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ÌÇÐĹÙÍø is committed to protecting and respecting your privacy. ÌÇÐĹÙÍø ("ÌÇÐĹÙÍø") is a subsidiary of CareTech Holdings Limited. This policy (together with ÌÇÐĹÙÍø'sÌýLegal NoticeÌýand any other documents referred to on it) sets out the basis on which any personal data that you provide to ÌÇÐĹÙÍø (including its subsidiaries), will be processed by ÌÇÐĹÙÍø and CareTech Holdings Limited.
Your personal data is information which by itself or with other information available to us can be used to identify you, the data subject. By ‘processing’, we mean anyÌýactivity that involves using your personal data. This includes collecting it, recording it, storing it, retrieving it, using it, amending it, disclosing it, destroying it, and transferring it to other individuals or organisations outside of the ÌÇÐĹÙÍø.ÌýPlease read the following carefully to understand ÌÇÐĹÙÍø's views and practices regarding your personal data and how ÌÇÐĹÙÍø will treat it.
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2.ÌýÌýÌýÌýThe types of personal data ÌÇÐĹÙÍø may collect from you
Personal information about individuals is usually provided to ÌÇÐĹÙÍø by the individualÌý(young person, their parent or guardian, foster carer, contractor, customer or visitor). Personal information that individuals provided to other organisations may also be forwarded to ÌÇÐĹÙÍø (for example from a local authority social worker when placing a young person with us).
ÌÇÐĹÙÍø may collect and process the following personal information:
- Personal details (name, date of birth, email address, home address, telephone number, unique pupil number, gender, disability, sexual orientation, criminal convictions, racial or ethnic origin, religious or other beliefs).
- Family details (contact details and relationships)
- Financial information (bank details)
- Safeguarding, special educational needs, physical and mental health
- Education details (school admission, attendance, absences, behaviour, exclusions, certificates, exams or tests records and progress)
- Visual images, personal appearance and behaviour (photographs, CCTV recordings)
- Information relation to offences or alleged offencesÌý
- Details of goods and services provided
- Shareholders details (number of shares held, certificates, voting instructions)
Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitiveâ€� personal information. We will process any such information only if youÌýhave given your explicit consent, it is necessary for a legal reason or you have deliberately made it public.
If you contact ÌÇÐĹÙÍø, we may keep a record of that correspondence; details of your visits to ÌÇÐĹÙÍø's site, and the resources that you access.
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3.ÌýÌýÌýÌýThe reasons why ÌÇÐĹÙÍø collects personal information.
We collect personal information to enable us to fulfil our legitimate business needs, such as:
- provide education and training
- provide residential healthcare, welfare and educational support services
- the provision of fostering for children and young people
- administer school property and library services
- maintain our own accounts and records
- administer the boarding and the organisation of alumni associations and events
- administer shareholders registrations and dividends service
- raise funds for our businesses
- support and manage our staff
- advertising and marketing
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4.ÌýÌýÌýÌýÌÇÐĹÙ꿉۪s legal basis and purposes for using your personal information
We collect and use your personal information in the following situations:
a)ÌýÌýÌýÌýwhere our use of your information isÌýnecessary for us to perform the contract or contracts that we have with you:
- These contracts include the terms and conditions of goods or services that individuals agreed with ÌÇÐĹÙÍø. For example, we record the personal details of individuals (such as Foster Parent) who care for children or young people on our behalf.Ìý
- We also record the names of staff from local authorities which commissioned ÌÇÐĹÙÍø to provide services.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to agree a contract with you or provide services under a contract.
b)ÌýÌýÌýÌýwhere our use of your information is for the purposes of ourÌýlegitimate business needsÌýor the legitimate business needs of third-party contractors who we engaged to deliver services on our behalf (see section 3, above). For example:
As part of our business needs we collectÌývisual images, personal appearance and behavioursÌýthrough CCTV recordingsÌýto maintain the security of property and premises and for preventing and investigating crime. This information may be about customers, clients, offenders, suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance. Where necessary or required this information is shared with the data subjects themselves, employees and agents, services providers, police forces, security organisations and persons making an enquiry.
- We alsoÌýkeep a record of any communications between us and you, for example emails and phone calls, because we need it to help us fulfil your requests, keep in touch with you, and offer you communications that are relevant to you.
Ìýc)ÌýÌýÌýÌýwhere we believe it isÌýnecessary to use your information to comply with a legal obligationÌýto which we are required to fulfil:
- We are required by law to track and record the progress of pupils in our schools so that this information can be shared with Ofsted, the government regulator.
- We have a legal duty to record and retain information (gender, age, date of birth) about pupils and share this information with the Department for Education.
- Where the law requires, we have a duty to cooperate with local authorities on arrangements for children and young people with special educational needs
Ìýd)ÌýÌýÌýÌýwhere our use of your information is necessary for usÌýto carry out a task in the public interest.
- We share information with the Police, Local Authority or other agencies where we consider that a child or vulnerable person may be at risk or harm.
- For the safe running of our schools we also monitor movement of visitors entering and leaving our sites
- We keep record of day to day observations of young persons within residential homes and foster homes so that we can manage any risks and track progress.
Ìýe)ÌýÌýÌýÌýwhere we believe use of your informationÌýis necessary in order to protect the vital interestsÌýof a young person or another person. These include:
- Ìýfamily contact details of pupils within our schools so that we can contact them in case of an emergency.
