Privacy

Policy Statement 1: Privacy Notice Formerly known as Fair Processing Notice

Version 2 22.05.18

 

Springboard North Wilts Opportunity Group are committed to protecting and respecting your privacy.

(The information Springboard Opportunity Group collects, holds and stores)

 

This policy, together with any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy meets the requirements of the Data Protection Act (DPA) 1998 and is based upon guidance published by the Information Commissioners Office (https://ico.org.uk/) the UK’s Regulatory body.  It takes into account GDPR (General Data Protection Regulation) which is due to come into force in May 2018.

 

Data Controller

As Springboard processes personal data relating to its children, families, staff, volunteers and visitors, Springboard is defined as a Data Controller for the purposes of the Data Protection Act. 

 

Data Protection Principles

The Data Protection Act 1998 is based on the following data protection principles, or rules for good data handling:

  • Data shall be processed fairly and lawfully
  • Personal data shall only be obtained for one or more lawful purposes
  • Personal data shall be relevant and not excessive in relation to the purpose(s) for which it is processed
  • Personal data shall be accurate and where necessary up to date
  • Personal data shall not be kept longer than guidelines state
  • Personal data shall be processed in accordance with the rights of the data subjects under the Data Protection Act 1998
  • Appropriate technical and organisation measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data
  • Personal data shall not be transferred to a country or territory outside of the European Economic Area unless the country or territory ensures an adequate level of protection for the rights and freedoms of data in relation to the processing of personal data

 

Roles & responsibilities

The Springboard Management committee has the responsibility of ensuring that Springboard complies with the obligations under the Data Protection Act 1998.

Day to day responsibilities lie with the Manager and the Data Protection Officer, whom act on behalf of the Management Committee.  They ensure all staff are aware of their data protection obligations and oversee any queries related to the storing and processing of personal data.

Staff are responsible for ensuring that they collect and store any personal data in accordance with this policy.

 

Privacy/ fair processing notice

Springboard has a separate child privacy notice for children over the age of 13.

 

Data Springboard holds includes:-

  • Personal data- name, address, contact information. (Data from which a person can be identified).
  • Child’s diagnosis, health, medical and developmental information.
  • Some data defined as ‘special classes’- these include ethnicity, genetic information (diagnosis) and medical conditions/ health information.

 

Why do we have and process data at Springboard?

 

  • To support a child’s development
  • Monitor and report on a child’s progress
  • Provide appropriate support and care,
  • Assess how well we are doing as a setting

 

This information includes a child‘s contact details, assessment results and personal characteristics such as ethnicity, special educational needs and any relevant medical information.

 

We may also receive information about the children from other organisations including, but not limited to other schools, Wiltshire Council (Local authority) and the Department for Education (DfE).  Springboard will only retain the data it receives for as long as necessary to satisfy the purpose for which it has been collected.

 

We will not give or share information about an individual to anyone outside of Springboard without prior consent unless the law dictates and information sharing protocols require us to. 

 

We are required by law to pass some of a child’s information to the Local Authority and the Department for Education (DfE)

 

There are six lawful legal basis for processing data. Springboard processes data from the following four categories:-

 

(a) Consent: the individual has given clear consent for us to process their personal data for a specific purpose.  This could be the consent to take a photograph and to use the photo in a defined way.

(b) Contract: the processing is necessary for a contract we have with the individual, for example a work experience or student placement

(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations) for example the retaining of paperwork for the specified legal timeframes.

 (d) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.  For example sending a newsletter to a past donor/ supporter.

Under the Freedom of Information Act an individual can ask to have a copy of the information held on them/ their child. This is called a Subject Access Request (SAR) and should be made in writing to the manager or Springboard’s Data Protection Officer- (DPO) Anne Farrell.  Contact can be made by email business@springboardchippenham.co.uk or by calling 01249 657145.  The written request should include a correspondence address, contact number, email address and details about the information requested. The information will be provided electronically unless a hard copy has been specifically requested.  No charge will be made for the first copy. The documents will be provided within one calendar month.  ID will need to be shown by the person making the SAR to confirm their identity.  The timeline begins once their ID has been verified.  Parents have the right to access their child’s personal data free of charge within 15 term days of the request.  The personal data belongs to the child and not the child’s parents. This is the case when the child is too young to understand the implications of subject access rights.  For a parent to make a subject access request, the child must be able to understand their rights and the implications of a subject access request, or have given their consent.

