This notice is to help you understand how and why we collect personal information about you and your child and what we do with that information. It also explains the decisions that you can make about your own information. It also explains the decisions that you can make about your child’s information.
We are giving you this notice because you are able to exercise your child’s data protection rights on their behalf. When your child is older (usually when they reach the age of 12) they will be considered mature enough to exercise their own data protection rights.
The Bursar can answer any questions which you may have about how we use your personal information. Contact the Bursar via telephone: 0121 410 6800.
What is “personal information”?
Personal information is information that the School holds about you and your child and which identifies you and/or your child.
This includes information such as your contact details, occupation, next of kind. Personal information we hold about your child includes their date of birth and address as well as things like exam results, medical details and behaviour records. We will also hold information such as your child’s religion or ethnic group for the purposes of census returns and dietary requirements. CCTV, photos and video recordings of you and your child are also personal information.
Our legal bases for using your child’s information
This section contains information about the legal basis that we are relying on when handling you and your child’s information.
This means that the School is using your child’s information when this is necessary for the School’s legitimate interests or someone else’s legitimate interests. We won’t rely on this basis when your child’s interests and fundamental rights override our legitimate interests. Specifically, the School has a legitimate interest in:
- Providing your child (and other children) with an education and making sure that your child is behaving properly.
- Complying with our agreement with you for your child to be at the School.
- Keeping the school buildings safe.
- Making sure that the School is well managed and that we protect the School’s reputation.
- Safeguarding and promoting your child’s welfare and the welfare of other children.
- Promoting the objects and interests of the School. This includes fundraising e.g. if we want to raise money to build new buildings and using photographs of your child in promotional material such as on our website and in the prospectus.
- Ensuring that all relevant legal obligations of the School are complied with (for example in relation to inspections).
- Using your child’s information in connection with legal disputes.
- Facilitating the efficient operation of the School.
In addition your child’s personal information may be processed for the legitimate interests of others. For example, we may use information about your child when investigating a complaint made by another pupil.
The School is relying on legitimate interests for all of the 40 purposes listed below except number 18.
Necessary for contract
We will need to use your information in order to perform our obligations under our contract with you and for you to perform your obligations as well. For example, we need your name and contact details so that we can update you on your child’s progress and so that we can contact you if there is a concern.
The School is relying on contract for the following purposes listed below : 1, 2, 3, 4, 14, 15, 16, 17, 18, 19, 21, 24 and 25.
Where the School needs to use your child’s information in order to comply with a legal obligation, for example to report a concern about your wellbeing to Children’s Services. We will also have to disclose your child’s information to third parties such as the courts, the local authority or the police where legally obliged to do so.
Legal obligation is relevant to the following purposes listed below: 6, 12, 13, 14, 15, 17, 18, 20, 21, 22, 23, 24 25, 26, 29 and 34.
In limited circumstances we may use your child’s information to protect your child’s vital interests or the vital interests of someone else (e.g. if your child or they are seriously hurt).
Performance of a task carried out in the public interest (or carrying out public tasks)
This applies where what we are doing is for the benefit of people generally. The following are examples of where this applies:
- providing your child and others with an education;
- safeguarding and promoting your child’s welfare and the welfare of other children;
- facilitating the efficient operation of the School; and
- ensuring that we comply with all of our legal obligations.
The School is carrying out a public task in respect of the 40 purposes listed below except numbers: 13, 18, 28, 35, 36, 37, 38 and 40.
The School must also comply with an additional legal basis (please see the table below) when it processes special categories of personal information. These special categories include: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information, health information, and information about sex life or orientation.
Substantial public interest
The School is allowed to use special categories of personal information where doing so is necessary in the substantial public interest. This is similar to “public interest” in the table above. For example the School will use information about your child’s health to look after him / her. We may also use other types of special category personal data about your child to provide them with an education, to look after your child and their classmates or when the School is inspected. The School is relying on this basis in respect of the 40 purposes listed below except numbers: 17, 28, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39 and 40.
