regulatory purposes (for example child protection, diversity monitoring, health and safety and immigration / visa sponsorship compliance) and to comply with its legal obligations and duties of care. 

TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL 

This will include by way of example:  

• names, addresses, telephone numbers, e-mail addresses and other contact details; 

• car details about those who use our car parking facilities;  

• biometric information, which will be collected and used by the school in accordance with the school's biometrics policy where applicable. 

• bank details and other financial information, e.g. about parents (or others) who pay fees to the school, and any anti-money laundering information we are required to collect by law; 

• past, present and prospective pupils' academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks; 

• nationality and other immigration status information (eg right to work / study), including copies of passport information; 

• where appropriate, information about individuals' health and welfare, and contact details for their next of kin; 

• references given or received by the school about pupils, and relevant information provided by previous educational establishments and/or other professionals or organisations working with pupils;  

• correspondence with and concerning pupils and parents (past and present); and 

• images of pupils (and occasionally other individuals) engaging in school activities, and images captured by the school's CCTV system (in accordance with the school's policy on taking, storing and using images of children); 

HOW THE SCHOOL COLLECTS DATA 

Generally, the school receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply 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); or collected from publicly available resources. 

WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT WITH 

Processing by third parties.  

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). However, some functions are outsourced including IT, cloud storage / records management, monitoring, mailing. In accordance with Data Protection Law, this type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with the school’s specific directions.  

Data sharing. Occasionally, the school – including its trustees / governing board – will need to share personal information relating to its community of staff, pupils and parents with third parties, such as: 

• the school’s parent association (FOG). 

• appropriate contractors, such as visiting music teachers;  

• professional advisers (e.g. lawyers, insurers, PR advisers and accountants); 

• examination boards; 

• Stage 3 complaints panels, which will include independent panel members;  

• third parties and their advisers in the event of a possible or actual sale, merger or other restructuring of the school; and 

• government authorities (e.g. ISI, DfE, CAFCASS, police, Home Office, a relevant public health / NHS body and / or local authority) and/or appropriate regulatory. 

ACCESS TO SENSITIVE DATA 

Particularly strict rules of access apply in the context of “special category” data, most notably: 

• medical records; and 

• pastoral or safeguarding files. 

Medical data: The school needs to process such information to comply with statutory duties and to keep pupils and others safe, but the school will ensure only authorised staff can access information on a need-to-know basis. This may include wider dissemination if needed for school trips or for catering purposes. Express consent will be sought where appropriate. 

However, a certain amount of any SEND pupil’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires.  

Safeguarding data: pupils and parents are reminded that the school is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education or KCSIE September 2023 UPDATE) 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.  

KCSIE also requires that, whenever a child leaves the school to join another school or college, his or her child protection file is promptly provided to the new organisation. The school will retain a copy in accordance with its retention policy for material related to safeguarding matters. 

For further information about this, please view the school’s Safeguarding Policy.  

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. Please see our guidance on document retention in our policy Here. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.  

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 Bursar at bursar@granvilleschool.org. 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 in order to fulfil your wishes (called a "suppression record"). 

KEEPING IN TOUCH AND SUPPORTING THE SCHOOL  

The school and/or any relevant other organisation, e.g. alumni / development 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 will also:  

• Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the school community, such as the Friends of Granville or where applicable a Granville alumni association; 

• Contact parents and/or alumni (including via the organisations above) by post and email in order to promote and raise funds for the school and, where appropriate, other worthy causes; 

• Should you wish to limit or object to any such use, or would like further information about them, please contact the Bursar in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).  

 YOUR RIGHTS 

You have the following rights: 

• to obtain access to, and copies of, the personal data that we hold about you; 

• to require us to correct the personal data we hold about you if it is incorrect; 

• to require us (in certain circumstances) to erase your personal data; 

• to request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal); 

• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; 

• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.  

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. The school will endeavour to respond to any such requests as soon as is reasonably practicable and in any event within statutory time-limits (which is generally one month, but actually fulfilling more complex or multiple requests, e.g. those involving third party information, may take 1-2 months longer). 

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 yours or your child's personal data: for example, a legal requirement, or where it falls within a proportionate legitimate interest identified in this Privacy Notice. Generally, if the school still considers the processing of the personal data to be reasonably necessary, it is entitled to continue. All such requests will be considered on their own merits. 

Requests by or on behalf of pupils 

Pupils 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. A pupil 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 pupils, the law still considers the information in question to be the child’s. For older pupils, the parent making the request may need to evidence their child's authority for the specific request. Requests not considered in the child’s best interests may sometimes be refused.    

Pupils at senior Schools aged e.g. 12/13 and above 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. Younger children may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.  

Parental requests 

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 pupils without their consent. The school may consider there are lawful grounds for sharing with or without reference to that pupil.  

Parents will in general receive educational and pastoral updates about their children, in accordance with the Parent Contract. 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, court orders, or pastoral issues. 

All information requests from, on behalf of, or concerning pupils – whether made under subject access or simply as an incidental request – will therefore be considered on a case by case basis.  

Consent 

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: [e.g. biometrics, certain types of uses of images, 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. parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents' association has been requested).  

DATA ACCURACY AND SECURITY  

The school will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.  Individuals must please notify the Bursar of any significant changes to important 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.  

THIS POLICY