The Information Commissioner’s Office, the organisation whom upholds information rights, generally regards children aged 12 and above as mature enough to understand their rights and the implications of a subject access request.  Therefore, most subject access requests from parents of children accessing Springboard would be granted without the permission of the child.

 

Springboard will always ask for parental consents. These include consent taking photos for use in the setting and for publicity, the sharing of records with other professionals, administering medication, outings, first aid, face painting and applying sun screen.  These consents will all be asked at the point of registration of a child, (the starting process with Springboard) and usually annually therein.  Parents will be given specific information regarding each of the consents and are asked to tick a box for each consent. This ensures that the process is clear and informed.

Written consents are obtained regularly whenever data is shared. This ensures that the consents are specific and parents can make an informed choice and the decision is freely given. For example a Team Around the Child (TAC) meeting, parents will be asked to consent to the meeting, agree the invitee list and also consent to the agreed minutes being shared.  Springboard has to be able to demonstrate consent was given and to be able to show an effective audit trail.

 

Staff

Springboard processes data relating to those employed to work at Springboard. The purpose is to enable Springboard to operate and to:

  • Enable individuals to be paid (data is shared with Sage, HMRC, Auto-enrolment and NEST)
  • Facilitate safe recruitment including but not limited to- DBS checks, references

 

Staff personal data includes but is not limited to: information such as:

  • Contact details
  • National Insurance numbers
  • Salary Information
  • Qualifications

 

Personal data is retained as detailed in the data storage table within this document.

 

 

Trustees

Springboard processes data relating to those whom volunteer as Trustees for Springboard. The purpose is to enable Springboard to operate and to:

  • Facilitate safe recruitment including but not limited to- DBS checks, references
  • Completing annual returns for Companies House and the Charities Commission

 

Trustee personal data includes but is not limited to: information such as:

  • Contact details
  • National Insurance numbers
  • Date of birth

 

Personal data is retained as detailed in the data storage table within this document.

 

Volunteers

Springboard processes data relating to those whom volunteer at Springboard. The purpose is to enable Springboard to operate and to:

  • Facilitate safe recruitment including but not limited to- DBS checks, references

 

Volunteer personal data includes but is not limited to: information such as:

  • Contact details
  • Medical information
  • Date of birth
  • Qualifications

Personal data is retained as detailed in the data storage table within this document.

 

Website

Springboard will collect and process the following categories of information /data about you:

 

  • Information you give us. This is information about you that you give us by filling in the contact form on the website (Site), interacting with the Site or by corresponding with us by phone, e-mail or otherwise. The information you give us will include your name, address, e-mail address and phone number.
  • Information we collect about you. This is information that we collect automatically about your visit during your time on the Site. It typically involves technical information and is often collected using small data files called “cookies”. This information helps us to provide you with a good experience when you browse the Site and also to indicate where the Site requires improvement.

More information on how cookies work, what cookies we use and why can be found in our Cookie Policy (see separate policy).

Social Media platforms

We operate social media platforms. These platforms are, in most cases, operated outside of the EU and do not comply with current Data Privacy Act and subsequent GDPR provision although they may well conform to the U.S Privacy Shield protocol.

It is our process and protocol that any personally identifiable data gathered on these platforms is only in response to users interacting out of their own volition with our social media pages. The contact is deemed as a legitimate business enquiry. Any personal contact data is removed from the site once the enquiry is processed or the user has requested so.

Analytics

Our website uses Google Analytics to collect information about how visitors use our website. We anonymise this data at the point of collection and automatically delete user and event data that is older than fourteen months.

Uses made of the information

All information about you that we collect or receive, whether of a personal or technical nature, may be used by us in the following ways:

 

  • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, services that you request from us;
  • To administer the Site and for internal operations, including troubleshooting, system and security updates, data analysis, testing, research, statistical and survey purposes;
  • To improve the Site to ensure that content is presented in the most effective manner for you and for your computer;
  • To allow you to participate in interactive features of our service, when you choose to do so;
  • As part of our efforts to keep the Site safe and secure;
  • To comply with our record keeping and information storage obligations and policy (please see the “Where We Store Your Personal Data” section below for more details).

