Shoreham College is a registered charity and company and our official name is Kennedy Independent School Trust Limited. Our registered charity number is 307045 and our company number is 875915. This Privacy Notice provides detailed information about how we process personal data and is intended to cover the activities of Shoreham College, the Old Shorehamers’ Association and the Parents’ Association. This information is provided because data protection law gives individuals the right to understand how their data is used. We may update this Privacy Notice from time to time, however any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
This Privacy Notice applies in addition to our terms and conditions and relevant policies, including:
- any contract between the College and its staff or the parents of pupils;
- the College’s policy on taking, storing and using images of children;
- the College’s CCTV policy;
- the College’s safeguarding, pastoral or health and safety policies, including as to how concerns or incidents are recorded; and
- the College’s IT policies, including its e-safety policy and mobile device policy.
Types of personal data we process
We process personal data about prospective, current and past pupils and their parents; staff, governors, suppliers and contractors; supporters and other individuals connected to or visiting the College. The types of data processed by the College may include by way of example:
- names, date of birth, addresses, telephone numbers, e-mail addresses and other contact details;
- car details (about those who use our car parking facilities);
- bank details and other financial information e.g. about parents who pay fees to the College;
- past, present and prospective pupils' academic, disciplinary, admissions and attendance records (including information about any special needs) as well as examination scripts and marks;
- personnel files, in connection with academics, employment or safeguarding;
- where appropriate, information about individuals' health and welfare and contact details for their next of kin;
- references given or received by the College, and relevant information provided by previous educational establishments and/or other professionals or organisations;
- correspondence with and concerning staff, pupils and parents; past and present; and
- images of pupils (and occasionally other individuals) engaging in College activities (in accordance with our Taking, Storing and Using Images of Children policy) and images captured by our CCTV system (in accordance with our CCTV policy).
Why we need to process personal data
In order to carry out our ordinary duties as an independent school, we need to process a wide range of personal data as part of our daily operation. Some of this activity we will need to carry out in order to fulfil our legal rights, duties or obligations – including those under a contract with our staff, or parents of our pupils. Other uses of personal data will be made in accordance with our 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. We expect that the following uses will fall within the category of ‘legitimate interests’:
- the selection and admission of pupils;
- the provision of education to pupils, including the administration of the curriculum and timetable; the provision of online educational resources; monitoring pupil progress and special educational needs and reporting on the same internally and to parents; administration of pupils’ entries to public examinations and other assessments including MidYIS and GL Assessments; reporting upon and publishing the results or achievements of pupils at the College;
- the provision of educational support and related services to pupils and parents, including the maintenance of discipline; provision of careers and library services; administration of sports fixtures and teams; extra-curricular activities such as school plays, musical education and educational visits;
- the safeguarding of pupils’ welfare and provision of pastoral care, welfare and health care services by College staff;
- to monitor (as appropriate) use of the College’s IT and communications systems in accordance with the College’sIT policies;
- to maintain relationships with members of the Old Shorehamers’ Association, the Parents’ Association and the school community, including direct marketing or fundraising activity;
- the promotion of the College through its own website, social media channels, the prospectus and other publications;
- the provision and receipt of references for past, current and prospective pupils, including relating to outstanding fees or payment history to and from any educational institution that the pupil attended, or where it is proposed they attend; and to provide references to potential employers of past pupils;
- compliance with legislation and regulation including the preparation of information for inspections by the Independent Schools Inspectorate and JCQ, so they may monitor the College’s performance and intervene or assist with incidents as appropriate; and the submission of annual census information;
- operational management including the administration of invoices, fees and accounts; the management of the College’s property; the management of security and safety arrangements (including the use of CCTV in accordance with our CCTV policy); management planning and forecasting; research and statistical analysis; and the maintenance of historic archives;
- staff administration including the recruitment of staff; administration of payroll, pensions and sick leave; review and appraisal of staff performance; conduct of any grievance, capability or disciplinary procedures; the maintenance of appropriate personnel records for current and former staff; and the provision of references;
- use of photographic images of pupils in College publications, including the prospectus, the College website and social media channels, in accordance with our Taking, Storing and Using Images of Children policy;
- to carry out or cooperate with any complaints, disciplinary or investigation process; and to obtain appropriate professional advice and insurance for the College where reasonably necessary.
