It applies to all current and former employees, workers and contractors.
Who Collects This Information
Bingley Grammar School is a “data controller.” This means that we are responsible for deciding how we hold and use personal information about you.
We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice does not form part of any contract of employment or other contract to provide services and we may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Protection Principles
We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection Policy.
The Categories of Information That We Collect, Process, Hold and Share
We may collect, store and use the following categories of personal information about you: -
How We Collect This Information
How We Use Your Information
We will only use your personal information when the law allows us to. Most commonly, we will use your information in the following circumstances: -
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. Please note that we may process your information without your knowledge or consent, where this is require or permitted by law.
The situations in which we will process your personal information are listed below: -
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
How We Use Particularly Sensitive Information
Sensitive personal information (as defined under the GDPR as “special category data”) require higher levels of protection and further justification for collecting, storing and using this type of personal information. We may process this data in the following circumstances: -
We will use this information in the following ways: -
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where it is necessary to carry out our legal obligations. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.
Where appropriate we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of working for us.
Automated Decision Making
Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision making in the following circumstances: -
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may need to share your data with third parties, including third party service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. These include the following: -
Information will be provided to those agencies securely or anonymised where possible.
The recipient of the information will be bound by confidentiality obligations, we require them to respect the security of your data and to treat it in accordance with the law.
Except as otherwise permitted or required by applicable law or regulation, the School only retains personal data for as long as necessary to fulfil the purposes they collected it for, as required to satisfy any legal, accounting or reporting obligations, or as necessary to resolve disputes.
To determine the appropriate retention period for personal data, the School considers the amount, nature, and sensitivity of personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for processing the personal data, whether we can fulfil the purposes of processing by other means and any applicable legal requirements.
Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
The School typically retains personal data for 6 years subject to any exceptional circumstances or to comply with laws or regulations that require a specific retention period.
We have put in place measures to protect the security of your information (i.e. against it being accidentally lost, used or accessed in an unauthorised way). In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. This may include the senior leadership team, governors, trustees and HR (including payroll), auditors, HMRC, DfE and pension providers.
Third parties will only process your personal information on our instructions or for legal reasons and where they have agreed to treat information confidentially and to keep it secure.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Collecting Medical Data during the current covid-19 pandemic
Due to the current covid-19 pandemic, we may need to ask for data, including medical data, that you have not previously supplied. This data will be collected for, and on behalf of the School to allow appropriate decisions to be made regarding assessing ability to return to school and ensure that appropriate measures are put in place to allow for this safe return.
We additionally may need to collect data about individuals that you reside with in order to factor in appropriate considerations for their wellbeing.
All data collected by us will be processed in accordance with our retention, destruction, data protection and data security policies. For further information these can be found on the School’s website or by requesting this information from reception.
The legal bases for using your data in these circumstances will be either (a) with your consent, (b) where it is necessary to process this data for the ‘vital interests’ of yourself or another person, (c) for the reasons of substantial public interest, (d) where it is necessary to assess the working capacity of an employee or (e) where is it in the interests of public health.
In the current pandemic, we may need to share select data with others. This can be with the NHS and emergency services, public authorities as well as other stakeholders. This will only be done where it is necessary and proportionate for us to do so.
Your Rights of Access, Correction, Erasure and Restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances by law you have the right to: -
If you want to exercise any of the above rights, please contact the school Business Manager (Judith Smithson) in writing.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the school Business Manager (Judith Smithson). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
How to Raise a Concern
We hope that the school Business Manager (Judith Smithson) can resolve any query you raise about our use of your information in the first instance.
We have appointed a data protection officer (DPO) to oversee compliance with data protection and this privacy notice. If you have any questions about how we handle your personal information which cannot be resolved by the school Business Manager (Judith Smithson) then you can contact the DPO on the details below: -
Data Protection Officer Name: Craig Stilwell
Data Protection Officer Details: Judicium Consulting Ltd, 72 Cannon Street, London, EC4N 6AE
Data Protection Officer Email: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.
Changes to This Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.