Privacy Policy

Who We Are

Grange Park Preparatory School is a charity with a registration number of 268328.

For day to day communications, the School is referred to as Grange Park Prep School or GPPS.

The Trust is established to promote and provide for the advancement of education of children in the United Kingdom, which it does by operating Grange Park Preparatory School for children aged from 3 to 11 years.

The School is a Data Controller for the purposes of Data Protection Law (The Data Protection Act 1998 and the General Data Protection Regulatory (GDPR) from 25 May 2018) which means it determines how an individual’s personal data is processed and for what purposes.

What This Policy Is For

This policy is intended to provide information about how the School will use (or "process") personal data about individuals including: its personnel (School personnel includes employed staff, self‐employed persons, volunteers and governors), its current, past and prospective students and their parents, carers or guardians (referred to in this policy as "parents").

This information is provided in accordance with the rights of individuals under Data Protection Law to understand how their data is used. School personnel, parents and students are all encouraged to read this Privacy Notice and understand the School’s obligations to its entire community.

This Privacy Notice applies alongside any other information the School may provide about a particular use of personal data, for example when collecting data via an online or paper form.

This Privacy Notice also applies in addition to the School's other relevant terms and conditions and policies, including:

• Any contract between the School and its staff or the parents of students
• The School's policy on taking, storing and using images of students
• The School’s policy on the use of CCTV
• The School’s retention of records
• The School's safeguarding and pastoral policies
• The School’s Health and Safety policy, including how concerns or incidents are recorded
• The School's IT policies, including its Acceptable Use policy, On-line Safety policy

Anyone who works for, or acts on behalf of, the School (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice and the School's Data Protection policy, which also provides further information about how personal data about those individuals will be used.

This document should be read in conjunction with Privacy Notice (pupil information) and Privacy Notice (how we use school workforce information).

Responsibility For Data Protection

The School has appointed a Data Protection Officer who will deal with all your requests and enquiries concerning the School’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.

Requests and enquiries should be sent to the Data Protection Officer at: office@gpps.org.uk

Why The School Needs to Process Personal Data

In order to carry out its ordinary duties to staff, students and parents, the School may process a wide range of personal data about individuals (including current, past and prospective staff, students 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 its staff, or parents of its students.

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 may fall within that category of its (or its community’s) “legitimate interests”:

• For the purposes of student selection (and to confirm the identity of prospective students and their parents)
• To provide education services, including musical education, physical training or spiritual development, extra-curricular activities to students, and monitoring students' progress and educational needs
• Maintaining relationships with alumnae and the School community, including direct marketing or fundraising activity;
• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as diversity or gender pay gap analysis and taxation records)
• 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, current and prospective students, 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 students
• To enable students to take part in national or other assessments, and to publish the results of public examinations or other achievements of students of the School
• To safeguard students' welfare and provide appropriate pastoral care
• To fulfil our contractual and legal obligations
• 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 students in School publications, on the School website and (where appropriate) on the School's social media channels in accordance with the School's policy on Taking, Storing and Using Images of Students
• For security purposes, including CCTV in accordance with the School’s CCTV policy
• Where otherwise reasonably necessary for the School's purposes, including to obtain appropriate professional advice and insurance for the School

In addition, the School may need to process special category personal data (concerning health, ethnicity, religion, 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 may include:

• To safeguard students' 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 where it is in the individual's interests to do so: for example for medical advice, social services, insurance purposes or to organisers of School trips;
• To provide educational services in the context of any special educational needs of a pupil
• To provide spiritual education in the context of any religious beliefs
• In connection with employment of its staff, for example DBS checks, welfare or pension plans
• For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) 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;
• Bank details and other financial information, e.g. about parents who pay fees to the School
• Past, present and prospective students' academic, disciplinary, admissions and attendance records (including information about any special needs), employment information and examination scripts and marks
• Past, present and prospective parents' employment information
• Where appropriate, information about individuals' health, and contact details for their next of kin
• References given or received by the School about students, and information provided by previous educational establishments and/or other professionals or organisations working with students
• Images of students (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 Students)
• Information relating to past, present and prospective School personnel

How The School Collects Data

Generally, the School receives personal data from the individual directly (including, in the case of students, 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 may 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

Occasionally, the School will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (HMRC, police or the local authority).