- Ìýinformation regarding young person’s health needs, including food allergies
Ìýf)ÌýÌýÌýÌýÌýwhere we have yourÌýconsent.ÌýWe will rely on your consent :
- to use your photographs to promote or market our business
- if you choose to receive marketing information (i.e. subscribing to our e-newsletters via our website, service email updates and general news about ÌÇÐĹÙÍø).ÌýYou will also be given the opportunity to indicate that you no longer wish to receive our direct marketing material.
We will always make it clear where we need your permission to process your personal information.ÌýWhere we rely on your consent to use your personal information, you have the right to withdraw that consent at any time, using the same method by which you gave us your consent originally.ÌýÌý
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5.ÌýÌýÌýÌýWho will ÌÇÐĹÙÍø share your personal information with?
In fulfilling our business needs, we may share your information for any of the purposes mentioned at section 3 and 4, above. These are: (a)Ìýto perform the contract or contracts that we have with you (b) our legitimate business needs (c)Ìýto comply with a legal obligation (d)Ìýto carry out a task in the public interest (e) to protect vital interests; or (f)Ìýwhere we have your consent.
Specifically, information may be shared with:
- Family and representatives of the person whose personal data we are processing
- CareTech Holdings Limited
- Ofsted, Department for Education and local authorities
- Welsh Inspectorate for both care and education
- Care Quality Commission (England)
- police, courts, tribunals andÌý security organisations
- contractors who we pay to provide services
- healthcare professionals, social and welfare organisations
- staff, students, governors and school boards
- debt collection and tracing agencies
- financial organisations
- foster parent
- education, training and examining bodies
6.ÌýÌýÌýÌýTransferring your personal information internationally
It may sometimes be necessary to transfer personal information overseas (outside of the United Kingdom). When this is needed information is only shared within the European Economic Area (EEA). Any transfers made will be in full compliance with all aspects of the General Data Protection Regulations and Data Protection Act 2018.
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7.ÌýÌýÌýÌýThe period for which we will keep your personal informationÌý
We will only retain your personal information for as long as it is required in relation to the purposes for which it was originally obtained or based on our legal and regulatory requirements. For example, the law requires us to keep information about the protection of children for 25 years after birth.
How long personal information will be retained for depends on the type of information it is and what it is being used for.Ìý For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (although we will keep a record of your preference not to be emailed).
We are updating our data retention schedule and it will be published on this site when completed.Ìý We will review our data retention periods for personal information on a regular basis. We also continually review the information that we hold, and delete anything that is no longer required.Ìý
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8.ÌýÌýÌýÌýHow we keep your personal information safe and who has access to it
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, unauthorised access, destruction or damage.
Personal information held by us electronically are stored on secure computer systems and we control who has access to them.Ìý Our staff receive data protection training and we have data protection policies and procedures in place which teams are required to adhere to.
Where we use external companies to collect or process personal data on our behalf, we undertake detailed checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collected or have access to.Ìý ÌýÌý
ÌÇÐĹÙÍø's site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that ÌÇÐĹÙÍø does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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9.ÌýÌýÌýÌýAutomated decision making and processing
Automated decision making involves processing your personal information without human intervention to evaluate your personal situation, such as your personal preferences, interests or behaviour. For instances, in relation to a decision on whether to admit or exclude a pupil from one of our schools. All such decisions regarding your personal information are made by one of our employees. Decisions are therefore not made solely by automated devices.
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10.ÌýYour Data Protection Rights
Under certain circumstances, by law you have the right to:
- Request informationÌýabout whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request accessÌýto your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correctionÌýof the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasureÌýof your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processingÌýof your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processingÌýof your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transferÌýof your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portabilityâ€�). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent.ÌýIn those circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please email the Data Protection Officer:Ìýdata.protection@caretech-uk.comÌýor by post to:ÌýÌÇÐĹÙÍø,Ìý4th Floor, Parkview,Ìý82 Oxford Road,ÌýUxbridgeÌýUB8 1UX.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
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11.ÌýIP addresses and cookies
ÌÇÐĹÙÍø may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. ÌÇÐĹÙÍø may also obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help ÌÇÐĹÙÍø to improve ÌÇÐĹÙÍø's site and to deliver a better and more personalised service.ÌýYou may select which cookies you wish to accept or amend your selections on theÌýCookie DeclarationÌýpage.
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12.ÌýChanges to ÌÇÐĹÙÍø's privacy policy
Any changes ÌÇÐĹÙÍø may make to ÌÇÐĹÙÍø's privacyÌýpolicy in the future will be posted on this page.
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13.ÌýContacting our Data Protection Officer
We have appointed a Data Protection Officer (“DPOâ€�) to oversee compliance with this policy. ÌýYou can make a complaint or raise a concern about how we process your personal information by contacting our Data Protection Officer:Ìýdata.protection@caretech-uk.com.
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14.ÌýYour right to contact the Information Commissioner
If you are not happy with how we have handled your complaint, or you believe that we have not handled your personal information in keeping with the law, you have the right to complain to theÌý, which oversees the protection of personal information in the United Kingdom.Ìý Alternatively, you may choose to contact either the ICO directly about your complaint, regardless of whether you have raised it with us first.
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15.ÌýContact usÌý
Questions, comments and requests regarding this privacy policy are welcomed including enquiries concerning your permission and privacy rights, and should be addressed toÌýData Protection Officer, ÌÇÐĹÙÍø,Ìý4th Floor, Parkview,Ìý82 Oxford Road,ÌýUxbridgeÌýUB8 1UX.Ìýtel:Ìý0208 735 6150.
