HOW WE USE YOUR PERSONAL DATA AND SCHOOL WORKFORCE INFORMATION
For those employed or otherwise engaged to work at a school or the Local Authority

 

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 with to work at our school.

We, Grange Park School, Borough Green Road, Wrotham, Kent, TN15 7RD, are the ‘data controller’ for the purposes of data protection law.

Our Data Protection Officers are James Stone and Babatunde Adegbenjo and our Data Protection Lead is Zoe McNally (see ‘Contact us’ below).

We process data relating to those we employ, or otherwise engage with 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:

• personal information (such as name, contact details, date of birth, gender, marital status, employee or teacher number and national insurance number)

• next of kin and emergency contact numbers

• special categories of data including characteristics information such as gender, age, ethnic group

• contract information (such as start dates, hours worked, post, roles, salary information bank account details, payroll records and tax status information) 

• work absence information (such as number of absences and reasons)

• 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, where relevant, subjects taught) and employment records, including work history, job titles, working hours, training records and professional membership

• performance information

• outcomes of any disciplinary and/or grievance procedures

• absence data

• photographs / CCTV footage

• data about your use of the school’s information and communications systems

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 part of our safeguarding obligations towards pupils

• support effective performance management

• inform our recruitment and retention policies

• allow better financial modelling and planning

• enable the development of a comprehensive picture of the workforce and how it is deployed

• enable ethnicity and disability monitoring

• improve the management of workforce data across the sector

• support the work of the School Teachers’ Review Body

 

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 process this information under:

• Article 6(1)(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

• Article 9(2)(b) processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

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 Information Management Toolkit for Schools.

A copy of the Toolkit is available at:

http://www.kelsi.org.uk/school-management/data-and-reporting/access-to-information/records-management

 

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 (DfE)

We are required to share information about our school employees with our local authority (LA) and the Department for Education (DfE) under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and amendments.

• your family or representatives

• educators and examining bodies

• our regulator [e.g. 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

• our auditors

• survey and research organisations

• trade unions and associations

• health authorities

• security organisations

• health and social welfare organisations

• professional advisers and consultants

• charities and voluntary organisations

• 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 Lead.

 

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 Lead.

 

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 Lead.

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, in the first instance please contact our:

 

Data Protection Lead:

• Zoe McNally, Business Manager

zoe.mcnally@grangepark.kent.sch.uk

 

Data Protection Officers are:

• James Stone and Babatunde Adegbenjo

sps-dpo-services@isystemsintegration.com

 

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.