Privacy Policy

Summary Privacy Notice

This summary is to help you understand how and why we collect personal information and what we do with that information when you enquire about a place at The Unicorn School for your child. If you have any questions about this notice, please contact the Bursar at bursar@unicornoxford.co.uk

This summary is intended to provide information about how we will use (or “process”) personal information about prospective pupils (“pupils”) and their parents, carers or guardians (“parents”). This information is provided in accordance with the rights of individuals under Data Protection Law to understand how your personal information is used. You are encouraged to read the full Privacy Notice for Parents and Pupils below and understand our obligations to you. We have also produced a pupil-friendly summary document of the privacy notice for pupils to read – available on request.

This summary applies when collecting information via any online enquiry form on the website, via email, telephone enquiries and/or any paper form. Anyone who works for, or acts on behalf of, the School (including staff, volunteers, governing council members and service providers) are made aware of and should comply with our Privacy Notice and our data protection procedures.

What is personal information?

Personal information, often referred to as data, is information that identifies you as an individual. This includes information such as your contact details, dates of birth and financial information.

Why we collect and use your personal information

Our primary reason for using personal information is to provide education services and to respond to requests for information about joining the school. We therefore have a legitimate interest for processing basic personal information and sensitive information. We will hold the minimum that is required to form and maintain the contact between us.

We may ask for your consent to use your information in certain ways

If we ask for your consent to use your personal information in relation to an enquiry for a place at The Unicorn School you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please contact the Bursar or Registrar if you would like to withdraw any consent given: bursar@unicornoxford.co.uk or registrar@unicornoxford.co.uk.

How long we keep personal information

We will keep personal information securely. The table below gives an example:

*Subject to safeguarding considerations: any material which may be relevant to potential claims should be kept for the lifetime of the pupil.

If you have any queries about how our retention policy is applied, or wish to request that personal information that you no longer believe to be relevant is considered for erasure, please contact the Registrar.

A limited and reasonable amount of information will be kept for archiving purposes. For example, where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a “suppression record”).

Consent

If we are relying on your consent as a means to process personal information, you may withdraw that consent at any time.

What decisions can you make about your information?

• if information is incorrect you can ask us to correct it;
• you can also ask what information we hold about you and be provided with a copy;
• you can ask us to delete the information that we hold about you in certain circumstances, for example, where we no longer need the information;
• our use of information about you may be restricted in some cases, for example, if you tell us that the information is inaccurate, we can only use it for limited purposes while we check its accuracy.

There is no automated decision-making or profiling involved in your enquiry process.

QUERIES AND COMPLAINTS

The Bursar is the person responsible at The Unicorn School for managing how we look after personal information and deciding how it is shared. Like other organisations we need to keep your information safe, up to date, only use it for what we said we would, destroy it when we no longer need it and most importantly, treat the information we get fairly.

Any comments or queries on this policy should be directed to the Bursar: bursar@unicornoxford.co.uk.

If you believe that we have not complied with this policy or acted otherwise than in accordance with Data Protection Law, you can make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator.

Full Privacy Notice

WHO WE ARE

The Unicorn School (“the school”) is an independent specialist day school for girls and boys aged 6 to 16 years who have Specific Learning Difficulties: dyslexia, dyspraxia, dyscalculia and Speech, Language and Communication Needs (SLCN).). The School is registered under the Companies Act, and the Charity Commission and is controlled by its Board of Governors.

This Privacy Notice is intended to cover The Unicorn School and the activities of the Friends of The Unicorn School (“FoTU”), and the Parents’ Association of The Unicorn School, both of which are unincorporated bodies.

WHAT THIS PRIVACY NOTICE IS FOR

This policy is intended to provide information about how the school will use (or “process”) personal data about individuals including: its staff; its current, past and prospective pupils; and their parents, carers or guardians (referred to in this policy as “parents”). Collectively, we refer to these individuals in the Privacy Notice as the school’s community.

This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents and pupils are all encouraged to read this Privacy Notice and understand the school’s obligations to its entire community. However, the school has a separate Data Protection policy and Privacy Notice applicable to its employees and other staff.

This Privacy Notice applies alongside any other information the school may provide about a particular use of personal data, for example when collecting data via an online or paper form.

This Privacy Notice applies in addition to the school’s other relevant terms and conditions and policies, including:

• any contract between the school and its staff or the parents of pupils;
• any policies or notices applicable to staff concerning the handling of personal data;
• the school’s policy on taking, storing and using images of children;
• the school’s CCTV policy;
• the school’s Data Protection Policy (staff) and Data Protection Policy (parents);
• the school’s safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
• the school’s IT policies, including its Acceptable Use of IT policy and eSafety policy.

Anyone who works for, or acts on behalf of, the school (including staff, volunteers, governors and service providers) will be subject to suitable training and/or policies commensurate with their role.

RESPONSIBILITY FOR DATA PROTECTION

The school has appointed the Bursar as Privacy and Compliance Officer who will deal with all your requests and enquiries concerning the school’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.

