Privacy Notice
Our contact details
Name: School Exclusion Project, City Law School, City, University of London
Address: Northampton Square, London EC1V 0HB, United Kingdom
E-mail: schoolexclusionproject@city.ac.uk
Who we are
City Law School, City, University of London, runs a School Exclusion Project (‘SEP’) which provides free advocacy to help parents or guardians appeal against a child’s permanent exclusion. The SEP is run through the Law in Real Life Service (‘LawIRL’) at the City Law School.
This privacy notice explains the kinds of information we may obtain from or about you and your child when you contact the SEP. It sets out how we may use that information and who we may share that information with.
We respect your right to privacy and are committed to protecting the personal information provided to us and meeting our legal duties under the Data Protection Act (DPA) 2018, the UK General Data Protection Regulation (UK GDPR), and any other applicable data protection laws. We will keep any personal information you provide us or which we obtain about you, secure and confidential using appropriate organisational and technical measures. Your personal information will never be sold and will not be used for any other purpose unless the law permits us to do so.
This privacy notice explains how the SEP uses, and shares your personal data, and your rights in relation the data that we hold. This notice applies particularly to clients of the SEP, and should be read alongside City’s general privacy notice.
City is a data controller in terms of the DPA 2018 and the UK GDPR. City is registered with the Information Commissioner’s Office (ICO) with the registration number Z8947127.
What information do we collect?
The types of information we collect will include names, date of birth, email addresses, postal addresses, telephone/mobile numbers and a summary of your case. You will also have to provide us with copies of documents which relate to your case, for example the letter confirming the child’s permanent exclusion.
Do you have to provide your personal information and what are the consequences of not doing so?
You must provide us with your name and either an email or telephone contact and brief details of your enquiry, including the reasons for the child’s permanent exclusion. If you do not, we will not be able to inform you about whether we can assist you with your enquiry.
You do not have to provide any other information if you do not wish to, but it would help us if you could provide the information we request – which may include, for example, information about any related criminal proceedings and details about any relevant disability or health conditions – so that we can inform you whether or not we can help you with your concern.
In the first instance, you will be asked to provide this information through a secure online form. You can also contact us to discuss this, at schoolexclusionproject@city.ac.uk.
By providing us with your personal information, you acknowledge that the SEP may process your personal information in accordance with the purposes as laid out in this privacy statement.
You may ask us to stop acting on your behalf at any time by notifying us by email at schoolexclusionproject@city.ac.uk.
How do we collect information?
We obtain personal information from you and any parties to the case when you enquire about our service. This will often be by telephone, email or online enquiry form. We may also receive information about you from third parties, for example, from a referral agency, or from a friend or family member who contacts us about our service on your behalf.
Why do we process this information?
We require your information to be able to contact you after we have received your enquiry and to tell you whether we can help you or not. If we are able to offer assistance, we will also need the information to enable us to address your query and to provide advocacy services and advice.
What is our ‘legal basis for processing’?
Our legal bases for processing your data are as follows:
(1) Legitimate interests
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
(2) Performance of a task carried out in the public interest
We may process personal data in the interests of justice.
(3) Consent
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.
(4) Contract
We may process your initial enquiry under the lawful basis of public task per our Royal Charter, as the SEP is a service that City offers for free to support people who otherwise would not have access to advocacy services, and it provides valuable experience to our students.
If we are in a position to provide free advocacy services to you, we enter into a client agreement with you. Once this happens, we will also process your personal information under the lawful basis of performance of a contract (including pre-contractual steps taken at your request). The reason we need your personal information is to deliver any agreement we have with you. This includes providing free advocacy services and associated advice, either verbally or in writing. It can also include providing a written response to your initial enquiry, which could be a positive or negative response in relation to whether we can help with your case.
Special category data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life or data concerning sexual orientation.
We process special category data and criminal offence data in accordance with the requirements of Article 9 and 10 of the UK GDPR and Schedule 1 of the DPA 2018. If you would like further information in relation to the conditions which permit the processing of your special category data, please email schoolexclusionproject@city.ac.uk.
