Our Policies

View the Data Security Protection pdf HERE or see below.

For the purpose of this document, the term ‘Academy’ is also used in reference to the School Centred Initial Teacher Training provider (SCITT), unless otherwise stated. The term Principal is also used in reference to the SCITT Executive Director unless otherwise stated. 

Physical security arrangements 

1. Site security 

1.1 All staff members will act in accordance with the Academy’s security policies or those in place at the site in which they are located. 

1.2 During Academy events, all rooms except those required will be locked. Only the site manager, or other designated persons, will have a copy of the keys required to access the rooms. 

1.3 Unless needed, all paperwork and equipment will be securely stored away. 

1.4 When the Academy site is open for events, the event organiser and data expert will carry out an extensive risk assessment to ensure the security of data. 

1.5 All Academies will implement a clear desk policy under which personal and sensitive data will not be kept in plain view, such as employee’s keeping paperwork which contains pupil information on their desk. 

1.6 Any paper documents containing sensitive or confidential information will be securely stored using a lock. Only the relevant member of staff will have a copy of the key required to access the data. This member of staff is responsible for ensuring the security of this key. 

1.7 Each Academy is responsible for maintaining an up-to-date record of any key holders. 

1.8 Where Academy devices are used at home, a record of all devices taken off the Academy site will be maintained. 

2. Devices and equipment 

2.1. When using devices such as hard drives to store data, the device may be approved and encrypted by the ICT support team prior to use. SCITT staff use Microsoft One Drive and do not generally store data on the hard drive of their laptops. If they need to store data they encrypt individual files stored on laptops, personal computers or other devices rather than utilising full hard drive encryption 

2.2. Devices will be locked and secured when not in use, ensuring that access to data is password protected. 

Data Security Policy 

2.3. All electronic equipment is stored in a secure location at the end of each day. 

2.4. After using Academy equipment, staff members are responsible for ensuring that it is returned to the appropriate storage location and secured. 

2.5. Staff, pupils, parents, visitors and contractors are responsible for their personal belongings, and any data stored on their devices, and the Academy is not liable for any damage or loss which may occur. 

2.6. Any equipment which someone wishes to take off the Academy site will be approved by the Principal in advance and a record of the loan kept, in line with the Academy’s Personal Devices Policy. 

2.7. Where the security of equipment storing data has been breached, the Academy’s data expert will be immediately informed. The expert will then report the incident to the Trust’s DPO, where necessary to do so. 

E-security arrangements 

1. Secure configuration 

1.1. An inventory will be kept of all IT hardware and software currently in use at each Academy, including mobile phones and other personal devices provided by the Academy. This will be stored in each Academy’s office and will be audited by the data expert on a termly basis to ensure it is up-to-date. 

1.2. Any changes to the IT hardware or software will be documented using the inventory, and will be authorised by the ICT support team before use. 

1.3. All systems will be audited on a termly basis to ensure the software is up-to-date. Any new versions of software or new security patches will be added to systems, ensuring that they do not affect network security, and will be recorded on the inventory. 

1.4. Any software that is out-of-date or reaches ‘end of life’ will be removed from systems, i.e. when suppliers end their support for outdated products, such that any security issues will not be rectified by suppliers. 

1.5. Only cloud computing systems agreed and configured by the ICT support team will be used. 

1.6. Each Academy’s data expert will ensure that a high-quality filtering system is in place at the Academy. 

Data Security Policy 

1.7. All hardware, software and operating systems, including cloud computing, will require passwords for individual users before use. 

1.8. Passwords will be changed on a 90 day basis to prevent access to facilities which could compromise network security. 

1.9. Passwords will not be written down or stored in a file. 

1.10. Staff members will not share private information, such as employee contact details and passwords. 

1.11. The Academy believes that locking down hardware, such as through strong passwords, is an effective way to prevent access to facilities by unauthorised users. This is detailed in section 6 of this policy. 

1.12. Staff members leaving the Academy will be removed from the Academy’s system immediately. 

2. Network security 

2.1. The Academy will employ firewalls in order to prevent unauthorised access to the systems. 

 The Academy’s firewall will be deployed as a centralised deployment. The broadband service connects to a firewall that is located within a data centre or other major network location. 

2.2. In relation to centralised deployments, the Academy’s firewall is managed locally by a third-party, the firewall management service will be thoroughly investigated by the ICT support team, to ensure that: 

 Any changes and updates that are logged by authorised users within the Academy, are undertaken efficiently by the provider to maintain operational effectiveness. 

 Patches and fixes are applied quickly to ensure that the network security is not compromised. 

2.3. In relation to localised deployments, the Academy’s firewall is managed on the premises, it is the responsibility of the ICT support team to effectively manage the firewall. The ICT support team will ensure that: 

 The firewall is checked regularly for any changes and/or updates, and that these are recorded using the inventory. 

 Any changes and/or updates that are added to servers, including access to new services and applications, do not compromise the overall network security. 

Data Security Policy 

 The firewall is checked regularly to ensure that a high level of security is maintained and there is effective protection from external threats. 

 Any compromise of security through the firewall is recorded using an incident log and is reported to the data expert. The ICT support team will react to security threats to find new ways of managing the firewall. 

2.4. In relation to centralised deployments, the Academy will consider installing additional firewalls on the servers in addition to the third-party service as a means of extra network protection. This decision will be made by the Academy’s Principal, taking into account the level of security currently provided and any incidents that have occurred. 

3. Email usage 

3.1. Any emails being sent externally which contain sensitive data, such as those pertaining to safeguarding concerns, will be encrypted to reduce the risk of it being viewed by anyone other than the intended audience. 

3.2. KNSTE use Egress to encrypt emails containing personal data. 

3.3. Circular and bulk emails to third parties are sent blind carbon copy (bcc), so email addresses are not disclosed to other recipients. 

4. Managing user privileges 

4.1. The Academy understands that controlling what users have access to is important for promoting network security. User privileges will be differentiated, i.e. pupils will have different access to data and the network than members of staff. 