The bursar can be contacted via email at bursar@unicornoxford.co.uk or by phone on 01235 530222.

WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA

In order to carry out its ordinary duties to staff, pupils and parents, the school needs to process a wide range of personal data about individuals (including current, past and prospective staff, pupils or parents) as part of its daily operation.

Some of this activity the school will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its staff, or parents of its pupils.

Other uses of personal data will be made in accordance with the school’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.

The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:

• For the purposes of pupil applications (and to confirm the identity of prospective pupils and their parents), and retain a record if appropriate for the purposes of future admissions;
• To provide education services, including musical education, physical training or spiritual development, career services, and extra-curricular activities to pupils, and monitoring pupils’ progress and educational needs;
• Maintaining relationships with alumni and the school community, including direct marketing or fundraising activity;
• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis);
• To enable relevant authorities to monitor the school’s performance and to intervene or assist with incidents as appropriate;
• To give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils;
• To enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the school;
• To safeguard pupils’ welfare and provide appropriate pastoral care;
• To monitor (as appropriate) use of the school’s IT and communications systems in accordance with the school’s Acceptable Use of IT policy;
• To make use of photographic images of pupils in school publications, on the school website and (where appropriate) on the school’s social media channels in accordance with the school’s policy on taking, storing and using images of children;
• For security purposes, including CCTV in accordance with the school’s CCTV policy;
• To carry out or cooperate with any school or external complaints, disciplinary or investigation process; and
• Where otherwise reasonably necessary for the school’s purposes, including to obtain appropriate professional advice and insurance for the school.

In addition, the school will on occasion need to process special category personal data (concerning health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required. These reasons will include:

• To safeguard pupils’ welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other information where it is in the individual’s interests to do so: for example for medical advice, for social protection, safeguarding, and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a pupil;
• In connection with employment of its staff, for example DBS checks, welfare, union membership or pension plans;
• As part of any school or external complaints, disciplinary or investigation process that involved such data, for example if there are SEN, health or safeguarding elements; or
• For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.

TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL

This will include by way of example:

• names, addresses, telephone numbers, e-mail addresses and other contact details;
• car details (about those who have parking permits for The Ock Mill or The Royal British Legion or who park on our site);
• bank details and other financial information, e.g. about parents who pay fees to the school, and any money laundering information we are required to collect by law;
• past, present and prospective pupils’ academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
• personnel files, including in connection with academics, employment or safeguarding;
• where appropriate, information about individuals’ health and welfare, and contact details for their next of kin;
• references given or received by the school about pupils, and relevant information provided by previous educational establishments and/or other professionals or organisations working with pupils;
• correspondence with and concerning staff, pupils and parents past and present; and
• images of pupils (and occasionally other individuals) engaging in school activities, and images captured by the school’s CCTV system (in accordance with the school’s policy on taking, storing and using images of children);

HOW THE SCHOOL COLLECTS DATA

Generally, the school receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments).

However in some cases personal data will be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from publicly available resources.

WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT WITH

Processing by third parties: For the most part, personal data collected by the school will remain within the school, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). However, some functions are outsourced including e.g. IT, cloud storage. In accordance with Data Protection Law, this type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with the school’s specific directions.

Data Sharing: Occasionally, the school, including its Governing Body, will need to share personal information relating to its community of staff, pupils and parents with third parties such as:

• appropriate contractors, such as external therapists or visiting teachers
• professional advisers (eg IT subcontractors, lawyers, insurers and accountants),
• examination boards,
• government authorities (HMRC, DfE, CAFCASS, police or the local authority), and
• appropriate regulatory bodies (e.g. Ofsted, ISI, The Charity Commission or the Information Commissioner).
• If you are a parent and a member of the Parents’ Association (PA), the school may share by email, for specific purposes, your contact details with the PA. The PA will be a separate data controller and the school is not responsible for the PA’s processing of personal data.
• Occasionally the school governors will need to process parent or pupil information, such as when a complaint is raised (and in accordance with the School Complaints Procedure, this may also require the involvement of independent panel members).

ACCESS TO SENSITIVE DATA

Particularly strict rules of access apply in the context of “special category” data, most notably:

• medical records; and
• pastoral or safeguarding files.

Medical data: The school needs to process such information to comply with statutory duties and to keep pupils and others safe, but the school will ensure only authorised staff can access information on a need-to-know basis. This may include wider dissemination if needed for school trips or for catering purposes. Express consent will be sought where appropriate.

However, a certain amount of any pupil’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and tailored education that the pupil requires.

Safeguarding data: Staff, pupils and parents are reminded that the school is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the LADO or police.

KCSIE also requires that, whenever a child leaves the school to join another school or college, his or her child protection file is promptly provided to the new organisation. The school will retain a copy in accordance with its retention policy for material related to safeguarding matters.

Data Sharing: In accordance with Data Protection Law, some of the school’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.

HOW LONG WE KEEP PERSONAL DATA

The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary staff and pupil personnel files is up to 7 years following departure from the school. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.