Employment and social protection and social security law
There will be times when the School needs to use your child’s information because we are an employer. Also the School will use your child’s information to comply with social protection law (e.g. to look after your child) and social security laws. Social protection law is concerned with preventing, managing, and overcoming situations that adversely affect people’s wellbeing. The School is relying on this ground for the following purposes in particular: 2, 6, 8, 12, 22 and 26.
Also the School may use your information to comply with social protection law (e.g. to look after your child) and social security laws. Social protection law is concerned with preventing, managing, and overcoming situations that adversely affect people’s wellbeing.
In limited circumstances we may use yours or your child’s information to protect your child’s vital interests or the vital interests of someone else (e.g. if you or your child are seriously hurt).
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers. This applies whenever sharing special category data is necessary in relation to legal claims and is relevant to purposes 24 and 27 in particular.
We are allowed to use your information if this is necessary in relation to legal claims. For example, this allows us to share information with our legal advisors and insurers, see the purposes described in 23 and 27.
This includes medical treatment for your child and the management of healthcare services. This applies to the following purposes especially: 2, 6, 7 and 8.
How and why does the School collect and use your child’s personal information?
We set out below the different ways in which we use personal information and where this personal information comes from.
- Our primary reason for using yours and your child’s information is to provide your child with an education.
- The School will also use your child’s personal information to safeguard and promote your child’s welfare and the welfare of others (for example, so that we can look after your child if they are hurt). We will have information about any family circumstances which might affect your child’s welfare or happiness. This is to help us provide appropriate care and support to your child.
The admissions forms which you complete give us personal information about your child. We get information from your child, their teachers and other pupils. Your child’s previous setting also gives us information about how well your child did and any difficulties they had if we need this information to teach and care for them.
Sometimes we get information from your child’s doctor and other professionals where we need this to look after your child.
- We will need information about any court orders or criminal petitions which relate to a child’s parents or guardians. This is so that we can safeguard the welfare and wellbeing of your child and the other pupils at the School.
- We will use information about your child during the admissions process e.g. when marking entrance exams and considering any information provided on the registration form. We may let your child’s previous setting know if they have been offered a place at the School.
- We need to tell all appropriate members of staff if your child has a health issue.
- We will tell your child’s teachers if they have special educational needs or require extra help with some tasks.
- We may need to share information about your child (e.g. about their health and wellbeing) with the appropriate members of staff e.g. the School Matron.
- If we have information that your child suffers from an allergy we will use this information so that we can look after your child and share it with the School’s catering suppliers.
- If we have information that your child suffers from a disability we will use information about that disability to provide support.
- Where appropriate, the School will have information about your religious beliefs and practices.
- We use CCTV to make sure the School site is safe. CCTV is not used in private areas such as changing rooms or toilets.
- We record your child’s attendance and if they have time away from the School we record the reason(s) why.
- We will need to report some of your child’s information to the government (e.g. the Department for Education). We will need to tell the local authority that your child attends the School, if your child leaves the School or let them know if we have any concerns about your child’s welfare.
- We may need to share information about your child with the Health and Safety Executive (a government organisation) if there is a health and safety issue at the School.
- The School is a charity which means that in exceptional circumstances we may need to share your child’s information with the Charity Commission e.g. in the event of a serious incident.
- When we are inspected by the Independent Schools Inspectorate / Ofsted we will have to make your child’s information available to the inspectors to assist them with their inspection.
- If the School receives a complaint or grievance which involves your child we will need to use their information to deal with this appropriately.
- The School may share information about your child with the local authority for the purpose of the preparation, implementation and / or review of your child’s Education Health and Care Plan (EHCP).
- We are legally required to provide the Department for Education with certain information about your child. Some of this information will be stored on the National Pupil Database. Organisations can request information from the National Pupil Database which includes information about your child. But they are only allowed to do this for limited purposes and they must be very careful about how they use your child’s information. More information can be found here – https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information.
- We will need information about any court orders or criminal petitions which relate to your child. This is so that we can safeguard your child’s welfare and wellbeing and the other pupils at the School.