4.2. Each Academy Principal will clearly define what users have access to and will communicate this to the ICT support team, ensuring that a written record is kept. 

4.3. The ICT support team will ensure that user accounts are set up appropriately such that users can access the facilities required, in line with the Principal’s instructions, whilst minimising the potential for deliberate or accidental attacks on the network. 

4.4. The ICT support team will ensure that websites are filtered on a weekly basis for inappropriate and malicious content. Any member of staff or pupil that has accessed inappropriate or malicious content will be recorded in accordance with the monitoring process in section 7 of this policy. 

Data Security Policy 

4.5. Pupils are responsible for remembering their own passwords; where appropriate to do so, the ICT support team will have an up-to-date record of all usernames and passwords. 

4.6. In Primary Academies, KS1 pupils will not have individual logins and class logins will be used instead. If it is appropriate for a pupil to have their individual login, the ICT support team will set up their individual user account, ensuring appropriate access and that their username and password is recorded. 

4.7. The ‘master user’ password used by the ICT support team will be made available to the Principal and will be kept in a secure place. 

4.8. A multi-user account will be created for visitors to the Academy, such as volunteers, and access will be filtered as per the Principal’s instructions. Usernames and passwords for this account will be changed on a 90 day basis, and will be provided as required. 

4.9. Academy business managers or Principals should establish robust systems for informing the ICT support team to delete inactive users or users who have left the Academy. The ICT support team will manage this provision to ensure that all users that should be deleted are, and that they do not have access to the system. 

5. Monitoring usage 

5.1. Monitoring user activity is important for early detection of attacks and incidents, as well as inappropriate usage by pupils or staff. 

5.2. The Academy will inform all pupils and staff that their usage will be monitored, in accordance with the Academy’s Acceptable Use Policy and E-safety Policy. 

5.3. An alert will be sent to the ICT support team or appropriate line manager when monitoring usage, if the user accesses inappropriate content or a threat is detected. Alerts will also be sent for unauthorised and accidental usage. 

5.4. Alerts will identify the user, the activity that prompted the alert and the information or service the user was attempting to access. 

5.5. The ICT support team or appropriate line manager will record any alerts using an incident log and will report this to the data expert. All incidents will be responded to in accordance with the Data Protection Policy. 

5.6. All data gathered by monitoring usage will be kept in a secure location for easy access when required. This data may be used as a method of 

Data Security Policy 

evidence for supporting a not yet discovered breach of network security. 

6. Removable media controls and home working 

6.1. The Academy understands that pupils and staff may need to access the Academy network from areas other than on the premises. Effective security management will be established to prevent access to, or leakage of, data, as well as any possible risk of malware. 

6.2. The ICT support team will encrypt all Academy-owned devices for personal use, such as laptops, USB sticks, mobile phones and tablets. If any portable devices are lost, this will prevent unauthorised access to personal data. 

6.3. The SCITT does not promote the use of removable media devices by its staff and requires all staff to agree to, and act in accordance with, the SCITT’s Laptop Computer Responsible Use Policy. 

6.4. In exceptional circumstances SCITT staff may encrypt individual files stored on laptops, personal computers or other devices rather than utilising full hard drive encryption. 

6.5. Pupils and staff are not permitted to use their personal devices where the Academy provides alternatives, such as work laptops, tablets and USB sticks, unless instructed otherwise by the Academy Principal. 

6.6. If pupils and staff are instructed that they are able to use their personal devices, they will ensure that they have an appropriate level of security and firewall to prevent any compromise of the Academy’s network security. This will be checked by the ICT support team. 

6.7. When using laptops, tablets and other portable devices, the data expert will determine the limitations for access to the network, as described in section 6 of this policy. 

6.8. Staff who use Academy-owned laptops, tablets and other portable devices will use them for work purposes only, whether on or off of the Academy premises. 

6.9. The ICT support team will filter the use of websites on devices when used onsite, in order to prevent inappropriate use and external threats which may compromise the network security. 

6.10. All data will be held on systems centrally in order to reduce the need for the creation of multiple copies, and/or the need to transfer data using removable media controls. 

6.11. The Wi-Fi network at the Academy will be password protected and will only be given out as required. Staff and pupils are not permitted to use 

Data Security Policy 

the Wi-Fi for their personal devices, such as mobile phones or tablets, unless instructed otherwise. 

6.12. A separate Wi-Fi network will be established for visitors at the Academy to limit their access from printers, shared storage areas and any other applications which are not necessary. 

7. Malware prevention 

7.1. The Academy understands that malware can be damaging for network security and may enter the network through a variety of means, such as email attachments, social media, malicious websites or removable media controls. 

7.2. The ICT support team will ensure that all Academy devices have secure malware protection, including regular malware scans. 

7.3. The ICT support team will update malware protection on a daily basis to ensure they are up-to-date and can react to changing threats. 

7.4. Malware protection will also be updated in the event of any attacks to the Academy’s hardware and software. 

7.5. Filtering of websites, as detailed in section 6 of this policy, will ensure that access to websites with known malware is blocked immediately and reported to the ICT support team. 

7.6. The Academy will use mail security technology, which will detect and block any malware that is transmitted by email. This will also detect any spam or other messages which are designed to exploit users. 

7.7. The ICT support team will review the mail security technology on a termly basis to ensure it is kept up-to-date and is effective. 

Processor protocol 

1.1 When handling personal data, staff members will: 

o Act in accordance with the Academy’s Data Protection Policy. 

o Verify the identity of the person requesting the information before releasing any data. 

o Be cautious about communications which involve phrases such as ‘urgent matter’, ‘forgotten password’ or ‘computer virus emergency’. 

o Report to the Academy data expert any form of intimidation for data from ‘higher level management’ and where the requester is ‘name dropping’ to give the appearance that they are authorised personnel. 