In addition, we will on occasion need to process special category personal data, which includes information concerning health, ethnicity, religion or sexual life as well as criminal records information (such as DBS checks). We will process this data as required of us by law, particularly in regards to safeguarding and employment and to provide educational services in the context of any special educational needs of a pupil. We may also need to process this data in order to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other relevant information where it is in the individual’s interests to do so. We will also, from time to time, need to seek explicit consent for the use of data, when appropriate.
Collecting, handling and sharing personal data
We collect most of the personal data we process directly from the individual (or in the case of pupils, from their parents). In some cases we collect data from third parties, for example previous schools, referees, the DBS, the local authority or other professionals or authorities working with an individual.
For the most part, personal data collected by us will remain within the College and will be processed only by appropriate members of staff, for the purposes for which the data was provided. Particularly strict rules of access apply in the context of medical records and pastoral or safeguarding files. A certain amount of information about pupils with special educational needs or disabilities, however, will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires.
On occasion we will need to share personal information with third parties such as professional advisers (e.g. lawyers, insurers, PR advisers and accountants); relevant authorities (e.g. HMRC, Department for Education, local authorities, Department for Work and Pensions or the police); regulatory bodies (e.g. Exam Boards, DBS, National College for Teaching and Leadership, Teacher Regulation Agency, Independent Schools Inspectorate, Independent Schools Council and the Charity Commission) and online educational and assessment providers.
You are reminded that we are under a duty to record or report incidents and concerns that arise or are reported to us (including to the Local Authority Designated Officer or the police), in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. For further information please see our Safeguarding/Child Protection policy, a copy of which is available on the Shoreham College website.
Some of our processing activity is carried out on our behalf by third parties, such as our IT systems, however this is always subject to contractual assurances that personal data will be kept securely and only in accordance with our specific directions. The College may transfer personal information outside the European Economic Area (EEA) but only on the basis that the organisation receiving the information has provided assurances that adequate safeguards are in place.
How long we keep personal data
Please bear in mind that we will often have lawful and necessary reasons to hold onto some personal data, even following such a request. A limited and reasonable amount of information may also be kept for historical archiving purposes and even where you have requested that we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes.
Keeping in touch and supporting the school
We will seek consent to use the contact details of parents and past pupils to keep them updated about the activities of the College, the Parent’s Association and the Old Shorehamers’ Association, which will include sending updates and newsletters by email and by post. These communications may also be sent in order to promote and raise funds for the College and, where appropriate, other worthy causes.
You have various rights under data protection law to access and understand the personal data that we hold about you. In some cases, you also have the right 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 we 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 (e.g. employment or parent contract).
We will respond to any such written requests as soon as is reasonably practicable and in any event no later than one month in the case of requests for access to information, as required by law. We will be better able to respond quickly to smaller, targeted requests for information. 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 the 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, or information which is subject to legal privilege. We are also not required to disclose any pupil examination scripts (or other information consisting solely of pupil test answers), provide examination or other test marks ahead of any ordinary publication, or share any confidential reference given by the College itself for the purposes of the education, training or employment of any individual.
The rights under data protection law belong to the individual to whom the data relates. However, in the case of pupils, we will often rely on parental consent to process personal data relating to pupils (if consent is required) unless, given the nature of the use of data in question and the pupil’s age, it is more appropriate to rely on the pupil’s consent.
In general, we will assume that pupils’ consent is not required for ordinary disclosure of their personal data to their parents, in accordance with the parent contract and this Privacy Notice (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). 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, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example where the College believes disclosure will be in the best interests of the pupil or other pupils, or is required by law.
Pupils can make subject access requests for their own personal data, provided that, in the reasonable opinion of the College, they have sufficient maturity to understand the request they are making. This will depend on both the child and the personal data requested, including any relevant circumstances at home, however as a general rule those pupils aged 13 years and over will be deemed to have sufficient maturity. A person with parental responsibility will generally be entitled to make a subject access request on behalf of pupils, but the law still considers the information to be the child’s. A pupil of any age may ask a parent or other representative to make a subject access request on their behalf, however, for older pupils the parents making the request may need to evidence their child’s authority for the specific request.
Change of details
If you believe that we have not complied with this Privacy Notice, or acted otherwise than in accordance with data protection law, then you should utilise the College’s Complaints Procedure which is available on the Shoreham College website. The complaint should be made directly to the Privacy Officer. You 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 College before involving the regulator.