 

Disclosure of your information

We will only share anonymised information with:

  • Analytics and search engine providers that assist us in the improvement and optimisation of the Site;
  • Third party support services, such as, but not limited to project management tools, accounting systems and hosting data centre.

 

We will disclose your personal information to third parties:

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or
  • To protect our rights, property or safety, or those of our clients or others.

 

Where we store your personal data

All information that you provide to us is stored on our, secure servers, and we will take reasonable steps to protect your information in accordance with this policy, including (without limitation):

  • Installing a secure firewall;
  • Using anti-virus protection software;
  • Encrypting data; and
  • Carrying out regular back-ups.

 

All data sent via website forms is passed through a third party relay service and deleted after 30 days.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Site; and any such transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The Site may, from time to time, contain links to and from the websites for other agencies we work alongside.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

General Data Protection Regulation (GDPR)

Springboard acknowledges GDPR will come into effect from May 2018, expanding upon the current DPA. The GDPR will harmonise the law between the European countries and expand to the current legislation to incorporate all the technology advances since 1995.

GDPR will still apply when the UK leaves the EU, as the regulation applies to all European citizens wherever they live.

 

The GDPR gives individuals increased rights and these include

  • The right to have their personal data deleted. An individual can request to have their data erased or deleted this applies to be both hard copies and electronic documents held.  Requests should be made directly in writing to either the manager or to the DPO.  The Manager and the DPO would review all their data held at Springboard.  As Springboard has a legal duty to maintain essential data not all data would be deleted, but Springboard would minimise what was held in accordance with the request.

 

  • Data portability- individuals have a right to their data being transferred in an accessible form. This would be applicable when families move out of the area or transfer into another pre-school or school. Springboard will always use standard formats e.g. PDF, Word and Excel documents. Security will always remain a priority and documents would be password protected if sent electronically. The data would be sent to a mutually agreed destination e.g. email address or storage media destination.

 

  • Right to have inaccuracies changed- a person has the right to the correct information being held about them. Errors or inaccuracies would be updated in a prompt timeframe, according to the usual working patterns of Springboard personnel. An annotation would be added to the records to state what correction has been made, when and by whom, in order to provide a full audit trail.

 

  • Parents/ carers provide consent due to the age of the children attending Springboard. In order to verify the age of the children attending Springboard, birth certificates are requested and checked for verification.

 

  • Stricter consents are required for text and email contact. Recipients of general emails will always be able to opt out and stop future contact. It should be clear that recipients have a choice to receive documentation.

 

Our Data Retention Procedures are as follows:

 

Secure storage and retention of all Data

Storage and access

Hard copies of personal data must be kept securely, in lockable, non-portable, storage containers with controlled access from authorised personnel.

 

Papers containing confidential and personal data should not be left on a printer, on a desk, in an office, on a notice board, where there is general access.

 

Where information needs to be taken off site (in paper or electronic form) staff must have this authorised by the manager and sign it in and out.

Trustees whom store personal information on personal devices must follow the same security procedures.

 

‘Personal’ data is not held locally on any IT device, but stored centrally and protected by passwords, third party security firewalls and security software.

Due to the working practices, there may be some photographs temporarily stored locally on playroom tablets, which are password protected.  Procedures must be followed to ensure the retention periods are followed to minimise the photographs held locally.

All staff are responsible for uploading and downloading data to ensure all data is stored securely.  All devices are protected by passwords which are changed every six months, or when a member of staff leaves.

 

Access to electronic data is restricted to the relevancy of each member of staff and their individual role and responsibilities

A back up of all electronic data is kept securely locked in the safe on site.  Only the Manager and the DPO have access.

 

Handling

To protect the identity of the children, they are referred to by their initials.  If more than one child has the same initials, the first two letters of their first name and the first two letters of their surname will be used to identify them. The Initials are used when sending out emails, meeting requests and general correspondence to multi-agency professionals to reduce the risk of the data being linked to a person.

When sending a document electronically, it is password protected and the password sent by a separate email.

 

Electronic documents are password protected before sending. The password is sent in a separate email, however the password could be sent using alternative mediums e.g. phone, and text.  If it is not possible to send an electronic document securely, a hard copy should be sent by post but only to a confirmed and known individual and to a known address.