Data Security Policy 

o Verify with the Academy data expert any third-party authorisation before releasing any information. 

o Immediately end any communication which they believe to be suspicious. 

o Be cautious of popup windows, mail attachments and suspicious looking websites, such as those claiming to offer something for free. 

o Treat information in the strictest confidence. 

o Only share the information on a need-to-know basis. 

1.2 When handling personal data, staff members will not: 

o Share the information with an unauthorised individual. 

o Release data where the requester’s identity cannot be verified. 

o Share information which requires releasing information that will reveal passwords, serial numbers, financial data or confidential information. 

o Open any emails which they believe to be suspicious. 

o Use the Academy system to open or send chain letters, as well as spam or hoax emails. 

o Enter their personal or sensitive data, such as their password, if someone is stood looking over their shoulder. 

1.3 Before sharing data, all staff members will ensure: 

o They are allowed to share it. 

o That adequate security is in place to protect it. 

o Who will receive the data has been outlined in a privacy notice to the data subject. 

1.4 Third-party data processors are bound by the same data requirements as the Trust and, therefore, are expected to act in accordance with the processes and responsibilities outlined in this policy. 

Retention and disposal of data 

1.1 All data will be retained in line with the Trust’s Data Protection Policy and KNSTE’s Data Retention Policy, as well as the guidelines provided by the Information and Records Management Society. 

1.2 The Trust will apply the principle that electronic data and document will be retained as if they were paper documents. 

1.3 Where a piece of electronic data, such as an email, is required to be retained indefinitely, or retained beyond the designated retention 

Data Security Policy 

period, the data should be printed in hard copy and kept in the appropriate physical document file. 

1.4 All hard copies of personal data will be shredded and disposed of once its purpose has been fulfilled. 

1.5 Where it is not practical to segregate and manage specific data types uniquely, then a blanket seven year policy will be applied to all data with a prescribed retention period of six years or less. 

Staff training and awareness 

1.1 Each Academy Principal is responsible for ensuring that data related policies and procedures are effectively communicated to staff members. 

1.2 Relevant staff members, such as administrative staff who regularly undertake data processing, will receive training on an annual basis and in regards to any changes in practice or policy. 

1.3 All staff members will be made aware of the Trust’s data security arrangements as part of their induction training. 

1.4 Staff members will undertake cyber-security awareness training as part of their induction training. 

1.5 Staff members will receive up-to-date refresher training regarding cyber security and data protection measures on a regular basis. 

1.6 In-house training will be provided in each Academy in regards to changes in law and policy, such as GDPR training. The Principal of each Academy is responsible for ensuring that this is undertaken within their establishment. 

1.7 All staff members will be made aware of the different methods of social engineering which are most commonly used, including: 

o Human-based 

o Impersonation – this usually involves a social engineer pretending to be a Academy’s employee, board member or technical support in order to gain access to Academy-specific data, such as employee contact details. This can happen over the phone, in person or via email. 

o Third-party authorisation – where a social engineer has obtained the name of someone in the Academy and says that they have been granted access to specific information. 

Data Security Policy 

o ‘Shoulder surfing’ – this is when someone is stood looking over an individual’s shoulder whilst they enter data, such as their personal details. 

o Computer-based 

o Popup windows – this is where a window will appear on the screen, saying something like the individual has lost their internet connection and must re-enter their details. 

o Mail attachments – viruses can be hidden in email attachments. These are often given names to entice the individual or a long file name. 

o Chain, spam and hoax emails – these types of email are often used to gain individual’s email addresses and can contain computer viruses. 

1.8 Staff members will understand how to prevent and manage concerns for both computer-based and human-based social engineering. 

Monitoring 

1.1 The impact of this policy and the associated procedures will be monitored by the DPO. 

1.2 Each Academy Principal and data expert is responsible for communicating any concerns in relation to data procedures to the DPO. 

1.3 This policy will be reviewed and, where necessary, amended on an annual basis by the DPO, in liaison with Academy data experts. 

1.4 Following the reporting of a data breach, the DPO and Academy’s data expert will review the security arrangements in place and amend as necessary to avoid recurrence of the breach and improve practice. 

View the Associate Teacher Privacy Notice pdf HERE or see below.

Keele and North Staffordshire Teacher Education (‘KNSTE’) collects a lot of data and information about our Associate Teachers (‘ATs’) so that we can run our teacher training programme effectively. This privacy notice explains how and why we collect ATs’ data, what we do with it and what rights ATs have.

KNSTE is a school centred initial teacher training provider (SCITT) within the Shaw Education Trust (“the Trust”), a multi academy trust with numerous academies. The Trust is a charitable company limited by guarantee (registration number 09067175) whose registered office is The Lodge Wolstanton High, Milehouse Lane, Newcastle Under Lyme, Staffordshire, England, ST5 9JU. The Trust is the Data Controller for all the academies within the Trust and the SCITT.

The Data Protection Officer for the Trust is Natalie Kennedy, natalie.kennedy@shaweducation.

org.uk.

Why do we collect and use associate teacher information?

We collect and use associate teacher information under the following lawful bases:

a. where we have the consent of the data subject (Article 6 (a));

b. where it is necessary for compliance with a legal obligation (Article 6 (c));

c. where processing is necessary to protect the vital interests of the data subject or another

person (Article 6(d));

d. where it is necessary for the performance of a task carried out in the public interest or in

the exercise of official authority vested in the controller (Article 6 (e).

Where the personal data we collect about ATs is sensitive personal data, we will only process it

where:

a. we have explicit consent;

b. processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

and / or

c. processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Please see our Data Protection Policy for a definition of sensitive personal data.

