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Data Protection

Your Space Therapies Privacy and Retention Notice

Under data protection law, individuals and commissioners have a right to be informed about how Your Space Therapies uses any personal data that we hold about them or their clients. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about Your Space Therapy clients.

We, Your Space Therapies, (Sompting Village Primary School, White Styles, Sompting, West Sussex BN15 0BU) are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is Emma Connor (see ‘Contact us’ below).

Your Space Therapies is registered with the ICO, the companies registration number is: ZA122812.

The personal data we hold

Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:

  • Contact details, contact preferences, date of birth, identification documents
  • Clinical therapeutic case notes
  • Safeguarding information
  • Details of any support received, including care packages, plans and support provided

We may also hold data about clients that we have received from other organisations, including other schools, local authorities and the Department for Education.

Why we use this data

We use this data to:

  • Provide psychotherapeutic support for clients
  • Monitor, evaluate and track improvement in emotional well-being, mental health and education attainment
  • Protect pupil welfare
  • Assess the quality of our services
  • Comply with the law regarding data sharing


Our legal basis for using this data

We only collect and use clients’ personal data when the law allows us to. Most commonly, we process it where:

  • We need to comply with a legal obligation
  • We need it to perform an official task in the public interest

Less commonly, we may also process pupils’ personal data in situations where:

  • We have obtained consent to use it in a certain way
  • We need to protect the individual’s vital interests (or someone else’s interests)

Where we have obtained consent to use clients’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.

Some of the reasons listed above for collecting and using clients’ personal data overlap, and there may be several grounds, which justify our use of this data.


How we store this data

We keep personal information about clients while they are attending our service. We also keep it beyond their attendance at our service in order to comply with our legal obligations. Clients’ personal information will be kept for six years after they have finished working with our service.

Data sharing

We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so.

Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about clients with:

  • Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
  • The clients’ school
  • The client’s family and representatives
  • Commissioners
  • Police forces, courts, tribunals

Parents and clients’ rights regarding personal data

Individuals have a right to make a ‘subject access request’ to gain access to personal information that the service holds about them.

Parents/carers can make a request with respect to their child’s data where the child is not considered mature enough to understand their rights over their own data (usually under the age of 12), or where the child has provided consent.

Parents also have the right to make a subject access request with respect to any personal data the school holds about them.

If you make a subject access request, and if we do hold information about you or your child, we will:

  • Give you a description of it
  • Tell you why we are holding and processing it, and how long we will keep it for
  • Explain where we got it from, if not from you or your child
  • Tell you who it has been, or will be, shared with
  • Let you know whether any automated decision-making is being applied to the data, and any consequences of this
  • Give you a copy of the information in an intelligible form if this is seen to be the best course of action

Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request please contact our data protection officer.

Other rights

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:

  • Object to the use of personal data if it would cause, or is causing, damage or distress
  • Prevent it being used to send direct marketing
  • Object to decisions being taken by automated means (by a computer or machine, rather than by a person)
  • In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
  • Claim compensation for damages caused by a breach of the data protection regulations

To exercise any of these rights, please contact our data protection officer.

Complaints

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our data protection officer.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

  • Report a concern online at https://ico.org.uk/concerns/
  • Call 0303 123 1113
  • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF


Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:

  • Emma Connor 01903 209991 emmaconnor@yourspacetherapies.org

This notice is based on the Department for Education’s model privacy notice for pupils, amended for parents and to reflect the way we use data in this service.

  1. Privacy notice for pupils

You have a legal right to be informed about how our service uses any personal information that we hold about you. To comply with this, we provide a ‘privacy notice’ to you where we are processing your personal data.

This privacy notice explains how we collect, store and use personal data about you.

We, Your Space Therapies (Sompting Village Primary School, White Styles Road, Sompting, West Sussex, BN15 0BU), are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is Emma Connor (see ‘Contact us’ below).

The personal data we hold

We hold some personal information about you to make sure we can help you and keep you safe whilst you are using the service.

For the same reasons, we get information about you from some other places too – like teachers and sometimes social workers.

This information includes:

  • Your contact details
  • Your test results
  • Your attendance records
  • Your characteristics, like your ethnic background or any special educational needs
  • Any medical conditions you have
  • Details of any behaviour or emotional well-being issues or exclusions

Why we use this data

We use this data to help provide a service for you, including to:

  • Get in touch with you and your parents when we need to
  • Check how you’re doing in terms of emotional well-being and educational attainment
  • Track how well the service as a whole is performing
  • Look after your wellbeing

Our legal basis for using this data

We will only collect and use your information when the law allows us to. Most often, we will use your information where:

  • We need to comply with the law
  • We need to use it to carry out a task in the public interest (in order to provide you with an education)

Sometimes, we may also use your personal information where:

  • You, or your parents/carers have given us permission to use it in a certain way
  • We need to protect your interests (or someone else’s interest)

Where we have got permission to use your data, you or your parents/carers may withdraw this at any time. We will make this clear when we ask for permission, and explain how to go about withdrawing consent.

Some of the reasons listed above for collecting and using your information overlap, and there may be several grounds, which mean we can use your data.

How we store this data

We will keep personal information about you while you are a client of our service and for six years after you have left the service.

Data sharing

We do not share personal information about you with anyone outside the school without permission from you or your parents/carers, unless the law and our policies allow us to do so.