 

Retention

Data is retained in accordance to the Data retention table below, this applies to both hard copies and electronic files kept. The archiving procedure must be followed and a retention date clearly labelled.

 

Disposal

Once the retention period has elapsed, Springboard will ensure all data is destroyed by secure means, e.g. by shredding, pulping or burning.  Files for destruction will be identified by a destruction date.  There will be an administration period required for physically destroying the files this could be several months due to term time only operations.

 

Data Storage
Document Retention Period
Child Individual Files Minimum 6 years from end of placement.

Recommended until the child is 21

Child Child Protection Files 24 years
Setting Press Clipping 6 months
Setting Newsletters 2 years
Setting Team meeting minutes Minimum 10 years
Setting Management meeting minutes Minimum 10 years

Recommended permanently

Setting Health and Safety documentation (risk assessments /accident records)

 

Minimum 7 Years

RIGGOR related Minimum 40 years

COSHH related minimum 40 years

Setting Complaint reports 10 years
Setting Registers 50 years
Setting Building records 10 years
Setting Records relating to accident or injury at work Minimum 12 years
Setting Office Accounts – this includes the name of people whom have made donations. Minimum 7 years
Setting Old Insurance policies/certificates 40 years
Staff Application Form Duration of Employment
Staff References received 1 year
Staff Records relating to promotion, transfer, training, disciplinary matters 7 years from the end of employment
Staff Annual Leave Records 2 years
Staff Sickness Records 3 years
Staff Unpaid leave/special leave records 3 years
Staff Appraisal /assessment records 5 years
Staff References given 5 years from end of employment
Staff Payroll and tax information 6 years from end of employment
Staff Summary of record of service, i.e. name, position held , dates of employment 7 years from the end of the employment
Staff Individual supervision notes 7 years

 

More information is available from

http://www.wiltshire.gov.uk/index.htm

http://www.teachernet.gov.uk/management/ims/datamanagement/privacynotices/pupilsdata/

http://www.teachernet.gov.uk/management/ims/datamanagement/privacynotices/pupilsdata/thirdpartyorgs/

or: Contact Wiltshire Council -01225 713000

Or     Public Communications Unit
Department for Education
Sanctuary Buildings
Great Smith Street
London
SW1P 3BT

Website:             www.education.gov.uk           email:              info@education.gsi.gov.uk
Telephone:         0870 000 2288

 

If there are any concerns with regards to Springboard‘s handling of personal data then contact should be made to either Springboard‘s Data Protection Officer- Anne Farrell or the UK’s regulatory body ICO (Information Commisioners Office) on 0303 123 1113

 

Data Breach

Data Breach- if a member of staff, volunteer or trustee sees or makes a data breach this must be highlighted to the Data Protection Officer (DPO) and the Manager immediately. The DPO and the Manager will investigate the breach, change procedures as appropriate to prevent future breaches and report to the ICO if applicable.  Data breaches must be reported to the ICO within 72 hours if there is an individual is likely to suffer damage, for example identity theft or a confidentiality breach.  The ICO must be informed of the nature of the breach, the number of data subjects, the categories of data and the proposed mitigation.

A letter should be written to all the subjects whose data has been breached (a template is available on the ICO’s website), an apology should be made and also practical advice concerning the breach.

Possible breaches would be: an email circulation list not hidden, so all recipients can see each other’s email addresses, this would be a breach but not reportable. A confidential document concerning a child, not password protected and sent to the wrong person, would be a breach.

Failure to report a breach would result in a fine, in addition to a fine for the breach itself.

 

Secure Storage, Handling, Use, Retention & Disposal of Disclosures and Disclosure Information

 

General Principles

As an organisation using the Disclosure Barring Service (DBS) to help assess the suitability of applicants for positions of trust, Springboard Opportunity Group complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure Information.

Springboard complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information for all its documents/ records and has a written policy on these matters, which is available to those who wish to see it on request.

Storage and access

Disclosure information should be kept securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties. At Springboard this is Manager /Deputy and/or Business Administrator

Handling

In accordance with Section124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties.  We maintain a record of all those to whom Disclosures or Disclosure information has been revealed and it is a criminal offence to pass this information to anyone who is not entitled to receive it.

Usage

Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

Retention

Once a recruitment (or other relevant) decision has been made, we do not keep Disclosure information for any longer than is necessary.  This is generally for a period of a year, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep Disclosure information for longer than a year, we will consult the DBS about this and will give full consideration to the data protection and human rights of the individual before doing so.  Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.

