INTRODUCTION
We are committed to protecting and respecting your privacy. Minerva Education is a group
reference to Minerva Education and our schools. (Eaton Square Schools Ltd, Eaton Square
Kensington Ltd, Hannay Rowe Education Ltd t/as The Lyceum School and Sancton Wood
School Ltd).
If you are reading this privacy notice online, we recommend that you print and retain a copy
for future reference.
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
their parents, carers or guardians (referred to in this policy as “parents”).
This information is provided because
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
This Privacy Notice also applies in addition to the school’s other relevant terms and conditions
and policies, including:
• any contract between the school and its staff or the parents of pupils;
• the school’s policy on taking, storing and using images of children;
• the school’s retention of records policy;
• the school’s safeguarding, pastoral, or health and safety policies, including as to how
concerns or incidents are recorded; and
• the school’s IT policies, including its Acceptable Use policy for Pupils / Staff.
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 the Privacy Notice for staff,
which also provides further information about how personal data about those individuals will
be used.
RESPONSIBILITY FOR DATA PROTECTION
• The group of schools has appointed the Head of Operations and Compliance as
Privacy and Compliance Officer who will deal with all your requests and enquiries
concerning the school’s uses of your personal data (see section on Your Rights below)
and endeavour to ensure that all personal data is processed in compliance with this
policy and Data Protection Law
They can be contacted via email: [email protected]
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 management planning and forecasting, research and statistical
analysis, including
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
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;
• 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:
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May 2018 3
• 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;
• As far as is practicable, to provide educational services in the context of any special
educational needs of a pupil;
• In connection with
membership or pension plans;
• As part of any school or external complaints, disciplinary or investigation process that
involves such data, for
• 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 SCHOOLS
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 at Sancton Wood School
only);
• 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
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 (in
accordance with the school’s policy on taking, storing and using images of children);
HOW THE SCHOOLS COLLECTS DATA
Generally, the school receives personal data from the individual directly (including, in the
However, in some
publicly available resources.
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARE 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 school’s PTA
• the Exploration Society, Outward Bound Trust and related organising bodies of
residential school trips
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:
• medical records; and
• pastoral or safeguarding 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
and discussed in team meetings as necessary.
Finally, in accordance with Data Protection Law, some of the school’s processing activity
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. 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.
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May 2018 5
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 the Registrar at the school address. 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”).
Information regarding the retention of data can be found in the school’s retention of records
policy.
KEEPING IN TOUCH AND SUPPORTING THE SCHOOLS
The schools 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, class rep system and Parent Forum;
• Contact parents and/or alumni including via the organisations above by post and email
in order to promote the school and, where appropriate, raise funds for other worthy
causes;
• Should you wish to limit or object to any such use, or would like further information
about them, please contact the Head of Operations and Compliance in writing. 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
• Rights of access, etc.
Individuals have various rights under Data Protection Law to access and understand personal
data about them held by the school, and in some cases ask for it to be erased or amended or
have it transferred to others, or for the school to stop processing it – but subject to certain
exemptions and limitations.
Any individual wishing to access or amend their personal data or wishing it to be transferred
to another person or organisation, or who has some other objection to how their personal data
is used, should put their request in writing to the Head.
The school will endeavour to respond to any such written requests as soon as is reasonably
practicable and in any event within statutory time-limits (which is one month in the case of
requests for access to information).
The school will be better able to respond quickly to smaller, targeted requests for information.
If the request for information is manifestly excessive or similar to previous requests, the school
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may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law
allows it).
• Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain
data is exempt from the right of access. This will include information which identifies other
individuals (and parents need to be aware this may include their own children, in certain limited
situations – please see further below), or information which is subject to legal privilege (for
example legal advice given to or sought by the school, or documents prepared in connection
with a legal action).
The school is also not required to disclose any pupil examination scripts (or other information
consisting solely of pupil test answers), provide examination or other test marks ahead of any
ordinary publication, nor share any confidential reference given by the school itself for the
purposes of the education, training or employment of any individual.
You may have heard of the “right to be forgotten”. However, we will sometimes have
compelling reasons to refuse specific requests to amend, delete or stop processing your (or
your child’s) personal data: for example, a legal requirement, or where it falls within a legitimate
interest identified in this Privacy Notice. All such requests will be considered on their own
merits.
• Pupil requests
Pupils can make subject access requests for their own personal data, provided that, in the
reasonable opinion of the school, they have sufficient maturity to understand the request they
are making (see section Whose Rights? below). A pupil of any age may ask a parent or other
representative to make a subject access request on his/her behalf.
Indeed, while a person with parental responsibility will generally be entitled to make a subject
access request on behalf of younger pupils, the law still considers the information in question
to be the child’s: for older pupils, the parent making the request may need to evidence their
child’s authority for the specific request.
Pupils aged 13 years or above are generally assumed to have this level of maturity, although
this will depend on both the child and the personal data requested, including any relevant
circumstances at home. Slightly younger children may however be sufficiently mature to have
a say in this decision, depending on the child and the circumstances.
• Parental requests, etc.
It should be clearly understood that the rules on subject access are not the sole basis on which
information requests are handled. Parents may not have a statutory right to information, but
they and others will often have a legitimate interest or expectation in receiving certain
information about pupils without their consent. The school may consider there are lawful
grounds for sharing with or without reference to that pupil.
Parents will in general receive educational and pastoral updates about their children, in
accordance with the Parent Contract. Where parents are separated, the school will in most
cases aim to provide the same information to each person with parental responsibility but may
need to factor in all the circumstances including the express wishes of the child.
