Policies & Statements
Privacy Statement
The General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 give you the right to be informed about how we process your personal information. The information below supports this right.
Intro
Education Training Collective is the data controller for purposes of data protection. We are committed to protecting the personal information of all our staff, students, parents, visitors, employers, partners and the general public. We recognise our obligations to keep personal information secure and believe it is important for you to know how we treat personal information.
Who is Education Training Collective?
Education Training Collective is a group of education institutions, representing Stockton Riverside College, Bede Sixth Form College, Redcar and Cleveland College, NETA Training and Innersummit.
We have tried to make this statement as easy to read as possible, but if you believe we can improve it, please let us know.
Data Protection Manager
Education Training Collective
Harvard Avenue
Thornaby
TS17 6FB
United Kingdom
Lawful Basis
Education Training Collective processes personal information about its staff, students, visitors and wider community under a lawful basis, as defined in the UK Data Protection Act 2018 and UK GDPR.
Legitimate Interest
In all our operations as a Further Education College Group, we use the ‘legitimate interest’ lawful basis for processing in relation to delivering our services and meeting the high expectations of our staff, students and visitors.
Consent
Sometimes, there will be situations where a staff member, student, or visitor may wish to engage with additional services or opportunities. For processing personal information in this way, we seek direct consent. This may be consent from the individual or consent from a parent or carer (depending on the individual’s ability to understand how giving consent might affect them).
We will always use ‘opted in’ consent to send you targeted marketing information. We will ensure that our marketing practices comply with the Privacy and Electronic Communications Regulation (PECR).
Contract
Some of our work with third parties (commercial or otherwise) requires us to create data sharing relationships. Whether either party is acting in a Controller or Processor role, we will always aim to use a Contract as a basis for sharing personal data and will apply data sharing compliance through a Data Sharing Agreement (the Contract, or written form of how we’ll do things).
Legal Obligation
Some information will be processed under a Legal Obligation and this usually relates to financial information, governance and corporate functions. In reference to students, we are under a legal obligation to share personal information with Local Authorities (Section 72 of the Education and Skills Act 2008).
Such information includes:
(a) the name, address and date of birth of the pupil or student;
(b) the name and address of a parent of the pupil or student;
(c) information in the institution’s possession about the pupil or student.
Where a student has not reached the age of 16, their own and their parents’ information will not be shared.
Vital Interests
We may be relied upon to provide personal information to the Emergency Services or other agencies in order for them to save a life or where an imminent or potential threat to life or health exists. We will disclose (only the required) information to these agencies under these circumstances.
Public Task
On occasion, we will be required to disclose personal information to the police for the purpose of the prevention or detection of a crime. As this purpose would be to protect the general public, we will share such information under the legal basis of a Public Task. Where special category personal data is involved and we decide to disclose information, we will also rely on the Condition of a ‘substantial public interest’ (in the prevention or detection of an unlawful act). We will not always be able to let data subjects know that we have disclosed their personal information to the police, but we will keep a record of this decision.
Safeguarding Policy
Below you will find our policy information related to Safeguarding.
Current written protocols, policies and procedures for delivering our services and responsibilities. The buttons below contain the overarching Safeguarding Policy as well as the Appendices, letters A through to T.
Privacy Policy
Education Training Collective customer privacy notice
Registered name: Education Training Collective
We are the controller of your personal data. This privacy notice tells you what to expect us to do with your personal information.