- If your child is from another country we have to make sure that they have the right to study in the UK. Sometimes the government will ask us to provide information as part of our reporting requirements.
- Depending on where your child will go when they leave us we will provide their information to other educational settings. For example, we will share information about your child’s exam results and provide references.
- If your child has a safeguarding file, we are legally required to pass this file to their next school/setting.
- If your child takes public examinations we will need to share information about them with examination boards. For example, if your child requires extra time in exams.
- We may need to share information with the police or our legal advisers if something goes wrong or to help with an enquiry. For example, if one of your child’s classmates is injured at School or if there is a burglary.
- We use consultants, experts and other advisors to assist the School in fulfilling its obligations and to help run the School properly. We will share your child’s information with them if this is relevant to their work.
- If your child has misbehaved in a serious way, and the police have become involved, we will need to use information about the action taken by the police.
- We may share some information with our insurance company to make sure that we have the insurance cover that we need.
- If you have appointed an agent to act on your behalf during the admissions process, then we may share information about your child with them. For example, we may send them the acceptance letter so that they can pass this on to you.
- We will share your child’s academic and (where fair) their behaviour records with you or their guardian so you can support their schooling.
- We will monitor your child’s use of email, the internet and mobile electronic devices e.g. iPads. This is to check that your child is not misbehaving when using this technology or putting themselves at risk of harm. If you would like more information about this you can read the ICT Acceptable Use Policy for Pupils, Online Safety Policy or speak to your child’s Class Teacher/Form Tutor.
- The School takes photographs of its pupils for the purposes of internal identification. In this regard, all pupils who are registered with the School will be photographed on an annual basis. The photographs are securely stored in the password-protected school Management Information System, where access is restricted to academic, pastoral and school office staff.
- Photographs and videos of pupils may be taken for evidence of pupils’ achievements, for use in pupils’ work, as part of observation and assessment records and for classroom displays. Coach Logic Video Analysis Software may be used in PE and Games lessons to help the children improve their technique.
- Images of pupils may be taken during special events such as prize-giving, school trips, concerts and sporting fixtures. Such images may be taken by professionals or a member of staff and the School may make these available for parents or guardians to purchase using online photography/printing services.
- The School uses images taken during various events e.g. plays, concerts, sporting fixtures, prizegiving, school trips etc. and generally reflecting school life for marketing and promotional purposes. For example, images of pupils may be used on the School’s website, social media and e-newsletter. Also in other marketing and promotional materials or on displays at Open Mornings and other marketing functions. Any images used in this context will be subject to stringent editorial control. In addition, when images are used in this context, the full names of such pupils will not be disclosed unless the parents or guardians (as the case may be) of such pupils have consented to such use. We will continue to use these photographs and videos after your child has left the School.
- We record our music recitals and concerts and share these with parents of participating pupils via an emailed link to our Vimeo account. Only parents with the link will be able to access the video unless we have informed parents otherwise.
If you have any concerns about us using photographs or videos of your child, please speak to the Director of Marketing and Admissions.
- We publish our public exam results, sports fixtures and other news on the School website, social media sites and put articles and photographs in the local news to tell people about what we have been doing.
- We will keep details of your child’s address and parental contact details when pupils leave so we can add them to the School Alumni database. Further information on the alumni association (The Blue Coat School Scholars) can be found here: https://thebluecoatoldscholars.co.uk/.
- The School must make sure that our computer network is working well and is secure. This may involve information about your child, for example, our anti-virus software might scan files containing information about your child.
- From time to time, we may use a third party to provide activities such as an external sports coach. We may share your child’s information with them, for example, specific medical needs such as asthma.
- We can keep information about your child for a very long time or even indefinitely if we need this for historical, research or statistical purposes. For example, if we consider the information might be useful if someone wanted to write a book about the School.
- We will process financial information about you in relation to the payment of fees. In some cases we get information about you from third parties such as credit reference agencies or from your child’s previous school(s).
- We will hold information about bankruptcy petitions and statutory demands, where relevant.