If you have any specific queries about our retention policy, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Bursar via email at bursar@unicornoxford.co.uk. However, please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such a request.

A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a “suppression record”).

KEEPING IN TOUCH AND SUPPORTING THE SCHOOL

The school will use the contact details of parents, alumni and other members of the school community to keep them updated about the activities of the school, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, the school will also:

• Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the school community, such as the Friends of The Unicorn School, or our Parents’ Association;
• Contact parents and/or alumni (including via the organisations above) by post and email in order to promote and raise funds for the school;
• Collect information from publicly available sources about parents’ and former pupils’ occupation and activities, in order to maximise the school’s fundraising potential.
• Should you wish to limit or object to any such use, or would like further information about them, please contact the Bursar in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).

YOUR RIGHTS

Rights of Access

Individuals have various rights under Data Protection Law to access and understand personal data about them held by the school, and in some cases ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it, but subject to certain exemptions and limitations.

The school will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is generally one month, but actually fulfilling more complex or multiple requests, e.g. those involving third party information, may take 1-2 months longer).

The school will be better able to respond quickly to smaller, targeted requests for information made during term time. If the request for information is manifestly excessive or similar to previous requests, the school may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).

If you consider that the personal data we hold on you is inaccurate, please let us know. However, the school will not necessarily delete or amend views, opinions, notes or records purely on the request of an individual who disputes the account, although we may keep a record of all parties’ viewpoints.

Requests that cannot be fulfilled

You should be aware that GDPR rights (including the right of access) are limited to your own personal data, and certain data is exempt. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations – [please see further below]), or information which is subject to legal privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).

The school is also not required to disclose any pupil examination scripts (or other information consisting solely of pupil test answers – although markers’ comments may still be disclosable if they constitute pupil personal data); provide examination or other test marks ahead of their ordinary publication date; nor share any confidential reference held by the school that was (or will be) given for the purposes of the education, training, appointment or employment of any individual.

You may have heard of the “right to be forgotten”. However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child’s) personal data: for example, a legal requirement, or where it falls within a proportionate legitimate interest identified in this Privacy Notice. Generally, if the school still considers the processing of the personal data to be reasonably necessary, it is entitled to continue. All such requests will be considered on their own merits.

Requests by or on behalf of pupils

Pupils can make subject access requests for their own personal data, provided that, in the reasonable opinion of the school, they have sufficient maturity to understand the request they are making (see section Whose Rights? below). A pupil of any age may ask a parent or other representative to make a subject access request on his/her behalf.

Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of younger pupils, the law still considers the information in question to be the child’s. For older pupils the parent making the request may need to evidence their child’s authority for the specific request. Requests not considered in the child’s best interests may sometimes be refused.

Pupils aged about 13 and above are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Slightly younger children may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.

Parental requests

It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about pupils without their consent. The school may consider there are lawful grounds for sharing with or without reference to that pupil.

Parents will in general receive educational and pastoral updates about their children, in accordance with the Parent Contract. Where parents are separated, the school will in most cases aim to provide the same information to each person with parental responsibility, but may need to factor in all the circumstances including the express wishes of the child, court orders or pastoral issues.

All information requests from, or on behalf of, or concerning pupils – whether made under subject access or simply as an incidental request – will therefore be considered on a case by case basis.

Consent

Where the school is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Examples where we do rely on consent include certain types of uses of images. Please be aware however that the school may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.

That reason will usually have been asserted under this Privacy Notice, or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents’ association has been requested).

WHOSE RIGHTS?

The rights under Data Protection Law belong to the individual to whom the data relates. However, the school will often rely on parental authority or notice for the necessary ways it processes personal data relating to pupils – for example, under the parent contract, or via a form. Parents and pupils should be aware that this is not necessarily the same as the school relying on strict consent (see section on Consent above).

Where consent is required, it may in some cases be necessary or appropriate – given the nature of the processing in question, and the pupil’s age and understanding – to seek the pupil’s consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances.

In general, the school will assume that pupils’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil’s activities, progress and behaviour, and in the interests of the pupil’s welfare. That is unless, in the school’s opinion, there is a good reason to do otherwise.

However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the school may be under an obligation to maintain confidentiality unless, in the school’s opinion, there is a good reason to do otherwise; for example where the school believes disclosure will be in the best interests of the pupil or other pupils, or if required by law.

Pupils are required to respect the personal data and privacy of others, and to comply with the school’s Acceptable Use of IT policy and the school rules.

DATA ACCURACY AND SECURITY

The school will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the school office or Bursar of any significant changes to important information, such as contact details, held about them.

An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the school may need to process your data, of who you may contact if you disagree.

The school will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training.

THIS POLICY

The school will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.

QUERIES AND COMPLAINTS

Any comments or queries on this policy should be directed to the bursar via email at bursar@unicornoxford.co.uk or via the school office.

If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should follow the school complaints procedure and should also notify the bursar. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the school before involving the regulator.

Member of staff: Bursar
Reviewed: September 2022
Next review date: September 2023