Privacy Notice
WHO WE ARE
Any reference to ‘the School’ in this privacy notice refers to Taunton School Educational Charity (TSEC) and its wholly owned trading subsidiary, Taunton School Enterprises (TSE Ltd) Ltd.
Taunton School Educational Charity is a company limited by guarantee (company number 4005803). It is also a registered charity (company number 1081420). Taunton School Enterprises Ltd is a limited company (company number 02846335).
The School provides independent (boarding and day) education for boys and girls between the ages of 3 months to 7 years (pre-prep school and nursery, including EYFS), 7 and 13 (prep school), 13 to 18 (senior school), 15 to 16 (Taunton School International) and 8 to 14 (Taunton School International Middle School). In addition, the School operates holiday courses and other commercial activities, some of which are carried out through TSE Ltd.
WHAT THIS PRIVACY NOTICE IS FOR
This policy is intended to provide information about how the school will use (or “process”) personal data about individuals including: its current, past and prospective staff; its current, past and prospective pupils; their parents, carers or guardians (referred to in this policy as “parents”); suppliers and contractors; donors, friends and supporters; governors and other individuals connected to or visiting the school.
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents and pupils are all encouraged to read this Privacy Notice and understand the school’s obligations to its entire community.
This Privacy Notice applies alongside any other information the school may provide about a particular use of personal data, for example when collecting data via an online or paper form. It also applies in addition to the school’s other relevant terms and conditions and policies.
Anyone who works for, or acts on behalf of, the school (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice which also provides further information about how personal data about those individuals will be used.
RESPONSIBILITY FOR DATA PROTECTION
Data related requests should be sent ICT Manager / DPO by email to DataRequests@tauntonschool.co.uk in the first instance or by post to Taunton School, Staplegrove Road, Taunton, TA2 6AD.
WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, pupils and parents, the school needs to process a wide range of personal data about individuals (including current, past and prospective staff, pupils or parents) as part of its daily operation.
Some of this activity the school will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its staff, or parents of its pupils.
Other uses of personal data will be made in accordance with the school’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
• For the purposes of pupil selection (and to confirm the identity of prospective pupils and their parents);
• To provide education services, including musical education, physical training or spiritual development, career services, and extra-curricular activities to pupils, and monitoring pupils’ progress and educational needs;
• Maintaining relationships with alumni and the school community, including direct marketing or fundraising activity;
• For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests;
• To support the operation of Taunton School Enterprises Ltd activities such as gym memberships and residential or day bookings;
• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis);
• To enable relevant authorities to monitor the school’s performance and to intervene or assist with incidents as appropriate;
• To give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils;
• To enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the school;
• To safeguard pupils’ welfare and provide appropriate pastoral care;
• To monitor (as appropriate) use of the school’s IT and communications systems in accordance with the school’s IT: acceptable use policy;
• To make use of photographic images of pupils in school publications, on the school website and (where appropriate) on the school’s social media channels in accordance with the school’s policy on taking, storing and using images of children;
• Video or screen recordings of remote learning and virtual lessons;
• For security purposes, including CCTV in accordance with the school’s CCTV policy;
• To carry out or cooperate with any school or external complaints, disciplinary or investigation process; and
• Where otherwise reasonably necessary for the school’s purposes, including to obtain appropriate professional advice and insurance for the school.
In addition, the school will on occasion need to process special category personal data (concerning health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required. These reasons will include:
• To safeguard pupils’ welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other relevant information where it is in the individual’s interests to do so: for example for medical advice, for social protection, safeguarding, and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a pupil;
• To provide spiritual education in the context of any religious beliefs;
• In connection with employment of its staff, for example DBS checks, welfare, union membership or pension plans;
• To run any of its systems that operate on biometric data, such as for security and other forms of pupil identification (lockers, lunch etc.);
• As part of any school or external complaints, disciplinary or investigation process that involves such data, for example if there are SEN, health or safeguarding elements; or
• For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.
TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL
This will include by way of example:
• names, addresses, telephone numbers, e-mail addresses and other contact details;
• car details (about those who use our car parking facilities);
• bank details and other financial information, e.g. about parents who pay fees to the school;
• past, present and prospective pupils’ academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
• personnel files, including in connection with academics, employment or safeguarding;
• where appropriate, information about individuals’ health and welfare, and contact details for their next of kin;
• references given or received by the school about pupils, and relevant information provided by previous educational establishments and/or other professionals or organisations working with pupils;
• correspondence with and concerning staff, pupils and parents past and present; and
• images of pupils (and occasionally other individuals) engaging in school activities, and images captured by the school’s CCTV system (in accordance with the school’s policy on taking, storing and using images of children);
HOW THE SCHOOL COLLECTS DATA
Generally, the school receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments).
However in some cases personal data will be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from publicly available resources.
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT WITH
Occasionally, the school will need to share personal information relating to its community with third parties, such as:
• professional advisers (e.g. lawyers, insurers, PR advisers and accountants);
• government authorities (e.g. HMRC, DfE, police or the local authority); and
• appropriate regulatory bodies e.g. NCTL, the Independent Schools Inspectorate, the Charity Commission or the Information Commissioner).
• Taunton School’s Foundation (Part of our charity which raises funds for the provision of additional services, including bursaries, to the School);
• Educational agents who may act as intermediaries between parents and the School.
For the most part personal data collected by the School will remain within the School and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
• Pupil medical records held only by the school doctor and appropriate medical staff under his/her supervision, or otherwise in accordance with express consent; and
• pastoral or safeguarding files; and
• staff medical data held on personnel files.
However, a certain amount of any SEN pupil’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires.
Staff, pupils and parents are reminded that the school is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the LADO or police. For further information about this, please view the school’s Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of the school’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.
HOW LONG WE KEEP PERSONAL DATA
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason in line with our Data Retention policy which is available on request. Typically, the legal recommendation for how long to keep ordinary staff and pupil personnel files is up to 7 years following departure from the school.
However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact by email DataRequests@tauntonschool.co.uk. However, please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a “suppression record”).
KEEPING IN TOUCH AND SUPPORTING THE SCHOOL
The school will use the contact details of parents, alumni and other members of the school community to keep them updated about the activities of the school, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, the school will also:
• Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the school community, such as the PTA and Foundation;
• Contact parents and/or alumni (including via the organisations above) by post and email in order to promote and raise funds for the school;
• Collect information from publicly available sources about parents’ and former pupils’ occupation and activities, in order to maximise the school’s fundraising potential.
• Should you wish to limit or object to any such use, or would like further information about them, please contact the School in writing or email DataRequests@tauntonschool.co.uk. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
YOUR RIGHTS
You have specific rights to the processing of your data; these are the right to:
• Request access to the information the school holds about you.
• Restrict our processing of your personal data, i.e. permitting its storage but no further processing.
• Object to direct marketing (including profiling) and processing for the purposes of scientific and/or historical research and statistics.
• Have your personal data rectified if it is inaccurate or incomplete.
• Not be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you.
• Request the deletion or removal of personal data where there is no compelling reason for the continued processing.
For further information on your rights, please refer to the school’s Data Protection Policy.
If you want to request access to the personal information we hold about you, please complete the Subject Access Request Form linked to the Data Protection Policy or email DataRequests@tauntonschool.co.uk for a copy of the form.
If you are concerned about the way we are collecting or using your information, please raise your concern with the school’s DPO in the first instance.
DATA ACCURACY AND SECURITY
The school will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the relevant school office of any significant changes to important information, such as contact details, held about them.
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the school may need to process your data, and of who you may contact if you disagree.
The school will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
THIS POLICY
The school will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to the school’s IT Manager by email to DataRequests@tauntonschool.co.uk.
If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school complaints/grievance procedure and should also notify the HR Director. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/concerns, although the ICO recommends that steps are taken to resolve the matter with the school before involving the regulator.