- We may search the files of any licensed credit reference agency in order to verify your identity. This also allows us to assess your application for the award of a bursary or for credit in contemplation of an agreement for the deferment of fees. The credit reference agency will keep a record of that search and details about your application. This record will be seen by other organisations which make searches about you.
- We may share your information with debt recovery suppliers if you do not pay any school fees owed to the School.
- We may obtain information about you from publicly available sources, such as Companies House and Zoopla, to assess your ability to pay School fees.
- We use a third party organisation called Bursary Administration Limited to assist us with our bursary application process. If you apply for a bursary we will share information about you with Bursary Administration Limited so that they can assess your application.
Failure to supply information may result in a refusal of an award or credit.
Sharing personal information with third parties
- In accordance with our legal obligations, we will share information with local authorities, the Independent Schools Inspectorate / Ofsted and the Department for Education, for example, where we have any safeguarding concerns or to comply with our legal obligations.
- On occasion, we may need to share your information with the police for the prevention and investigation of crime and the prosecution of offenders. We will only do this in specific circumstances to assist the police with their investigations.
- We may need to share information about you with the Health and Safety Executive (a government organisation) if there is a health and safety issue at the School.
- In certain circumstances, we may also need to share information with our legal advisers for the purpose of obtaining legal advice.
- Occasionally we may use consultants, experts and other advisors to assist the School in fulfilling its obligations and to help run the School properly (e.g. our accountants). We will share your information with them if this is relevant to their work.
- If your child is not of British nationality we have to make sure that your child has the right to study in the UK. Sometimes the government will ask us to provide information as part of our reporting requirements.
- The School is a charity which means that in exceptional circumstances we may need to share your information with the Charity Commission e.g. in the event of a serious incident.
- We may share information about you with our insurance company, for example, where there is a serious incident at the School.
If you have unpaid fees while your child is at the School we may share information about this with other schools or educational establishments to which you intend to send your child.
- If your child leaves us to attend another school we may provide that school with information about you. For example, details of family circumstances if there have been any safeguarding incidents.
- We may share information about you with others in your family, such as another parent or step-parent. For example, where this is part of our obligation to take care of your child, as part of our wider legal and regulatory obligations, or in connection with school fees.
- We may need to share information if there is an emergency, for example, if you are hurt whilst on School premises.
- If you have appointed an agent to act on your behalf, we may share information with them. For example, we may send letters to them so that they can pass these on to you.
- We may send you information about the School before you accept a place for your child. For example, we may send you a copy of the school prospectus.
- The School use third party organisations for marketing functions such as graphic design, pay-per-click advertising, social media advertising, videography and printing. In order to fulfil these services, photographs, videos and names of children may be shared. The School has data handling agreements in place with all third party service providers and personal information shared is limited to what is essential and is only held for the duration of fulfilling the contract of work.
- If your child has an Education and Health Care Plan (EHCP), we will share information with and obtain information from the local authority about you.
We will only share your child’s information with other people and organisations when we have a good reason to do so. In exceptional circumstances we may need to share it more widely than we would normally.
We sometimes use contractors to handle personal information on our behalf. The following are examples:
IT consultants who might access information about you when checking the security of our IT network; and we use third party “cloud computing” services to store some information rather than the information being stored on hard drives located on the School site.
We obtain information about you from admissions forms and from your child’s previous setting. We may also get information from professionals such as doctors and from local authorities.
Criminal offence information
In exceptional circumstances, we may use information about criminal convictions or offences. We will only do this where the law allows us to. This will usually be where such processing is necessary to carry out our obligations, to exercise our rights or to look after our pupils.
Less commonly, we may use information relating to criminal convictions and offences where it is necessary in relation to legal claims, where it is necessary to protect our pupils and you are not capable of giving your consent, or where you have already made the information public.
More than one basis
As you will see from the information above, in some cases we will rely on more than one basis for a particular use of yours or your child’s information. In addition, we may move from one of the legal bases listed above to another as circumstances change. For example, as a safeguarding matter becomes more serious, we may start to rely on “legal obligation” to share personal information with the local authority in addition to the other legal bases which are noted for safeguarding purposes.
