CLIFTON COLLEGE SERVICES LIMITED
PRIVACY STATEMENT FOR CUSTOMERS
- This privacy statement (or fair processing notice) is aimed at customers and explains how Clifton College Services Limited uses Personal Data that is covered by the UK Data Protection Act 1998 (“the Act”). Clifton College Services Limited may amend this statement at any time.
- The purpose of the Act is to safeguard Personal Data. The Act covers issues such as data security, individuals’ rights to access information about them and the use and disclosure of Personal Data.
- For the purposes of the Act, we (“Clifton College Services Limited “) are the “Data Controller” of Personal Data about customers. This means that Clifton College Services Limited is responsible for compliance with the Act.
- Personal Data covers information about individuals, such as information about academic achievements, hobbies and health.
Personal Data processed by Clifton College Services Limited
Clifton College Services Limited may acquire Personal Data in a number of ways. For example:
- customers may provide Clifton College Services Limited with Personal Data about themselves or their family in correspondence, forms, documents, during discussions with staff and through our website;
- we may acquire Personal Data from other customers, or from people outside of our community who know customers; and
- we may acquire Personal Data from third parties such as schools and nurseries, public authorities, public sources or from commercial sources such as credit reference agencies.
- Personal Data processed by Clifton College Services Limited includes contact details, information relating to special educational needs and images of customers engaging in activities, and may include financial information). Clifton College Services Limited may also process Sensitive Personal Data such as information about ethnic group, religious beliefs and relevant medical information.
Purposes for which your data may be processed
Your Personal Data (including Sensitive Personal Data, where appropriate) is processed by Clifton College Services Limited strictly in accordance with the Act in order to:
- ensure that Clifton College Services Limited provides a safe and secure environment;
- protect and promote Clifton College Services Limited’s interests and objectives;
- safeguard and promote the welfare of the customers of Clifton College Services Limited;
- fulfil Clifton College Services Limited’s contractual and other legal obligations;
- support pupils’ teaching and learning;
- assess how well Clifton College Services Limited as a whole is doing;
- where appropriate, promote Clifton College Services Limited to prospective customers (including through the website);
- other reasonable purposes relating to the operation of Clifton College Services Limited.
- Clifton College Services Limited may use Personal Data for other purposes where the Act allows and where providing an explanation would not be appropriate – this includes for the prevention and investigation of crime and the prosecution of offenders.
- Unless you have requested otherwise, Clifton College Services Limited may also use your contact details to send you promotional and marketing information by post or email about Clifton College Services Limited.
- From time to time Clifton College Services Limited may pass your Personal Data (including Sensitive Personal Data where appropriate) to third parties, including local authorities, other public authorities, independent school bodies such as the Independent Schools Inspectorate and the Independent Schools Council, health professionals and Clifton College Services Limited’s professional advisers, who may process the data for the purposes set out above.
Clifton College Services Limited’s aims are:
- To record sufficient information for the applicable purpose, but not unnecessary information.
- To record Personal Data accurately and to keep it up-to-date.
- Not to use Personal Data in ways which are incompatible with the purpose for which it was originally recorded.
- Not to transfer Personal Data outside the European Economic Area unless with the permission of the individual, or has made appropriate arrangements with the recipient to ensure that the individual’s privacy rights are protected.
- To have appropriate security arrangements in place to help prevent any unauthorised use of, or accidental loss or damage to, Personal Data. This includes using encryption and other technologies where appropriate.
- To dispose of Personal Data appropriately after it is no longer needed. This includes:
(a) shredding papers where appropriate; and
(b) permanently deleting information from computers and memory devices before they are disposed of.
- To be fair to the subject of the information and to whoever provides it (if that is someone else).
Data protection compliance: specific examples
- Clifton College Services Limited uses CCTV recordings for the purposes of crime prevention and investigation and also in connection with the College’s obligation to safeguard the welfare of visitors to our buildings.
- CCTV recordings may be disclosed to third parties such as the police but only where such disclosure is in accordance with the Act.
- Clifton College Services Limited may use photographs in our publications for marketing purposes (but we will not publish the name of the customer alongside the photo without consent).
Customer Statutory Rights
- Subject Access Request: Customers, as data subjects, have certain rights under the Act, including a general right to be given access to Personal Data held about them by any data controller. Often by the age of 12 a child has sufficient maturity to understand his/her rights and to make an access request themselves if he/she wishes (in which case the request should come from the child, not the parent). A parent would normally be expected to make a request on the child’s behalf if the child is younger. If you wish to access your Personal Data, or that of your child or a customer for whom you have parental responsibility, then please contact Clifton College Services Limited in writing. Clifton College Services Limited will respond to a request within 40 days from when we receive the request in writing or alternatively from the date when we receive any further information reasonably requested by us and (if we ask for it) the statutory fee (usually £10).
- Corrections: Customers have a statutory right to ask for incorrect Personal Data to be corrected or annotated.
- ICO website: Further details of the Personal Data that Clifton College Services Limited holds, and how we use it, can be found in our registry entry on the Information Commissioner’s website at ico.gov.uk under registration number Z5846821. This website also contains further information about data protection.
- If you have any queries about this privacy statement or about how Personal Data is processed by Clifton College Services Limited, please contact:
|Authorised by||Richard Avery|
|Effective date of the policy||October 2014|
|Review date||On each anniversary of the effective date of the policy and immediately following any data protection related incident.|
|Circulation||Clifton College Services Limited website|
|Status||Complies with the Data Protection Act 1998.|