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All information requests from, on behalf of, or concerning pupils – whether made under subject
access or simply as an incidental request – will therefore be considered on a case by case
basis.
• Consent
Where the school is relying on consent as a means to process personal data, any person may
withdraw this consent at any time (subject to similar age considerations as above). Examples
where we do rely on consent are: e.g. certain types of uses of images, certain types of
fundraising activity. Please be aware however that the school may not be relying on consent
but have another lawful reason to process the personal data in question even without your
consent.
That reason will usually have been asserted under this Privacy Notice or may otherwise exist
under some form of contract or agreement with the individual (e.g. an employment or parent
contract, or because a purchase of goods, services or membership of an organisation such as
an alumni or parents’ association has been requested).
• Whose rights?
The rights under Data Protection Law belong to the individual to whom the data relates.
However, the school will often rely on parental authority or notice for the necessary ways it
processes personal data relating to pupils – for example, under the parent contract, or via a
form. Parents and pupils should be aware that this is not necessarily the same as the school
relying on strict consent (see section on Consent above).
Where consent is required, it may in some cases be necessary or appropriate – given the
nature of the processing in question, and the pupil’s age and understanding – to seek the
pupil’s consent. Parents should be aware that in such situations they may not be consulted,
depending on the interests of the child, the parents’ rights at law or under their contract, and
all the circumstances.
In general, the school will assume that pupils’ consent is not required for ordinary disclosure
of their personal data to their parents, e.g. for the purposes of keeping parents informed about
the pupil’s activities, progress and behaviour, and in the interests of the pupil’s welfare. That is
unless, in the school’s opinion, there is a good reason to do otherwise.
However, where a pupil seeks to raise concerns confidentially with a member
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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, 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 Head of Operations and
Compliance using the following contact details.
Head of Operations and Compliance: Lisa Maynard c/o Eaton Square Mayfair, 106 Piccadilly,
London, W1J 7NL [email protected]
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 Head of Operations and Compliance You can
also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO),
although the ICO recommends that steps are taken to resolve the matter with the school before
involving the regulator.
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May 2018 9
ANNEX A
Privacy Notice– parents (or guardians) of children at the school, or applying to join the
school
This annex should be read in conjunction with the introductory paragraphs in the covering
document.
This privacy notice will be provided to you at the time your data is being obtained, if it is being
obtained directly.
Data will be processed for the purposes of responding to requests for information about joining
the school and the school will therefore have a “legitimate interest” for processing basic
personal data and sensitive personal data. The data the school holds will be the minimum it
requires to form and maintain the contract between you and the school.
The school will share your data with the following companies who have contracts with the
school and who have equalled the school’s precautions and systems for dealing with data,
these are:
• Holroyd Howe Caterers
• Compatibility – School IT Support
• IT software providers – Furlong Business Solutions Ltd, Management Information
System; Classroom Monitor, Tapestry, GL Assessment for assessment and reporting;
and Scappit Ltd, School App
It is not necessary for data to be shared with other countries. The exception to this will be
international trips that the school organises, should this be envisaged for your child, you will
be contacted for your consent, the consent will be limited in time and content if it be required.
The retention period for pupil data will be until the pupil reaches the age of 25, or be modified
by any other legal obligation the school finds itself under.
You have the right to withdraw your consent to data processing at any time, however this will
only apply to certain groups of data for which you have given particular consent.
You can complain at any time about how the school has handled your data, the Information
Commissioner is available as follows:
ICO helpline is 0303 123 1113.
We see the provision of personal data as necessary to properly admit you child to the school
and to administer, and for the school to fulfil its obligations under the contract once your child
is a pupil here.
There is no automated decision making or profiling involved in this data stream into and
through the school.
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May 2018 10
ANNEX B
Privacy Notice– Children at the school over the age of 13.
This annex should be read with the introductory paragraphs in the covering document.
The paragraphs in red refer to guidance from the Information Commissioner’s Office (ICO) on
the compilation of privacy notices.
This privacy notice will be provided to you at the time your data is being obtained, if it is being
obtained directly. This means you get this when the school gets your data from your parents,
or within a month.
Data will be processed for the purposes of allowing you to make the best of your time at school.
The school will therefore have what is called a “legitimate interest” for processing basic
personal data and sensitive personal data. The data the school holds will be the minimum it
requires to allow you to thrive in your years here.
The school will share your data with the following companies who have contracts with the
school and who have equalled the school’s precautions, systems and procedures for dealing
with data, these are:
• Holroyd Howe Caterers
• Compatibility – School IT Support
• IT software providers – Furlong Business Solutions Ltd, Management Information
System; Classroom Monitor, Tapestry, GL Assessment for assessment and reporting;
and Scappit Ltd, School App
It is not necessary for data to be shared with other countries. The exception to this will be
international trips that the school organises, should this be envisaged for you, you will be
contacted for your consent, the consent will be limited in time and content if it is required.
The retention period for pupil data will be until you reach the age of 25.
You have the right to withdraw your consent to data processing at any time, however this will
only apply to certain groups of data for which you have given particular consent.
You can complain at any time about how the school has handled your data, the Information
Commissioner is available as follows:
ICO helpline is 0303 123 1113.
We will obtain the data the school requires from you, should we need data from other sources
we will contact you.
We see the provision of personal data as necessary to properly manage your time at the school
There is no automated decision making or profiling involved handling this data.
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