We may ask for your consent to use yours or your child’s information in certain ways as an alternative to relying on any of the bases in the table above. For example, we may ask for your consent before taking or using some photographs and videos if the photograph or video is more intrusive and we cannot rely on legitimate interests. If we ask for your consent to use yours or your child’s personal information you can take back this consent at any time.
Any use of yours or your child’s information before you withdraw your consent remains valid. Please speak to the Bursar if you would like to withdraw any consent given.
Sending information to other countries
When the School sends personal data outside of the UK, we have to consider if the other country has the same level of protection for personal data as there is in the UK. Some countries are considered by the UK Government to have adequate rules and this includes all of the European Economic Area and some other countries, such as, New Zealand, Argentina and Japan.
In certain circumstances, we may send yours or your child’s information to countries which do not have the same level of protection for personal data as there is in the UK. For example, we may store your information on cloud computer storage based in the USA.
We will provide you with details about where we are sending yours or your child’s personal data, whether the country has an adequacy decision and if not the safeguards which we have in place outside of this privacy notice.
If you have any questions about the safeguards that are in place please contact the Estates and Compliance Manager via the Bursar.
For how long do we keep your child’s information?
We keep yours and your child’s information for as long as we need to in order to educate and look after them. We will keep certain information after your child has left the School, for example, so that we can find out what happened if you make a complaint.
In exceptional circumstances we may keep yours or your child’s information for a longer time than usual, but we would only do so if we had a good reason and only if we are allowed to do so under the General Data Protection Regulations.
Please see the relevant clauses in our Data Policy for more detailed information. This can be found on our website: https://www.thebluecoatschool.com/school-policies/.
What decisions can you make about your child’s information?
Data protection legislation gives you a number of rights regarding your information. Some of these are new rights whilst others build on your existing rights.
Your rights are as follows:
- Rectification: if information held by the School about you or your child is incorrect you can ask us to correct it.
- Access: you can also ask what information we hold about you or your child and be provided with a copy. This is commonly known as making a subject access request. We will also give you extra information, such as why we use this information about you or your child, where it came from and what types of people we have sent it to.
- Deletion: you can ask us to delete the information that we hold about you or your child in certain circumstances. For example, where we no longer need the information.
- Portability: you can request the transfer of yours or your child’s information to you or to a third party in a format that can be read by computer in certain circumstances. This applies where (a) the information has been provided by you; (b) the basis that we are relying on to process your information is consent or contract (please see “Our legal bases for using your information” above); and (c) the information is being processed by us on computer.
- Restriction: our use of information about you or your child may be restricted to simply storing it in some cases. For example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy.
- Object: you may object to us using yours or your child’s information where:
- we are using it for direct marketing purposes
- the legal basis on which we are relying is either legitimate interests or performance of a task carried out in the public interest. Please see the section “Our legal bases for using your child’s information” above;
- we are using it for historical or scientific research purposes or archiving purposes. For example, we may keep photographs of your class for historical reasons.
The Bursar can give you more information about you and your child’s data protection rights.
Further information and guidance
This notice is to explain how we look after yours and your child’s personal information. The Bursar can answer any questions which you might have.
Please speak to the Bursar or Director of Marketing and Admissions if:
- you would like to exercise any of your rights listed above; or
- you would like us to update the information we hold about you or your child; or
- you would prefer that certain information is kept confidential
If you fail to provide certain information when requested, we may not be able to perform our obligations under the contract we have entered into with you. We may also be prevented from complying with our legal obligations (such as to ensure the welfare of your child and their classmates).
If you consider that we have not acted properly when using yours or your child’s personal information you can contact the Information Commissioner’s Office: ico.org.uk.
It should be noted that at the time of writing this Privacy Notice, our website is hosted by Rooster Marketing and our School Management Information System is hosted by iSAMS. Cloud data is kept in a Data Centre in London and our School Alumni database is hosted by Amazon servers in London.