The School Exclusion Project is committed to protecting and respecting any personal data that we process.
This Privacy Notice describes:
- Who we are
- What personal data we collect and store
- How we collect it
- Why we collect it and what we do with it
- How we retain personal data and keep it secure
- Your rights and how to exercise them
- How to contact us
2. WHO WE ARE
We are a project of City University that provides free advocacy to help parents appeal against their child’s permanent exclusion.
For the purposes of data protection law, City University (which, for these purposes, includes the School Exclusion Project) is a ‘data controller’. In order to provide support to parents of permanently excluded children, we need to collect, process and hold personal data. This includes personal data relating to parents and children who apply for assistance, student representatives, barrister mentors, and other personal data relating to others who feature in
our work (including other pupils and school staff).
City University is registered with the Information Commissioner’s Office (‘the ICO’), the UK’s supervisory authority for data protection matters.
The registered address isNorthampton Square,
If you would like to receive any further information about this notice or raise any other issues relating to it, please contact firstname.lastname@example.org.
3. WHAT PERSONAL DATA DO WE PROCESS?
The data which we process may include:
Personal details including
- Family details
- Information on lifestyle and social circumstances
- Financial details
- Education details
- Other details relevant to the case in question
We also process sensitive classes of personal data (sometimes known as ‘special category data). These may include information relating to:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Sexual orientation
4. HOW DO WE COLLECT PERSONAL DATA?
Parents who wish to apply for assistance from the project are invited to submit personal data through an online form hosted on a password secured website.
The data contains confidential information such as the reasons for the child’s exclusion, information about any criminal proceedings, details about any disabilities and other health conditions. Only the student directors and the barrister directors have access to all the data submitted each time a parent fills in the form, although some or all of that data may be provided to others as set out below.
If and when a student representative is offered and accepts a case, it is likely to be necessary for the parents and/or the child to provide further details to the representative in conference or in correspondence.
5. WHY DO WE USE PERSONAL DATA?
We may process personal data for legitimate purposes, which include the following:
- Providing parents and children with support during the process of permanent exclusion and appeal, including advocacy and advisory support
- Establishing whether an enquiry is within the scope of the project
- Effectively matching an application for assistance to a student volunteer
- Ensuring effective oversight over student volunteers
- Dealing with complaints and concerns, including any legal or regulatory action
- Assessing and improving the services we provide
Performance of a task carried out in the public interest
We may process personal data in the interests of justice.
We may process personal data with the consent of the person to whom it relates (sometimes known as the ‘data subject’) or, where the person is a child, the consent of their parent or guardian. Where this is the lawful basis for processing personal data, we will ensure that the data subject, parent or guardian has consented to the processing for each specific purpose and, where the processing includes processing of special category data, we will ensure that the data subject, parent or guardian has explicitly consented to the processing. The data subject, parent or guardian may withdraw consent at any time and without giving a reason.
6. WHEN DO WE SHARE PERSONAL DATA?
For the purposes set out above, we may provide data to the following:
- Trained student volunteers enrolled at City University
- Barristers at Matrix Chambers and 11KBW
- The IT providers for Matrix Chambers
- Legal advisors, in the event of a dispute arising
- School Governing Bodies, Independent Review Panels and their clerks
- Any other party where the data subject has consented
The process by which we share personal data is set out below:
We use personal data to assign trained student representatives from City University to assist parents with the exclusion process. We do this by sending emails from the SEP gmail account to the approximately 40 student representatives currently volunteering with the project to let them know which cases are available. At any one time there is normally one student director on duty. This director anonymises these emails so that the student representatives only see the facts leading to exclusion, the student’s health conditions, and the region in which the student lives.
When a student representative accepts a case they are given access to the case file in which the parent and child data is stored. The student representative may obtain further personal data in the course of carrying out their functions from, for example, the parent(s), the child, any relevant school and/or any relevant local authority. The student representative then prepares written submissions on behalf of the student and sends these to their assigned barrister mentor. These submissions are likely to include personal data. The barrister mentor reviews the submissions and sends them back to the representative.
We may also provide anonymised data for the purposes of research, consultation and journalism on the subject of school exclusions, and for training student representatives.
Save as set out above, we never pass student or parent data to third parties. We do not use automated decision making in the processing of personal information.
7. FOR HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will not keep information in a form from which a person may be identified for longer than is necessary for the purposes set out above or as required by the law. We will automatically delete or anonymise personal data after seven years from the conclusion of the case.
8. DO WE TRANSFER DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (‘THE EEA’)?
Although we are based in the United Kingdom, we may transfer personal data to a person or location (for example, a server) outside the EEA if we consider it necessary or desirable for the purposes set out above.
9. HOW DO WE KEEP PERSONAL DATA SECURE
We are committed to keeping personal data safe, private and secure.
We have measures in place which are designed to provide appropriate security for personal data, including protections against unlawful or unauthorized processing and against accidental loss, destruction and damage.
Only the persons identified above have access to personal data processed by the project. When these individuals are processing data they may only do so as far as is necessary for the purposes for which they have access to the data.
10. INFORMATION RIGHTS
Generally you have the following rights under data protection law:
- The right to be informed about the collection and use of your personal data
- The right of access to your personal data and the right to request a copy of the information I hold about you and supplementary details about it: if you wish to exercise this right, I will require proof of identity and residential address and I may need further details.
- The right to have inaccuracies in the data corrected
- The right to have data erased, destroyed or blocked in certain circumstances
- The right to object to the processing of personal data
- The right of portability of your personal data depending on the circumstances
If you wish to exercise any of these rights, please make your request using the contact details set out in section 2. You will not have to pay for this service unless your request is clearly unfounded, repetitive or excessive. In this case we may refuse your request.
11. OTHER MATTERS
We may change this privacy notice. If we do, we will put a revised copy on the website.
If you have questions or complaints about the processing of your personal data, we hope to resolve that complaint if you contact us using the contact details. However you also have the right to complain to the ICO: see www.ico.org.uk.
Date of Last Revision 23/01/20