Inclusion School:  Website Privacy Notice

We want you to feel confident in the importance we place on the privacy and security of any data shared with us here at Inclusion School. This policy relates to our use and collection of data on website, social media and external communications. For further details on our policies to learner data and staff data, please read the relevant sections on our website.  

‘We’ used throughout this policy refers to Inclusion School, registered as a Data Controller with the ICO reference number: ZA369136

 

Compliance 

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy: 

UK Data Protection Act 1988 (DPA) 

EU Data Protection Directive 1995 (DPD) 

EU General Data Protection Regulation 2018 (GDPR) 

UK GDPR Regulations 

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer for clarification. 

 

Personal information that this website collects and why we collect it 

This website collects and uses personal information for the following reasons: 

 

Website visitor tracking 

This website uses Google Analytics to track visitor interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to understand their journey through the website. 

Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. Google Analytics also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section below). 

Google Analytics also makes use of cookies, details of which can be found on Google’s developer guides. 

Disabling cookies on your internet browser will stop Google Analytics from tracking any part of your visit to pages within this website. 

 

Website Cookies 

Website cookies and link tracking cookies allow us to provide important site functionality. Cookies also allow us to record what links and pages have been clicked or viewed during a session. By using your browser controls, you change how cookies are stored and accessed on your computer. 

 

Communications 

Sometimes we may want to contact you to inform you of news and updates about Inclusion School and our services.  This is via an email newsletter which users can subscribe to via our website. This information is collected and stored using Mailchimp, a third party data processor (see below). All subscribers have given consent via an ‘opt-in’ option and can request to unsubscribe in every mailing.  

 

Our third party data processors 

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant. Please read their privacy policies below:  

Google  

Mailchimp 

PayPal (via our donations button)  

 

Social Media 

Inclusion School have a number of social media accounts – such as Twitter, Facebook, Instagram and Linked In.  Depending on your settings or the privacy policies for social media and messaging services like Facebook or Twitter, you might give us permission to access information from those accounts or services. These are used to better understand the impact and reach of our social media accounts.  

 

Data Breaches 

We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen. 

 

Data Controller 

The data controller of this website is: Inclusion School, CIO number: 1162711  

How to find out more or make a complaint 

To make a formal complaint about Inclusion School’s approach to data protection or your privacy rights please contact: 

Data Protection Officer 

Inclusion Hampshire 

Office 5, The Clock Tower 

Chineham Shopping Centre 

Chineham 

Basingstoke 

RG24 8BQ 

Or call 01256 760 800 

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office (ICO) which regulates and enforces data protection law in the UK.  

The ICO contact details are: 

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

Wilmslow 

Cheshire 

SK9 5AF 

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number. Registration number: Z1843836.  

If you would like more information, or have any questions about this policy, please contact our admin team by email at info@inclusionhampshire.org.uk  

 

Data Protection Officer 

Emma Barnard 

Business Manager 

Telephone: 01256 760 800 

Emma.barnard@inclusionhampshire.org.uk 

Changes to our privacy policy 

This privacy policy may change from time to time in line with legislation. We will not explicitly inform our website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. 

Inclusion School:  Privacy Notice

Under data protection law, individuals have a right to be informed about how Inclusion School uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ to individuals where personal data is being processed.

We use learner information as part of our working partnership with the referring schools and agencies under section 537A of the Education Act 1996, and section 83 of the Children Act 1989. We also comply with Article 6(1)(c) and Article 9(2)(b) of the General Data Protection Regulation (GDPR)

This privacy notice explains how we collect, store and use personal data.

 

Why do we collect and use learner information?

We use the learner data:

  • to support learning
  • to monitor and report on progress
  • to provide appropriate pastoral care
  • to assess the quality of our service
  • to comply with the law regarding data sharing
  • to support in what to do after leaving school

Personal data that we may collect, use, store and share (when appropriate) about learners includes, but is not restricted to:

  • Contact details (including parents / carers), 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

We may also hold data about learners that we have received from other organisations, including your referring school, local authorities and multi agency professionals.

 

Our legal basis for using this data

We only collect and use learners personal data when the law allows us to. Most commonly, we process it:

  • To fulfil the legitimate interest with the referring schools and to enable them to comply with a legal obligation

We may also process learner’s’ personal data in situations where:

  • We have obtained consent
  • We need to protect the individual’s vital interests (or someone else’s interests)

Where we have obtained consent to use learners personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.

Some of the reasons listed above for collecting and using personal data overlap, and there may be several grounds which justify our use of this data.

 

Collecting Learner information

Whilst the majority of information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain information to us or if you have a choice in this. 

 

Storing Learner information:

Inclusion School keep information about learners on computer systems and where necessary on paper with appropriate secure storage. The length of time we keep our records is in line with the referring schools, current guidance  and in order to comply with any legal obligations.

Following this period of time all data is safely destroyed.

 

Who do we share pupil information with?

We will not share your data if you have advised us that you do not want it shared unless it is the only way we can make sure learners stay safe and healthy or we are legally required to do so. Information may be shared with:

  • Referring schools and agencies
  • Local Authority: to meet our obligations to share certain information such as safeguarding concerns.
  • Examining bodies
  • Other schools, colleges or destination pathways
  • Regulatory bodies i.e Ofsted, Department for Education (DfE)
  • Partnership service providers
  • Financing departartments for invoicing purposes and auditing.
  • Public bodies i.e Police, Health and Social Welfare organisations.

 

Why we share learner information:

To allow our referring schools and agencies to comply with their statutory obligation to the Department for Education and Local Authority. For more information on what these are please contact your referring school or agency.

We do not share information about our learners with anyone without consent unless the law and our policies allow us to do so.

 

Requesting access to your personal data

Under data protection legislation, parents and learners have the right to request access to information about them that we hold. To make a ‘subject access request’ (SAR), contact us using our contact form.

Details of your rights in relation to a SAR can be found on the Inclusion School GDPR / Data Protection policy.

 

Declaration:

I (name) ………………………………………………………….., declare that I understand:

  • Inclusion Sch0ol has legal and legitimate interest to collect and process my / my child’s personal data in order to meet statutory requirements.
  • How my data is used.
  • Who Inclusion School may share my data with.
  • That Inclusion School will not share my data with any other third parties without consent, unless the law requires us to do so.
  • My data is retained in line with Inclusion School’s GDPR / Data Protection Policy.
  • I have a right to withdraw consent at any time; unless the information is required in order to comply with legal or statutory obligation.

 

 If you have any concerns about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/