We use the AT data to fulfil our legal requirements and to support the application process and delivery and administration of the course, in part, but not limited to, the following:

a. to decide who to offer a place to on the course;

b. to support AT learning in connection with PGCE and QTS awards;

c. to monitor and report on AT progress;

d. to provide appropriate pastoral care;

e. to assess the quality of our services;

f. to comply with the law regarding data sharing;

g. for the protection and welfare of ATs and others in our partnership schools;

h. for the safe and orderly running of the programme;

i. to promote the SCITT;

j. in order to respond to investigations from our regulators or to respond to complaints raised by our stakeholders;

k. in connection with any legal proceedings threatened or commenced against the SCITT

The categories of Associate Teacher information that we collect, hold and share include:

a. Personal information (such as name, address, unique UCAS and SLC reference);

b. Characteristics (such as ethnicity, medical conditions, nationality, country of birth )

c. Attendance information (such as sessions attended, number of absences and absence

reasons)

d. Assignment and assessment point data

e. Safeguarding checks including those pertaining to childcare disqualification.

f. Referee statements

g. Photographs

This data may be obtained through requests for information including, but not limited to, the

following:

• Passport, National Insurance or driving licence

• Recent utility bill/bank statement/council tax bill (proof of address)

• Proof of your qualifications

• Completed DBS declaration

From time to time and in certain circumstances, we might also process personal data about ATs, some of which might be classed as “special categories” of more sensitive personal information.

For example, information about criminal proceedings/convictions is collected in respect of

determining an individual’s suitability to teach. Child protection/safeguarding information is routinely collected about ATs but is only likely to be processed by the SCITT in specific circumstances relating to particular ATs, for example, if a protection issue arises or if an AT is involved in a criminal matter. Where appropriate, such information may be shared with external agencies such as the child protection team at the Local Authority, the Local Authority Designated Officer and/or the Police. Such information will only be processed to the extent that it is lawful to do so and appropriate measures will be taken to keep the data secure.

In order to fulfil statutory duties in respect of determining your fitness to teach, we also collect medical information through the form of an Occupational Health medical check. We also collect information about disabilities through completion of a disclosure.

We collect information about ATs when they join the programme and update it during their time on the course as and when new information is acquired.

Collecting Associate Teacher information

Whilst the majority of AT information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain AT information to us or if you have a choice in this. Where appropriate, we will ask ATs for consent to process personal data where there is no other lawful basis for processing it, for example where we wish to use photos or images of ATs on our website or on social media to promote school activities, or if we want to ask your permission to use your information for marketing purposes. ATs may withdraw consent at any time.

In addition, some of our partner schools use CCTV cameras around their school site for security purposes and for the protection of staff, associate teachers and pupils. CCTV footage may be referred to during the course of disciplinary procedures (for staff or associate teachers) or to investigate other issues. CCTV footage involving associate teachers will only be processed to the extent that it is lawful to do so. Please see the CCTV policy implemented at the site you are located at for more details.

Storing Associate Teacher data

In most cases we hold AT data for six years after the completion of the programme. We may also keep it longer if this is necessary in order to comply with our legal obligations.

We have a data retention policy which sets out how long we must keep AT data for. Our retention policy is available on the KNSTE website.

A significant amount of personal data is stored electronically, for example, on our database. KNSTE uses a number of IT systems and servers, such as:

• Office 365 is a cloud based system provided by Microsoft. They have many servers all over the world; however, Microsoft are fully compliant with data protection requirements.
• A restricted area on an administration server located at Seabridge Primary School, Roe Lane Newcastle Staffs ST5 3PJ.
• Paragon, a fully managed and hosted cloud-based application providing a data management system, stored on servers run by Rackspace at one of their UK data centres. Data submitted to Paragon employs end-to-end encryption Data is not transferred outside of Europe without the Users express permission.

Data stored electronically may be saved on a cloud based system which may be hosted in a different country. Personal data may be transferred to other countries if, for example, we are arranging a trip to a different country. Appropriate steps will be taken to keep the data secure.

Any information stored electronically or in hard copy will be done so in accordance with the Data Protection Policy.

Who do we share Associate Teacher information with?

We routinely share associate teacher information with:

• the Department for Education (DfE);
• KNSTE Strategic Board

• our partner schools (see list below);
• the central team at the Trust;
• Keele University;
• Student Loan Company.
• Ofsted

Where appropriate, we share AT information with the following lead schools and their partner schools:

• Blackfriars Academy
• Hempstalls Primary School
• Seabridge Primary School
• St Mary’s Catholic Academy Norton
• Painsley Catholic College
• Potteries Teaching School Alliance
• Societas Multi Academy Trust
• Parkside Primary School
• City Learning Trust
• St Mary’s C of E (A) Primary School, Tunstall
• Thomas Alleyne’s Uttoxeter Learning Trust.

From time to time, we may also share AT information with other third parties including the following:

• the Police and law enforcement agencies;
• Occupational Health;
• Courts, if ordered to do so;
• the Department for Education (DfE);
• Prevent teams in accordance with the Prevent Duty on schools;
• our HR providers, for example, if we are seeking HR advice and an AT is involved in an issue;
• UCAS;
• I&I;
• external providers and session teachers;
• our legal advisors;
• our insurance providers/the Risk Protection Arrangement.

Some of the above organisations may also be Data Controllers in their own right in which case we will be jointly controllers of your personal data and may be jointly liable in the event of any data breaches.

In the event that we share personal data about ATs with third parties, we will provide the minimum amount of personal data necessary to fulfil the purpose for which we are required to share the data.

Why we share Associate Teacher information

We do not share information about our ATs with anyone without consent unless the law allows us to do so.

We share AT data with the Department for Education (DfE) on a statutory basis.

Data collection requirements:

To find out more about the data collection requirements placed on us by the Department for Education (for example; via the ITT census) go to https://www.gov.uk/government/collections/ initial-teacher-training

The DfE has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. Decisions on whether DfE releases data to third parties are subject to a strict approval process and based on a detailed assessment of:

• who is requesting the data;
• the purpose for which it is required;
• the level and sensitivity of data requested; and
• the arrangements in place to store and handle the data.

To be granted access to AT information, organisations must comply with strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the department’s data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data   

To contact DfE: https://www.gov.uk/contact-dfe

Associate Teacher Privacy Notice

Requesting access to your personal data

Under data protection legislation, ATs have the right to request access to information about them that we hold (“Subject Access Request”).

