This privacy notice provides detailed information about how we process personal data. Please read it carefully and, if you have questions regarding your personal data or its use, please contact the school Chief Privacy Officer by email on [email protected]; by telephone on 020 8452 7340; or, by post at The Bursar, Mulberry House School, 7 Minster Rd, West Hampstead, London NW2 3SD.
2. TYPES OF PERSONAL DATA WE PROCESS
We process personal data about prospective, current and past: pupils and their parents; staff, suppliers and contractors; donors, friends and supporters; and other individuals connected to or visiting the school.
The personal data we process takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples include:
- names, addresses, telephone numbers, e-mail addresses and other contact details;
- family details;
- admissions, academic, disciplinary and other education related records, information about special educational needs, references, examination scripts and marks;
- education and employment data;
- images, audio and video recordings;
- courses, meetings or events attended.
As a school, we need to process special category personal data (eg concerning health, ethnicity, religion or biometric data) and criminal records information about some individuals (particularly pupils and staff). We do so in accordance with applicable law (including with respect to safeguarding or employment) or by explicit consent.
3. COLLECTING, HANDLING AND SHARING PERSONAL DATA
We collect most of the personal data we process directly from the individual concerned (or in the case of pupils, from their parents). In some cases, we collect data from third parties (for example, referees, previous schools, the Disclosure and Barring Service, or professionals or authorities working with the individual).
Personal data held by us is processed by appropriate members of staff for the purposes for which the data was provided. We 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. We do not transfer personal data outside of the European Economic Area unless we are satisfied that the personal data will be afforded an equivalent level of protection.
In the course of school business, we share personal data (including special category personal data where appropriate) with third parties such as the school’s professional advisors and relevant authorities (eg the Local Children Safeguarding Board, DBS, NCTL, UK Visas and Immigration, HM Revenue and Customs, Department for Education and Department for Work and Pensions). Some of our systems are provided by third parties, eg hosted databases, school website, school calendar, school post and my school portal or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with our specific directions.
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We process personal data to support the schools operation as an independent school for children aged 2 – 7, and in particular for
- The selection and admission of pupils;
- The provision of education to pupils including the administration of the school curriculum and timetable; monitoring pupil progress and educational needs; reporting on the same internally and to parents; providing references for pupils (including after a pupil has left);
- The provision of educational support and related services to pupils (and parents) including the maintenance of discipline; provision of careers; administration of sports fixtures and teams, school trips; provision of the school’s IT and communications system (and monitoring the same) all in accordance with our IT policies;
- The safeguarding of pupils’ welfare and provision of pastoral care, welfare, health care services by school staff;
- Compliance with legislation and regulation including the preparation of information for inspections by the Independent Schools Inspectorate, submission of annual census information to each of the
- Independent Schools Council and Department for Education;
- Operational management including the compilation of pupil records; the administration of invoices, fees and accounts; the management of the school’s property; the management of security and safety arrangements (including the use of CCTV in accordance with our CCTV Policies and monitoring of the school’s IT and communications systems in accordance with our Acceptable Use Policy); management planning and forecasting; research and statistical analysis; the administration and implementation of the schools rules and policies for pupils and staff; the maintenance of historic archives and other operational purposes;
- Staff administration including the recruitment of staff/ engagement of contractors (including compliance with DBS procedures); administration of payroll, pensions and sick leave; review and appraisal of staff performance; conduct of any grievance, capability or disciplinary procedures; and the maintenance of appropriate human resources records for current and former staff; and providing references and
- The promotion of the school through its own websites, the prospectus and other publications and communications (including through our social media channels).
The processing set out above is carried out to fulfil our legal obligations (including those under our parent contract and staff employment contracts). We also expect these purposes to form our legitimate interests
5. HOW LONG WE KEEP PERSONAL DATA
We retain personal data only for a legitimate and lawful reason and only for so long as necessary or required by law. We have adopted Records Retention Guidelines which set out the time period for which different categories of data are kept. Currently we retain all boy files given the ongoing Independent Inquiry into Child Sexual Abuse. If you have any specific queries about our record retention periods or wish to request that your personal data is considered for erasure, please contact the school chief privacy officer.
6. YOUR RIGHTS
You have various rights under Data Protection Law to access and understand the personal data we hold about you, and in some cases to ask for it to be erased or amended or for us to stop processing it, but subject to certain exemptions and limitations.
You always have the right to withdraw consent, where given, or otherwise object to receiving generic or fundraising communications. 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 exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods or services).
Your right to access your, or your child’s personal data.
If you would like to access or amend your personal data, or would like it to be transferred to another person or organisation, or have some other objection to how your personal data is used, please contact the School Chief Privacy Officer by:
Email: [email protected];
Telephone: 020 8452 7340;
or, by Post at
Mulberry House School,
7 Minster Rd,
We will to respond to any such requests within 1 month and fulfil the request without undue delay. We will be better able to respond quickly to smaller, targeted requests for information and may contact you for further information or clarification. If the request is manifestly excessive or similar to previous requests, we may ask you to reconsider or charge a proportionate fee, but only where Data Protection Law allows it.
You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, may place another individual at risk, information relating to the management or planning of the school, information which is subject to legal privilege, nor any confidential reference given or received by the school for the purposes of the education, training or employment of any individual.
7. CHANGE OF DETAILS
We try to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Please notify [email protected] of any significant changes to important information, such as contact details, held about you.
8. THIS POLICY
Our privacy notice should be read in conjunction with our other policies and terms and conditions which make reference to personal data, including our Parent Contract, our Safeguarding Policy, Health & Safety Policies, Acceptable Use Policies and IT Policies.
We will update this Privacy Notice from time to time. Any substantial changes that affect how we process your personal data will be notified on our website and to you directly, as far as practicable.
If you believe that we have not complied with this policy or have acted otherwise than in accordance with Data Protection Law, you should notify the school Chief Privacy Officer.
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO),
Wycliffe House, Water Ln, Wilmslow SK9 5AF
Tel: 0303 123 1113
…although the ICO recommends that steps are taken to resolve the matter with us before involving them.