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. Particularly strict rules of access apply in the context of:

• Medical records held and accessed only by the School Office and appropriate staff under the authorisation of the School Office, or otherwise in accordance with express consent
• Safeguarding files

However, a certain amount of any medical, pastoral and SEN 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.

Staff, students and parents are reminded that the School is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) 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 may include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as Social Services or police. For further information about this, please view the School’s Safeguarding Policy.

For the purposes of maintaining a safe and secure environment, the School reserves the right to monitor all internet traffic through its filtering systems and all domain joined devices through monitoring software and services.

Finally, in accordance with Data Protection Law, some of the School’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers, cloud storage and social media providers. Where possible this is subject to contractual assurances that personal data will be kept securely and only in accordance with the School’s specific directions.

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. Typically, the legal recommendation for how long to keep ordinary staff and pupil personnel files is up to 7 years following departure from the School. 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 this 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 Data Protection Officer at office@gpps.org.uk

However, please bear in mind that the School may have lawful and necessary reasons to hold on to some data.

Keeping In Touch And Supporting The School

The School will use the contact details of parents, alumnae and other members of the School community to keep them updated about the activities of the School, or alumnae and parent events of interest, including by sending updates and newsletters, by email and by post.

Unless the relevant individual objects, the School may also:

• Share personal data about parents and/or alumnae, as appropriate, with organisations set up to help establish and maintain relationships with the School community, such as the Parent Teacher Association
• Contact parents and/or alumnae 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 Data Protection Officer in writing.

You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the School may need nonetheless 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

Individuals have various rights under Data Protection Law to access and understand personal data about them held by the School, and in some cases ask for it to be erased or amended or for the School to stop processing it, but subject to certain exemptions and limitations.

Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to the Data Protection Officer in writing office@gpps.org.uk

The School will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is one month in the case of requests for access to information.

The School will be better able to respond quickly to smaller, targeted requests for information.

You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal professional privilege. The School is also not required to disclose any pupil examination scripts, nor any confidential reference given by the School for the purposes of the education, training or employment of any individual.

Students where supported by their parents, can make subject access requests for their own personal data. Indeed, while a person with parental responsibility will generally be expected to make a subject access request on behalf of younger students, the information in question is always considered to be the child’s at law.

A student of any age may ask a parent or other legal representative to make a subject access request on her behalf, and moreover (if of sufficient age) their consent or authority may need to be sought by the parent.

Students aged 13+ 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.

Students younger than 13 may be sufficiently mature to have a say in this decision. All subject access requests from students will therefore be considered on a case by case basis.

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).

Please be aware however that the School may 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. an employment or parent contract, or a purchase of goods, services or membership of an organisation has been requested).

Whoose Rights

The rights under Data Protection Law belong to the individual to whom the data relates. However, the School will often rely on parental consent to process personal data relating to students (if consent is required) unless, given the nature of the processing in question, and the student’s age and understanding, it is more appropriate to rely on the student’s consent.

Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances.

In general, the School will assume that students’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare, unless, in the School's opinion, there is a good reason to do otherwise.

However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the School may be under an obligation to maintain confidentiality unless, in the School's opinion, there is a good reason to do otherwise; for example where the School believes disclosure will be in the best interests of the pupil or other students, or if required by law.

Students are required to respect the personal data and privacy of others, and to comply with the School's relevant policies, e.g. IT: Acceptable Use Policy and the School rules.

Staff are under professional duties to do the same, covered under the relevant staff policy.

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 notify the School at least on an annual basis of any changes to information held about them. Responsibility for changes in information relating to students rests with the parent.

An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under the Act): please see above.

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 School personnel will be made aware of this policy and their duties under Data Protection Law and receive relevant training.

Queries and Complaints

Any comments or queries on this policy should be directed to the Data Protection Officer using the email address: office@gpps.org.uk

If an individual believes that the School has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the School complaints or grievance procedure and should also notify the Data Protection Officer.

The School can also make a referral to, or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator.

Contact

If you would like to discuss anything in this privacy notice, please contact:

Data Protection Officer
Flavia Rizzo
Headteacher
headteacher@gpps.org.uk
020 8360 1469