Subject to the section below, the legal timescales for the SCITT to respond to a Subject Access Request is one calendar month. As the SCITT has limited staff resources outside of term time, we encourage ATs to submit Subject Access Requests during term time and to avoid sending a request during periods when the SCITT is closed or is about to close for the holidays where possible. This will assist us in responding to your request as promptly as possible. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.

You also have the right to:

• object to processing of personal data that is likely to cause, or is causing, damage or distress;
• prevent processing for the purpose of direct marketing;
• object to decisions being taken by automated means;
• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
• claim compensation for damages caused by a breach of the our data protection responsibilities.

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/

Contact:

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

Natalie Kennedy, DPO, via Natalie.kennedy@shaw-education.org.uk

View our Employee PrivacyNotice pdf HERE or see below.

 What is the purpose of this document? 

The Academy is committed to protecting the privacy and security of your personal information. 

Keele and North Staffordshire Teacher Education (‘KNSTE’) is a School Centred Initial Teacher Training provider (‘SCITT’) within the Shaw Education Trust (“the Trust”), a multi academy trust with numerous academies. The Trust is a charitable company limited by guarantee (registration number 09067175) whose registered office is The Lodge Wolstanton High, Milehouse Lane, Newcastle under Lyme, Staffordshire, England, ST5 9JU. The Trust is the Data Controller for all the academies within the Trust. 

This privacy notice describes how we collect and use personal information about you before, during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). 

The Trust 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 applies to current and former employees, seconded staff workers and contractors. This notice does not form part of any contract of employment or other type of contract to provide services. 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 data protection law. This says that the personal information we hold about you must be: 

(a) Used lawfully, fairly and in a transparent way. 

(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 

(c) Relevant to the purposes we have told you about and limited only to those purposes. 

(d) Accurate and kept up to date. 

(e) Kept only as long as necessary for the purposes we have told you about. 

(f) Kept securely. 

The type of information we hold about you 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

There are “special categories” of more sensitive personal data which require a higher level of protection. 

We will collect, store, and use the following categories of personal information about you: 

 Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses 

 Date of birth 

 Gender 

 Marital status and dependants 

 Next of kin and emergency contact information 

 National Insurance number 

 Bank account details, payroll records and tax status information 

 Salary, annual leave, pension and benefits information 

 Teacher Reference Number 

 Start date 

 Location of employment or workplace 

 Copy of driving licence 

 Recruitment information (including copies of pre-vetting recruitment and identity checks (including, where appropriate, information about your employment history, Standard or Enhanced Disclosure and Barring Service Checks, Barred Lists Checks, prohibition checks [/section 128 checks] and disqualification checks, for example under the Childcare (Disqualification) Regulations 2009 and any further checks that are required if you have lived or worked outside the UK), your nationality and right to work documentation, references and other information included in a CV, application form or cover letter or as part of the application process) 

 Employment records (including job titles, work history, working hours, training records and professional memberships) 

 Compensation history 

 Performance information 

 Disciplinary and grievance information, including warnings issued to you] 

 CCTV footage and other information obtained through electronic means such as swipecard records 

 Information about your use of our information and communications systems] 

 Photographs 

We may also collect, store and use the following “special categories” of more sensitive personal information: 

 Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions 

 Trade union membership 

 Information about your health, including any medical condition, health and sickness records 

 Genetic information and biometric data 

 Information about your criminal record 

How is your personal information collected? 

We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, the Local Authority or other background check agencies. 

We will also collect additional personal information in the course of job-related activities throughout the period of you working for us. 

How we will use information about you 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 

(a) Where we need to perform the contract we have entered into with you. 

(b) Where we need to comply with a legal obligation. 

We may also use your personal information in the following situations: 

(c) Where we need to protect your interests (or someone else’s interests).

(d) Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you, to enable us to comply with legal obligations and/or where it is needed in the public interest or for official purposes. The situations in which we will process your personal information are listed below.

3. • Making a decision about your recruitment or appointment
   • Determining the terms on which you work for us
   • Checking you are legally entitled to work in the UK
   • Checking the award of Qualified Teacher Status, completion of teacher induction and prohibitions, sanctions and restrictions that might prevent the individual from taking part in certain activities or working in specific positions via the Teacher Services Online platform
   • To maintain our single central record and to comply with our general safeguarding obligations
   • To provide information on our website about our employees
   • Where appropriate, to disclose certain information in the Academy’s accounts in accordance with the Accounts direction
   • Paying you and, if you are an employee, deducting tax and National Insurance contributions
   • Liaising with your pension provider
   • Administering the contract we have entered into with you
   • In order to operate as a school, which may involve us sharing certain information about our staff with our stakeholders or processing correspondence or other documents, audits or reports which contain your personal data
   • Business management and planning, including accounting and auditing
   • Conducting performance reviews, managing performance and determining performance requirements
   • Making decisions about salary reviews and compensation
   • Assessing qualifications for a particular job or task, including decisions about promotions
   • Gathering evidence for possible grievance or disciplinary hearings
   • Responding to complaints or investigations from stakeholders or our regulators
   • Making decisions about your continued employment or engagement
   • Making arrangements for the termination of our working relationship
   • Providing references to prospective employers
   • Education, training and development requirements
   • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work
   • Ascertaining your fitness to work
   • Managing sickness absence
   • Complying with health and safety obligations
   • To prevent fraud
   • To monitor your use of our information and communication systems to ensure compliance with our IT policies
   • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
   • To conduct data analytics studies to review and better understand employee retention and attrition rates
   • In connection with the Transfer of Undertaking (Protection of Employment) Regulations 2006, for example, if a service is outsourced or in connection with an academy conversion.
   • To maintain and promote equality in the workplace
   • To receive advice from external advisors and consultants
   • In appropriate circumstances to liaise with regulatory bodies, such as the NCTL, the Department for Education, the DBS and the Local Authority about your suitability to work in a school or in connection with other regulatory matters

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

In addition, some of our partner schools use CCTV cameras around their school site for security purposes and for the protection of staff and pupils. CCTV footage may be referred to during the course of disciplinary procedures (for staff, pupils or associate teachers) or to investigate other issues. CCTV footage involving staff will only be processed to the extent that it is lawful to do so. Please see the CCTV policy implemented at the site you are located at for more details.