City also processes and stores CCTV footage for security and safety.
What we do with the information we have
We shall use your information only for the purposes of contacting you in relation to your enquiry, considering whether we can assist you, and providing advocacy services and associated legal advice to you, along with other purposes specified in this privacy notice (as updated from time to time). This includes administrative, legal and regulatory purposes related to the provision of our services.
Within SEP we may use the information to analyse trends, for reporting, or to audit our performance. This enables us to monitor and improve the quality of advice that we offer you. Wherever possible (i.e. if we do not need to know who you are) we will not use identifiable information for these purposes. Your personal data will be protected at all times.
Your personal information will never be sold and will not be used for any other purpose unless the law permits us to do so.
How we store your information
Your information is securely stored as a mixture of paper and/or computer records on City premises and our cloud-based case management system. SEP has taken steps to implement appropriate technical and organisational measures with a view to protecting the personal data we process about users of our services.
All individuals working within the SEP (including students and barrister mentors) are aware of the confidential nature of these records and we will only release this information in accordance with the law.
How long do we keep your information for?
SEP aims not to keep data for longer than we need to.
The length of time we will keep your information for will depend on which of the following categories you fall into:
Category | Explanation of Category | When will your information be deleted? |
Enquiries in relation to which we are unable to help, whether because they fall outside the scope of the project, because there are no available representatives, or for any other reason | You may be signposted to other organisations to seek advice and/or informed that the SEP cannot help. | We will delete your information no later than six months after your initial enquiry. |
Taken on as one of our clients | Where we have confirmed that we are able to provide you with services and you enter into an agreement with us. | We will delete your information no later than seven years after the date we formally close your case file. |
Do you share my information with others?
In the course of dealing with your query, we store information on our case management system, which is secure and cloud-based. To ensure your data is adequately protected City staff and students will only use City email accounts to communicate about your case, and information is stored securely on a case management system with controlled access. The way we process your data is covered by our Data Protection Policy.
SEP representatives work with barrister mentors at Matrix Chambers and 11KBW. Your personal information will be shared with them in the course of the case. This may involve email for activities such as conflict checks, but your case will be managed via our case management system. The barrister mentors have a duty as barristers to keep client data confidential, as set out in the BSB Handbook.
We will share your information with school governing bodies, independent review panels and their clerks in the course of providing you with our services.
We may also share your information with other third parties in situations where we are obliged to take action, for example with respect to safeguarding, money laundering or in the event of a complaint. Where possible, we will advise you before your information is shared.
Your personal information will never be sold and will not be used for any other purpose unless the law permits us to do so.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
Your rights in relation to automated decision-making – You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal or other significant effects on you as an individual. In practice, however, CLAC does not undertake this form of processing activity (i.e. in essence, using computer software alone to make decisions about people) in the course of providing its services to you.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
If you wish to exercise any of these rights, please send your request to the Data Protection Officer via email or by post to:
City, University of London, Information Assurance Team, Northampton Square, London, EC1V 0HB, United Kingdom
Further information
Further information regarding your individual rights is available from the Information Commissioner’s website.
City’s legal documents and policies can be accessed here. These include various privacy policies and related documents.
City also has a Data Protection Policy that sets out how we process personal data to ensure that it is always kept secure and only used appropriately.
Who can you contact if you have a concern?
City has appointed a Data Protection Officer, Dr Emma White, who can be contacted by email or by writing to her at our address:
City, University of London
Information Assurance Team
Northampton Square
London EC1V 0HB
United Kingdom
Website: https://www.city.ac.uk/
The Information Commissioner’s Office
The Information Commissioner’s Office (ICO) is responsible for making sure that personal data is collected and processed in accordance with the UK GDPR and the Data Protection Act, 2018.
If you are dissatisfied with the way in which your personal data has been processed, you may lodge a complaint with them by contacting:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://ico.org.uk/