Disposal

Once the retention period has elapsed, we will ensure that any Disclosure information is immediately destroyed by secure means, e.g. by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).  We will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure. However, notwithstanding the above, we may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.

 

Privacy Impact Assessments

Privacy Impact Assessments (PIAs) demonstrate good working practice.  The DPO and the Manager will use the assessment tool, a standardised template to analyse current processes in order to comply with the GDPR by identifying risk areas and reducing the risks. When new processes or technology is implemented it is paramount a PIA is completed at the implementation stage to minimise any possible risk of data breach.  A PIA can demonstrate to the ICO, how Springboard complies with the DPA/GDPR and also reduce the likelihood of Springboard failing to meet its legal duties.  A log, listing all the PIAs completed will be maintained.

The PIA assessment template can be found using the link below-

https://ico.org.uk/media/1042836/pia-code-of-practice-editable-annexes.docx

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be updated on our website www.springboardchippenham.co.uk.

 

Cross reference policies

Accident Reporting  – Admissions

Safeguarding Children – Allegations Against Staff

Equality and Diversity – Whistleblowing

Comment, Compliments and Complaints – Confidentiality

SEN – Working With Parents

Conflict of Interest – Looked After Children

E-Safety – Staff Safety

Disciplinary and Dismissal – Grievance

Staff well being – Competency and Capability

 

This policy was adopted at a meeting of Springboard Opportunity Group’s Management Committee

Held on:  May 2018                            Date to be reviewed:  May 2019

Signed By:

Name of signatory:  Paul Sweet         Role of signatory:        Chairman

 

Cookie policy

 

Our website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse our website and also allows us to improve the website.

 

By continuing to browse the website, you are agreeing to our use of cookies as set out by this policy.

1.    Information about cookies

 

A cookie is a small file of letters and numbers that, if you agree to their use, is stored on your browser or the hard drive of your computer or device.  They contain information that is transferred to your hard drive.

The cookies that we could use can be split into the following categories:

 

  • Necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into parts of the website.

 

  • Analytical cookies. These cookies allow us to recognise and count the number of visitors to the website and to see how they move around within the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.

 

  • Third party cookies. These are used to third parties (such as Google) to enable their services to work, for example Google Captcha on forms or Google Maps. Some third parties use their cookies for advertising purposes. We have no control over these cookies and provide a link to the third party’s privacy policy, where you may have the option to opt-out of their data collection.

 

We use the following cookies:

Category Cookie Name Purpose
Necessary Cookies PHPSESSID Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.
Necessary Cookies cookiesAccepted Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.
Necessary Cookies cookiesAcceptedGoogle Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.
Necessary Cookies cookiesAcceptedAnalytics Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.
Analytical cookies '_ga','_gat_gtag_UA_110087179_1','_gid' Used to see how our website users navigate the site
Google 'NID' Used by Google for delivering Google Maps on the website

 

Please note third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.  These cookies are likely to be analytical/performance cookies or targeting cookies.

3.    How you can block cookies

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, please be aware that blocking cookies may affect your ability to use the website.  In particular, you may not be able to access all or parts of the website or use the functionalities contained on it.

 

By visiting this website, you are accepting and consenting to the practices described in this policy.

  1. Data Collection Points

The website has several data collection points which use cookies, please refer to the relevant third parties for their privacy /cookie policies

(YouTube & Vimeo)    https://vimeo.com/privacy

 

For the purpose of the Data Protection Act 1998 (Act), the data controller is , a company registered in England and Wales under company number 2698820, with its registered office Springboard North Wilts Opportunity Group, Kings Rise Centre, lodge Road, Chippenham, Wilts, SN15 3SY.

We are a registered data controller with the Information Commissioner’s Office.If there are any concerns with regards to Springboard‘s handling of personal data please contact Springboard‘s Data Protection Officer- Anne Farrell Contact can be made by email business@springboardchippenham.co.uk or by calling 01249 657145.

This policy was adopted at a meeting of Springboard Opportunity Group’s Management Committee

Held on:  May 2018                            Date to be reviewed:  May 2019

Signed By:

Name of signatory:  Paul Sweet         Role of signatory:        Chairman