Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)

Details of any criminal convictions

Account access information

Information relating to compliments and complaints

Exclusion, suspension and behavioural information

We also collect or use the following information for student education and welfare:

Racial or ethnic origin

Political opinions

Religious or philosophical beliefs

Health information

Sex life information

Sexual orientation information

We collect or use the following information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes:

Names and contact details for carers

Welfare information (includes family and home life circumstances and history)

Special Educational Needs and Disabilities (SEND) information (includes reasonable adjustments and special educational needs and disabilities)

Details of any criminal convictions

Witness statements and contact details

Records and reports

Video recordings of public areas (including entrances and outside spaces to which some or all members of the public have access)

Call recordings

We also collect or use the following information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes:

Racial or ethnic origin

Political opinions

Religious or philosophical beliefs

Health information

Sex life information

Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details

Address

Payment details

Account login or user information

Purchase or service history

Video recordings of public areas

Audio recordings of public areas

Video recordings of private or staff only areas

Audio recordings of private or staff only areas

Call recordings

Witness statements and contact details

Relevant information from previous investigations

Financial transaction information

Information relating to health and safety (including incident investigation details and reports and accident book records)

Correspondence

Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)

Attendance and reason for absence data

We also collect the following information for dealing with queries, complaints or claims:

Racial or ethnic origin

Political opinions

Religious or philosophical beliefs

Trade union membership

Health information

Sex life information

Sexual orientation information

We collect or use the following information for information updates or marketing purposes:

Marketing preferences

Website and app user journey information

IP addresses

Records of consent, where appropriate

We also collect or use the following information for information updates or marketing purposes:

Racial or ethnic origin

Political opinions

Religious or philosophical beliefs

Health information

Sex life information

Sexual orientation information

We collect or use the following information to comply with legal requirements:

Identification documents

Health and safety information

Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

We also collect or use the following information to comply with legal requirements:

Racial or ethnic origin

Political opinions

Religious or philosophical beliefs

Trade union membership

Health information

Sex life information

Sexual orientation information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for student education and welfare are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

Directly from you

Regulatory authorities (eg HMRC)

Parents or carers

Health care providers

CCTV footage or other recordings

Publicly available sources

Previous employers

Professional consultants

How long we keep information:

We keep data on potential clients and leads for 30 days after the last contact. We keep active and current client data for 3 years from the date of the last invoice generated for them, unless requested otherwise.

We keep accurate, proportionate records to:

Provide a high-quality service to patients and the public.
Provide feedback to health and social care services
Ensure good support and supervision to volunteers
Comply with all employment, charity and company legal requirements
Publicise our activities
Comply with quality assurance systems.

All records are made and held in accordance with the principles of the UK GDPR and Data Protection Act 2018. Our responsibility is to ensure that our activities, whether solely or as part of another organisation, are covered by our registration with the Information Commissioner’s Office.

We keep records for the period specified in the procedure below.

This policy was adopted on 07/01/2025 and will be reviewed on 06/01/2026

Who we share information with

Local authorities

Specialist teachers such as peripatetic workers or speech and language therapists

School governing bodies (such as Board of governors or Parent/teacher associations (PTA))

Insurance companies, brokers or other intermediaries

Organisations we need to share information with for safeguarding reasons

Emergency services

Legal bodies or authorities

Relevant regulatory authorities

External auditors or inspectors

Organisations we’re legally obliged to share personal information with

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

12 February 2025

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