If you fail to provide 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) or we may be unable to discharge our obligations which may be in the public interest or for official purposes.

Change of purpose

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.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require us to ensure higher levels of data protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our Data Protection Policy. Where it is needed in the public interest, such as for equal opportunities monitoring, or in relation to our occupational pension scheme, and in line with our Data Protection Policy.
3. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are, or where you have already made the information public.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence including the reasons for the leave, which may include sickness absence or family-related leave, sabbaticals, to comply with employment and other laws.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to comply with the Equality Act 2010, to monitor and manage sickness absence and to administer benefits.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• We will use trade union membership information to pay trade union subscriptions, register the status of a protected employee and to comply with employment law obligations.

Do we need your consent?

We do not need your consent if we use your particularly sensitive information in accordance with our written policy where processing is necessary:

• to carry out our legal obligations or exercise specific rights in the field of employment law;
• for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
• for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and we provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

In other circumstances, we may approach you for your written consent to allow us to process certain  particularly sensitive  data. If we  do  so, we  will provide  you  with full details  of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract of employment with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions, for example, if information about criminal convictions comes to light as a result of our recruitment and Disclosure and Barring Service checks, or if information about criminal convictions comes to light during your employment with us.

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

Employee Privacy Notice

information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

• to meet safer recruitment requirements
• to fulfil our duties as an employer
• to fulfil safeguarding requirements

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:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to meet our obligations under your employment contract and ensure that appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

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 do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other organisations.

In particular, we may share your data with organisations including, but not limited to, the following:

1. • the Local Authority
   • the Department for Education
   • the Education & Skills Funding Agency
   • the Disclosure and Barring Service
   • the Teaching Regulation Agency
   • the Teachers’ Pension Service
   • the Local Government Pension Scheme which is administered by Staffordshire Pension Fund
   • our external HR provider
   • our external payroll provider
   • Our IT Provider
   • HMRC
   • the Police or other law enforcement agencies
   • our legal advisors
   • insurance providers / Risk Protection Arrangement

Employee Privacy Notice

We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, where it is needed in the public interest or for official purposes, or where we have your consent.

Which third-party service providers process your personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: payroll, pension administration, HR, benefits provision and administration, IT services.

Department for Education

We share personal data with the Department for Education (DfE) on a statutory basis. This data sharing underpins workforce policy monitoring, evaluation, and links to school funding / expenditure and the assessment educational attainment.

We are required to share information about our pupils with the Department for Education (DfE) under regulation 7 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 as amended.

DfE data collection requirements

The following is information provided by the DfE concerning the reason it collects data about school employees:

• The DfE collects and processes personal data relating to those employed by schools (including Multi Academy Trusts) and local authorities that work in state funded schools (including all maintained schools, all academies and free schools and all special schools including Pupil Referral Units and Alternative Provision). All state funded schools are required to make a census submission because it is a statutory return under sections 113 and 114 of the Education Act 2005.
• To find out more about the data collection requirements placed on us by the DfE including the data that we share with them, go to https://www.gov.uk/education/data- collection-and-censuses-for-schools.

The DfE may share information about school employees with third parties who promote the education or well-being of children or the effective deployment of school staff by:

• conducting research or analysis;
• producing statistics; and / or
• providing information, advice or guidance

The DfE has robust processes in place to ensure that the confidentiality of personal data is maintained and there are stringent controls in place regarding access to it and its use. Decisions on whether DfE releases personal data to third parties are subject to a strict approval process and based on a detailed assessment of:

• who is requesting the data;
• the purpose for which it is required;
• the level and sensitivity of data requested; and

Employee Privacy Notice

• the arrangements in place to securely store and handle the data

To be granted access to school workforce information, organisations must comply with the DfE’s strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the DfE’s data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data To contact the department: https://www.gov.uk/contact-dfe

How secure is your information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example if there was a TUPE transfer of staff in future. We may also need to share your personal information with a regulator or to otherwise comply with the law.

From time to time, we may disclose your personal data in response to a request for information pursuant to the Freedom of Information Act 2000 or following a data subject access request. We may approach you for your consent but, in any event, we will only disclose your personal data if we are satisfied that it is reasonable to do so in all the circumstances. This means that we may refuse to disclose some or all of your personal data following receipt of such a request.

Transferring information outside the EU

Where necessary, we will transfer the personal information we collect about you outside the EU in order to perform our contract with you.

We may sometimes transfer your personal data outside of the EU if, for example, we are arranging a trip and we are booking transport, accommodation or activities. In these circumstances, we will obtain your consent for us to process your data in this way.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available in our Data Security Policy.

Third parties who are processing personal data on our behalf will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the DPO.

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.

Employee Privacy Notice

Data retention

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy which is available on the KNSTE website. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 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 and applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

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.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.

Employee Privacy Notice

The legal timescales for the school / trust to respond to a Subject Access Request is one calendar  month. As the school/trust has limited staff resources outside of term time, we encourage local governor / trustees to submit Subject Access Requests during term time and to avoid sending a request during periods when the School is closed or is about to close for the holidays where possible. This will assist us in responding to your request as promptly as possible. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

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 DPO. 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.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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.

If you have any questions about this privacy notice, please contact the DPO, Natalie Kennedy, on natalie.kennedy@shaw-education.org.uk

External Sessional Provider/Supplier Privacy Notice

The Shaw Education Trust (“the Trust”) is committed to protecting the privacy and security of your personal information. The Trust is a charitable company limited by guarantee (registration number 09067175) whose registered office is The Lodge Wolstanton High, Milehouse Lane, Newcastle Under Lyme, Staffordshire, England, ST5 9JU. The Trust is the Data Controller for all the academies within the Trust.