Where it is legally required, or necessary for another reason allowed under data protection law, we may share personal information about you with:

  • Our local authority – to meet our legal duties to share certain information with it, such as concerns about pupils’ safety and exclusions
  • Your family and representatives
  • Health authorities
  • Health and social welfare organisations
  • Professional advisers and consultants
  • Police forces, courts, tribunals


Your rights

How to access personal information we hold about you

You can find out if we hold any personal information about you, and how we use it, by making a ‘subject access request’, as long as we judge that you can properly understand your rights and what they mean and judge it to be in your best interest.

If we do hold information about you, we will:

  • Give you a description of it
  • Tell you why we are holding and using it, and how long we will keep it for
  • Explain where we got it from, if not from you or your parents
  • Tell you who it has been, or will be, shared with
  • Let you know if we are using your data to make any automated decisions (decisions being taken by a computer or machine, rather than by a person)
  • Give you a copy of the information

You may also ask us to send your personal information to another organisation electronically in certain circumstances.

If you want to make a request please contact our data protection officer.

Your other rights over your data

You have other rights over how your personal data is used and kept safe, including the right to:

  • Say that you don’t want it to be used if this would cause, or is causing, harm or distress
  • Stop it being used to send you marketing materials
  • Say that you don’t want it used to make automated decisions (decisions made by a computer or machine, rather than by a person)
  • Have it corrected, deleted or destroyed if it is wrong, or restrict our use of it
  • Claim compensation if the data protection rules are broken and this harms you in some way


Complaints

We take any complaints about how we collect and use your personal data very seriously, so please let us know if you think we’ve done something wrong.

You can make a complaint at any time by contacting our data protection officer.

You can also complain to the Information Commissioner’s Office in one of the following ways:

  • Report a concern online at https://ico.org.uk/concerns/
  • Call 0303 123 1113
  • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:

  • Emma Connor 01903 209991 emmaconnor@yourspacetherapies.org

This notice is based on the Department for Education’s model privacy notice for pupils, amended to reflect the way we use data in this school.

  1. Privacy notice for staff

Under data protection law, individuals have a right to be informed about how the service uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about individuals we employ, or otherwise engage, to work at our service.

We, Your Space Therapies (Sompting Village Primary School, White Styles Road, Sompting, West Sussex, BN15 0BU, are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is Emma Connor (see ‘Contact us’ below).

The personal data we hold

We process data relating to those we employ, or otherwise engage, to work at our service. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

  • Contact details
  • Date of birth, marital status and gender
  • Next of kin and emergency contact numbers
  • Salary, annual leave, pension and benefits information
  • Bank account details, payroll records, National Insurance number and tax status information
  • Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process
  • Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships
  • Performance information
  • Outcomes of any disciplinary and/or grievance procedures
  • Absence data
  • Copy of driving licence
  • Photographs

We may also collect, store and use information about you that falls into “special categories” of more sensitive personal data. This includes information about (where applicable):

  • Race, ethnicity, religious beliefs, sexual orientation and political opinions
  • Trade union membership
  • Health, including any medical conditions, and sickness records

 

Why we use this data

The purpose of processing this data is to help us run the school, including to:

  • Enable you to be paid
  • Facilitate safe recruitment, as part of our safeguarding obligations towards pupils
  • Support effective performance management
  • Inform our recruitment and retention policies
  • Allow better financial modelling and planning
  • Enable ethnicity and disability monitoring
  • Improve the management of workforce data across the sector

 

Our lawful basis for using this data

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

  • Fulfil a contract we have entered into with you
  • Comply with a legal obligation
  • Carry out a task in the public interest

Less commonly, we may also use personal information about you where:

  • You have given us consent to use it in a certain way
  • We need to protect your vital interests (or someone else’s interests)

 

Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so.

Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds, which justify the services’ use of your data.

 

Collecting this information

While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us.

Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.

 

How we store this data

We create and maintain an employment file for each staff member. The information contained in this file is kept secure and is only used for purposes directly relevant to your employment.

Once your employment with us has ended, we will retain this file and delete the information in it after six months.

Data sharing

We do not share information about you with any third party without your consent unless the law and our policies allow us to do so.

Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about you with:

  • Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and [maintained schools only] information about head teacher performance and staff dismissals
  • Your family or representatives
  • Suppliers and service providers – to enable them to provide the service we have contracted them for, such as payroll
  • Financial organisations
  • Health authorities
  • Security organisations
  • Health and social welfare organisations
  • Professional advisers and consultants
  • Police forces, courts, tribunals
  • Professional bodies

 

Transferring data internationally

Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.

Your rights

How to access personal information we hold about you

Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school holds about them.

If you make a subject access request, and if we do hold information about you, we will:

  • Give you a description of it
  • Tell you why we are holding and processing it, and how long we will keep it for
  • Explain where we got it from, if not from you
  • Tell you who it has been, or will be, shared with
  • Let you know whether any automated decision-making is being applied to the data, and any consequences of this
  • Give you a copy of the information in an intelligible form

You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request, please contact our data protection officer.

Your other rights regarding your data

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:

  • Object to the use of your personal data if it would cause, or is causing, damage or distress
  • Prevent your data being used to send direct marketing
  • Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person)
  • In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
  • Claim compensation for damages caused by a breach of the data protection regulations

To exercise any of these rights, please contact our data protection officer.

Complaints

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our data protection officer.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

  • Report a concern online at https://ico.org.uk/concerns/
  • Call 0303 123 1113
  • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:

  • Emma Connor 01903 209991 emmaconnor@yourspacetherapies.org

 

This notice is based on the Department for Education’s model privacy notice for the school workforce, amended to reflect the way we use data in this school.