Data Protection Policy
This Data Protection Policy sets out the ways we process personal data at English Country Schools (ECS). This policy relates to personal data collected via our website www.countryschools.co.uk; via our enquiry and booking forms, emails and telephone calls; and to our use of data collected through third parties. Any personal data collected by English Country Schools is used in accordance with UK and EU data protection legislation.
TERMS used in this document:
- ‘the school’ 'us' and 'we' is English Country Schools, otherwise known as ECS.
- ‘parent’ is the adult bearing legal responsibility for the child booked onto our course: this may be the parent or another adult such as a guardian or relative.
- ‘data subject’ is the person about whom information is provided. This will typically be a child, parent or member of staff.
By providing personal data to English Country Schools data subjects consent to the processing of such data by English Country Schools as described in this Data Protection Policy.
MAIN DATA PRINCIPLES
• We will request only the data we need and make this purpose clear at the time of collection.
• We will keep physical and electronic data securely and will ensure a secure flow of data within our organisation.
• We will share data within our organisation on a need-to-know basis.
• We will never sell data to a third party.
• When we share data with a third party we will check and review data security regularly.
• We will make it easy for recipients to opt out of receiving marketing communications
• We will make it possible for subjects to view, alter or delete the information we hold about them
Enquirers: We collect names and email addresses to answer general enquiries. Enquirers can choose to be kept informed about our courses.
Parents and children: We collect information about parents and children when a booking is made. We collect information when a payment is made. We collect information about pupils during our courses in order to create records and provide feedback to parents.
Staff: We collect information about staff when they apply for employment. We collect more detailed information about staff after we appoint them. We collect information about staff during courses in order to provide feedback and employment records and references.
We collect, process and store some data with third parties. We endeavour to use third parties with robust data protection measures and regularly review and test the security of such data. We follow generally accepted industry standards to transfer information to and from third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security and canot accept responsibility for data breach by a third party.
In a medical emergency we may need to disclose personal and medical details about a child to a medical professional. Consent for this is requested at the time of booking.
WEB SITE / BROWSER DATA COLLECTION
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring / exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
USE OF PERSONAL INFORMATION
Personal information provided to ECS will be used for the purposes outlined at the time of collection which may include:
- To provide information about our courses
- To put parents in contact with other parents
- Administration of our courses
- Student reports
- Employment records
- Statistical analysis
We reserve the right to disclose personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights, to protect the wellbeing of a child in our care and / or to comply with a judicial proceeding, court order, or legal process served on our Web site.
The rights of children as data subjects and the rights of parents may sometimes conflict. For example parents may tell us things in confidence about their children and children may tell us things in confidence that they do not wish their parents to know. In such cases we will make our own judgement as to what we are willing to disclose, if necessary taking legal advice. A simple privacy notice addressed to pupils is contained in our pre-course documentation (Notes for Pupils) as follows:
>>When your parents make a booking for you to attend ECS they will provide information that we need in order to care for you during your stay. During your stay we will collect information about your performance in class and on the course generally in order to write reports for your parents. We will also collect information about you if you have an accident or if you significantly misbehave. We will need to retain some of this information in case it is required in the future. You have a right to see the data that we hold about you but will make our own judgement about sharing sensitive information.<<
PHOTOS AND VIDEOS
- We ask parents to supply a photo of their child before the course begins. Houseparents also take an up-to-date photo of each child on arrival in their boarding house. These help our staff to identify children by name and are needed in the unlikely event that a child goes missing.
- We believe that photos provide essential feedback for relatives of children attending our courses and that parents have a legitimate interest in seeing their child taking part in our courses. We take photos and videos of pupils for example in lessons and workshops, during excursions and organised activities. We publish these via our public online blog and other social media channels. We also publish them to a password-protected online gallery for pupils and their families to view after they return home.
- Photos and videos are also an essential part of our promotional efforts. We use them to illustrate our brochure, web site and newsletters.
- We will tell children when we intend to take photos or video and respect their wishes not to be included if they state this clearly.
- We take care to avoid taking or publishing indiscreet or demeaning images and we do not include the names of children when we publish their images.
- Children and teenagers tend to group together and move around a lot. Therefore It is difficult for us to always exclude particular individuals from photos and videos. We are not willing to remove particular children from activities we wish to photograph or video and cannot examine every photo and video frame to exclude every incidence of a particular child or children.
- Pupils at ECS have cameras on their phones and like to take photos and videos of each other. We regard this as normal social behaviour. Pupils also sometimes publish their photos and videos on social media. We ask pupils to exercise caution in this but we have no direct control over the images that pupils take of each other and publish.
- Therefore if you send your child to ECS you must accept that your child’s image may appear online.
- However if you prefer us to avoid making your child the centre of attention in a photo or video please write to us before your child attends and we will discuss how best we can comply.
We maintain a public Facebook site for general promotional purposes. We maintain a private Facebook site for our pupils to meet before a course and to maintain contact after a course. We limit membership of our private Facebook site to our own pupils and ex pupils, some who are now adults. Participation is governed by Facebook’s own privacy and safety polices at http://www.facebook.com/policy.php
VIEWING, VERIFYING AND AMENDING YOUR PERSONAL INFORMATION
You can request a copy of all the data we hold about you or your child. This will be supplied within 30 working days at a cost of GBP 10. All marketing communications will contain a link enabling you to opt out of receiving further communications. If your personally identifiable information changes, you may correct, update, or delete the information that we hold about you by contacting us using the details below. If you have made a booking we will send login details that will enable you to edit some of your child's details and check the main booking and financial details that we hold for you and your child. Updating or amendment of personal data will take place within 30 working days of receipt of the request. We are required by law and organisational necessity to retain some information, for example relating to accidents and child safeguarding. This takes priority over the right of data subjects to delete their information and we will exercise our discretion in this regard.
CHANGES IN THIS DATA PROTECTION POLICY
We reserve the right to modify this data protection policy at any time. When we do so, we will indicate this by changing the ‘date of update’ at the end of the policy.
English Country Schools Ltd.
Telephone national: 01242 604067
Telephone international: +44 1242 604067
Updated 25 May 2018