Keele and North Staffordshire Teacher Education is a School Centred Initial Teacher Training Provider (SCITT). The Trust is the legal entity for the SCITT; therefore, for the purpose of this privacy notice, where there is a reference to the academies within the Trust the SCITT will also be included.

The Data Protection Officer for the Trust is Natalie Kennedy, who can be contacted at The Lodge, Wolstanton High, Milehouse Lane, Newcastle Under Lyme, Staffordshire, ST5 9JU or via email on: natalie.kennedy@shaw-education.org.uk

This privacy notice describes how we collect and use personal information about you before, during and after your relationship with us a supplier, in accordance with the General Data Protection Regulation (GDPR).

The Trust 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.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The type of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, addresses, telephone numbers, and personal email addresses
• Bank account details provided by you in order to make payment for goods/services supplied

External Sessional Provider/Supplier Privacy Notice

How is your personal information collected?

We collect personal information about suppliers at the point whereby you are requested by an Academy within The Shaw Education Trust to be set up as a supplier on our central Purchase Ledger. Contact is made with you by the Finance Team at The Shaw Education Trust to ensure that data stored about you is correct.

If by any means a request is made to The Shaw Education Trust to amend your data then you will be contacted again to ensure the data we have on your record is correct. If any of your personal data changes then it will be your responsibility to inform The Shaw Education Trust regarding these changes.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you
2. Where we need to comply with a legal obligation
3. Where we need to protect your interests (or someone else’s interests)
4. Where it is needed in the public interest or for official purposes

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below.

• Setting up an account on our central Purchase Ledger
• Making payment for supply of goods/services
• Dealing with any queries regarding Purchase Orders or payments due to you
• Business management, administrative and planning purposes, including accounting and auditing
• Responding to complaints or investigations from stakeholders or our regulators
• Sending you communications connected with your role as a supplier
• Complying with health and safety obligations
• Complying with safeguarding obligations
• To prevent fraud
• In appropriate circumstances to liaise with regulatory bodies, the Department for Education, the DBS and the Local Authority about your suitability to be a supplier or in connection with other regulatory matters

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 personal information

If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations or we may be unable to discharge our obligations which may be in the public interest or for official purposes.

Change of purpose

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

External Sessional Provider/Supplier Privacy Notice

unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data sharing

We may have to share your data with third parties, including third-party service providers and other organisations.

In particular, we may share your data with organisations including, but not limited to, the following:

• Finance system provider
• Banking provider
• HMRC
• the Local Authority
• the Department for Education
• the Education & Skills Funding Agency
• the Shaw Education Trust
• the Disclosure and Barring Service
• the Police or other law enforcement agencies
• our legal advisors / other external consultants
• insurance providers

We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is needed in the public interest or for official purposes.

Which third-party service providers process your personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following third-party service provider’s process personal information about you for the following purposes: finance system and banking provider to The Shaw Education Trust for the purposes of making BACS payments to you for goods/services supplied.

How secure is your information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example if there are changes to the Trust in future. We may also need to share your personal information with a regulator or to otherwise comply with the law.

External Sessional Provider/Supplier Privacy Notice

From time to time, we may disclose your personal  data in response to a request  for information pursuant to the Freedom of Information Act 2000 or following a data subject access request. We may approach you for your consent but, in any event, we will only disclose your personal data if we are satisfied that it is reasonable to do so in all the circumstances.  This means that we may refuse to disclose some or all of your personal data following receipt of such a request.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties who are processing personal data on our behalf will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the DPO.

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.

DATA RETENTION:

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements. Details of retention periods for your personal information are available in our Data Retention Policy which is available on the KNSTE website. To determine the appropriate  retention period for personal data,  we consider  the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a supplier to the Trust we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION:

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes whilst you are a supplier of goods/services to the trust.

External Sessional Provider/Supplier Privacy Notice

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your  personal information where we are  relying on a  legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.

The legal timescales for the trust to respond to a Subject Access Request is one calendar month. As the trust has limited staff resources outside of term time, we encourage you to submit any Subject Access Requests during term time and to avoid sending a request during periods when the Trust is closed or is about to close for the holidays where possible. This will assist us in responding to your request as promptly as possible. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

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.

External Sessional Provider/Supplier Privacy Notice

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO Natalie Kennedy, The Lodge, Wolstanton High, Milehouse Lane, Newcastle Under Lyme, Staffordshire, ST5 9JU. Email: Natalie.kennedy@shaw-education.org.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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.

If you have any questions about this privacy notice, please contact the Data Protection Officer.

View the Strategic Board Privacy Notice pdf HERE or see below.

The Shaw Education Trust (“the Trust”) is committed to protecting the privacy and security of your personal information. The Trust is a charitable company limited by guarantee (registration number 09067175) whose registered office is The Lodge Wolstanton High, Milehouse Lane, Newcastle Under Lyme, Staffordshire, England, ST5 9JU. The Trust is the Data Controller for all the academies within the Trust.

The Data Protection Officer for the Trust is Natalie Kennedy, natalie.kennedy@shaw- education.org.uk.

This privacy notice describes how we collect and use personal information about you before, during and after your relationship with us as an Academy Councillor or Trustee, in accordance with the General Data Protection Regulation (GDPR).

The Trust 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.

For the purpose of this Privacy Notice, the terms ‘Academy Councillors’ and ‘Trustees’ is used in reference to the Keele and North Staffordshire Teacher Education’s (KNSTE) Strategic Board members.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The type of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

1. • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
   • Date of birth
   • Gender
   • Occupation
   • Start date
   • Skills and experience
   • Information acquired as part of your application to become a local governor or trustee (including copies of identity checks (including, where Standard or Enhanced Disclosure and Barring Service Checks, Barred Lists Checks, and disqualification checks,

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information about bankruptcy, references and other information included in a CV, application form or cover letter or as part of the application process)

• Information about pecuniary or business held by you or your family members
• Information about other posts held by you
• Information about your conduct
• CCTV footage and other information obtained through electronic means such as swipecard records
• Information about your use of our information and communications systems
• Photographs

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
• Information about your health, including any medical condition
• Information about your criminal records, fines and other similar judicial records

How is your personal information collected?