Contact details
Post
Education Training Collective, Harvard Avenue, Thornaby, STOCKTON-ON-TEES, Cleveland, TS17 6FB, GBTelephone
01642865400
info@the-etc.ac.uk
What information we collect, use, and why
We collect or use the following information for student education and welfare:
- Names and contact details for students/children
- Names and contact details for parents, guardians, carers
- Gender
- Pronoun preferences
- Date of birth
- Next of kin and emergency contact information
- Dietary requirements (including vegetarian, vegan, gluten free and religious requirements)
- Payment details and financial information including transactions
- Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)
- Welfare information (includes family and home life circumstances and history)
- Details of any criminal convictions
- Photographs
- Attendance and reason for absence data
- Account access information
- Exam results and qualifications
- Progress reports
- Information relating to compliments and complaints
- Exclusion, suspension and behavioural information
- Right to work information
We also collect or use the following special category information for student education and welfare. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Health information
We collect or use the following information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes:
- Names and contact details for students/children
- Names and contact details for carers
- Gender
- Pronoun preferences
- Welfare information (includes family and home life circumstances and history)
- Special Educational Needs and Disabilities (SEND) information (includes reasonable adjustments and special educational needs and disabilities)
- Details of any criminal convictions
- Attendance and reason for absence data
- Witness statements and contact details
- Records and reports
- Video recordings of public areas (including entrances and outside spaces to which some or all members of the public have access)
- Audio recordings of public areas (including entrances and outside spaces to which some or all members of the public have access)
- Video recordings of student access areas (including classrooms, corridors, canteens and outside spaces to which students have access)
- Audio recordings of student access areas (including classrooms, corridors, canteens and outside spaces to which only staff have access)
- Call recordings
We also collect or use the following special category information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Health information
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Addresses
- Payment details
- Account login or user information
- Purchase or service history
- Video recordings of public areas
- Audio recordings of public areas
- Video recordings of private or staff only areas
- Audio recordings of private or staff only areas
- Call recordings
- Dashcam footage – outside vehicle
- Dashcam footage – inside vehicle
- Witness statements and contact details
- Relevant information from previous investigations
- Financial transaction information
- Information relating to health and safety (including incident investigation details and reports and accident book records)
- Correspondence
- Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)
- Attendance and reason for absence data
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Health information
We collect or use the following information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
- Photographs
- Website and app user journey information
- IP addresses
- Records of consent, where appropriate
- Alumni records
We collect or use the following information for recruitment purposes:
- Contact details (eg name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg DBS, Access NI or Disclosure Scotland checks)
- Security clearance details (eg basic checks and higher security clearance)
We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Health information
We collect or use the following information to comply with legal requirements:
- Identification documents
- Health and safety information
- Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Safeguarding information
- Any other personal information required to comply with legal obligations
We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Trade union membership
- Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information for student education and welfare are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
We process personal information under a lawful basis of legitimate interests to ensure students\’ personal information is processed to enable their application and enrolment onto an appropriate course of study, as well as their progression. For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for disciplinary investigations or to prevent, detect, investigate or prosecute crimes are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
We process personal information under a legitimate interest to ensure we can effectively deal with queries and concerns raised to us by individuals. For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Where we get personal information from
- Directly from you
- Parents or carers
- Local authorities or local councils
- Social services
- Other education establishments
- Health care providers
- CCTV footage or other recordings
- Previous employers
- Current employer
- How long we keep informationWe generally only keep personal information for as long as we need it. However, we generally keep your information for the duration of your studies plus 6 years. We keep records of complaints for 3 years. We keep data requests and FOI requests for 6 years. There may be occasions when we are required to keep some personal information for longer to carry out a legal obligation or public task, or to support an investigation or when required by a court. We may delete some types of personal information upon your request (information given to us by you).
Third Party Suppliers and Providers
Third party service suppliers and providers provide services related to the general running of the business: – internet, email, data management, business software, print management, payroll, finance, exam management, events, streaming services, cloud services.
Others we share personal information with
- Parents and carers
- Local authorities
- Social services
- Fostering agencies
- Schools for the education purposes (transitions, destinations, etc)
- Pupil Referral Units (PRU’s) or Education Otherwise at School Centres (EOTAS)
- Specialist teachers such as peripatetic workers or speech and language therapists
- School governing bodies (such as Board of governors or Parent/teacher associations (PTA))
- Examination boards and bodies
- Health care providers
- Organisations we need to share information with for safeguarding reasons
- Emergency services
- Legal bodies or authorities
- Relevant regulatory authorities
- External auditors or inspectors
- Organisations we’re legally obliged to share personal information with
- Publicly on our website, social media or other marketing and information media
- Debt collection agencies
- Previous employers
- Suppliers and service providers
- Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: Make a complaint | ICO
Contact
Privacy Support
If you have an enquiry about our privacy statement, please contact:
Data Protection Manager
Education Training Collective,
Harvard Avenue,
Thornaby,
Stockton-on-Tees,
TS17 6FB
data@the-etc.ac.uk