We collect personal information about Academy Councillors and Trustees through the application and recruitment process, either directly from individuals or sometimes from an external organisation such as SGOSS, Academy Ambassadors or the Local Authority.

We will also collect additional personal information in the course of local governor and trustee activities throughout the term of your appointment.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

(a) Where we need to comply with a legal obligation

1. Where we need to protect your interests (or someone else’s interests)
2. Where it is needed in the public interest or for official purposes
3. Where we have your consent.

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below.

1. • Making a decision about whether to appoint you as a local governor or trustee
   • Dealing with any processes for the election of Academy Councillors
   • Checking your suitability to be a local governor or trustee
   • Complying with our general safeguarding obligations
   • Providing information on our website about our Academy Councillors and Trustees
   • Providing information on any online databases to set out our governance arrangements
   • Communicating with stakeholders about the school / trust
   • Delivering the school / trust’s services to our community, and to carry out any other voluntary or  charitable activities for the benefit of the public as provided for in our constitution and statutory framework
   • Business management, administrative and planning purposes, including accounting and auditing
   • Financial information such as expenses claimed
   • Responding to complaints or investigations from stakeholders or our regulators
   • Sending you communications connected with your role as a local governor or trustee

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• Making decisions about your continued appointment as a local governor or trustee
• Making arrangements for the termination of your appointment
• Education, training and development requirements
• For the purposes of carrying out governance reviews
• Dealing with legal disputes involving you or other stakeholders
• Complying with health and safety obligations
• For the purposes of keeping records about local governor or trustee decision-making processes, including copies of minutes, reports and other documentation
• Where you sit on a committee or a panel on a school or Trust matter we may process your name, opinions, comments and decisions attributed to you, for example, if you sit on a panel for the purposes of considering a complaint, exclusion or HR issue
• To prevent fraud
• To monitor your use of our information and communication systems to ensure compliance with our IT policies
• To ensure network and information security, including preventing unauthorised access to  our computer and electronic communications systems and preventing malicious software distribution
• To maintain and promote equality
• To receive advice from external advisors and consultants
• In appropriate circumstances to liaise with regulatory bodies, the Department for Education, the DBS and the Local Authority about your suitability to be a local governor or trustee or in connection with other regulatory matters

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 personal information

If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to discharge our safeguarding obligations) or we may be unable to discharge our obligations which may be in the public interest or for official purposes.

Change of purpose

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.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require us to ensure higher levels of data protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• 1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations and in line with our Data Protection Policy.
  3. Where it is needed in the public interest and in line with our Data Protection Policy.

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Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations

We will use your particularly sensitive personal information in the following ways:

• We will hold information relating to sickness-related absence from your local governor or trustee commitments.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety and to provide appropriate adjustments to comply with the Equality Act 2010.

Do we need your consent?

We do not need your consent if we use your particularly sensitive information in accordance with our written policy where processing is necessary:

• for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
• for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, where we respect the essence of the right to data protection and where we provide for suitable and specific measures to safeguard your fundamental rights.

In limited circumstances, we may approach you for your written consent to allow us to process certain  particularly sensitive  data. If we  do  so, we  will provide  you  with full details  of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions, for example, if information about criminal convictions comes to light as a result of our appointment and Disclosure and Barring Service checks, or if information about criminal convictions comes to light during your time as a local governor or trustee.

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:

(a) Where we have notified you of the decision and given you 21 days to request a reconsideration.

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2. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

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 do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other organisations.

In particular, we may share your data with organisations including, but not limited to, the following:

2. • the Local Authority
   • the Department for Education
   • the Education & Skills Funding Agency
   • the Shaw Education Trust
   • the Disclosure and Barring Service
   • our external HR providers, for example, if you are involved in considering a disciplinary matter
   • the Police or other law enforcement agencies
   • our IT provider
   • our legal advisors / other external consultants
   • insurance providers

We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is needed in the public interest or for official purposes or where we have your consent.

Which third-party service providers process your personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers:

2. • personal data will be stored on a restricted area on an administration server located at Seabridge Primary School, Roe Lane.

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How secure is your information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example if there are changes to the Trust in future. We may also need to share your personal information with a regulator or to otherwise comply with the law.

From time to time, we may disclose your personal data in response to a request for information pursuant to the Freedom of Information Act 2000 or following a data subject access request. We may approach you for your consent but, in any event, we will only disclose your personal data if we are satisfied that it is reasonable to do so in all the circumstances. This means that we may refuse to disclose some or all of your personal data following receipt of such a request.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available within our Data Security Policy.

Third parties who are processing personal data on our behalf will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the DPO.

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.

Data retention

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements. Details of retention periods for different aspects of your personal information  are available  in  our  Data  Retention  Policy  which  is available  from the KNSTE website. To determine the appropriate retention  period  for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a local governor or trustee of the Trust we will retain and securely destroy your personal information in accordance with our Data Retention Policy and applicable laws and regulations.

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Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

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 appointment as a trustee or local governor.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.

The legal timescales for the school / trust to respond to a Subject Access Request is one calendar month. As the school / trust has limited staff resources outside of term time, we encourage you to submit any Subject Access Requests during term time and to avoid sending a request during periods when the School is closed or is about to close for the holidays where possible. This will assist us in responding to your request as promptly as possible. [For further information about how we handle Subject Access Requests, please see our Data Protection Policy].

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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What we may need from you

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 DPO. 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.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, Natalie Kennedy, via natalie.kennedy@shaw- education.org.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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.

If you have any questions about this privacy notice, please contact the DPO, Natalie Kennedy, on natalie.kennedy@shaw-education.org.uk