ECT Privacy Policy

Privacy Notice 1 Introduction 1.1 OneCornwall is the Teaching School Hub partnership for Cornwall and the Isles of Scilly and is jointly run by Kernow Learning Multi Academy Trust (hereafter called Kernow Learning) and The Roseland Multi Academy Trust. It is a partnership of schools and institutions across Cornwall and the Isles of Scilly. 1.2 Kernow Learning is the Data Controller for the personal information provided to OneCornwall for schools in the Cornwall West and Isles of Scilly area (DfE Teaching School Hub number SW8). The Roseland Multi Academy Trust is the Data Controller for the personal information provided to OneCornwall for schools in the Cornwall East area (DfE Teaching School Hub number SW11). This means that Kernow Learning and The Roseland Multi Academy Trust determine the purposes for which, and the manner in which, any personal data relating to delegates, enquirers, contractors, employees and OneCornwall partners. 1.3 In some cases, your data will be shared with a third party processor who provides a service to us. Where OneCornwall shares data with a third party processor, the same data protection standards that OneCornwall upholds are imposed on the processor. 2 What is this notice for? 2.1 This notice explains the purposes for which One Cornwall hold information about you (your personal data) 2.2 All data is held and processed in line with the Kernow Learning and The Roseland Multi Academy Trust’s respective Data Protection Policies which can be found on their websites (www.kernowlearning.co.uk and www.theroselandmat.co.uk) 3 How we use your personal information 3.1 We collect information about you when you register with us or place an order for products and services. We also collect information when you voluntarily complete customer surveys, provide feedback and use our online enquiry form. Additionally, we collect information on contractors and employees for the purposes of payments and legal processing of HMRC information. The information we collect on partners is used for communication and distributing information. 3.2 The categories of the information that we collect, process, hold and share include: 3.2.1 Personal OneCornwall delegate or participant information (such as name, email address, workplace, photos and DBS status for access to schools) 3.2.2 Contractor information (such as name, email address, premises address, phone number, DBS status, rates of pay and tax status) 3.2.3 Employee information (such as name, email address, residence, contact number, DBS status, rates of pay, HMRC PAYE information, Health and Safety records, divulged medical information, next of kin and absence information). Kernow Learning and The Roseland Multi Academy Trust have separate Privacy Notices for employees employed by each respective Trust. 3.2.4 Enquirer information (such as name, email address, organisation and job title) 3.2.5 Partner organisation information (such as name, email address, organisation, job title, biographies and photos) 3.2.6 OneCornwall partner school pupil information (such as photos). This data will only be held and processed with consent. 4 Why we collect and use this information 4.1 We use delegate data to: 4.1.1 Enable us to carry out specific function for which we are responsible 4.1.2 Evaluation with government departments if requested 4.1.3 Email marketing if opted in 4.1.4 Derive statistics which inform decisions such as the funding of courses 4.1.5 Assess performance of courses/programmes 4.1.6 Monitor attendance on courses/programmes 4.1.7 Invoice for attendance on courses/programmes 4.2 We use contractor and employee data to: 4.2.1 Enable us to carry out specific functions for which we are responsible, including safeguarding 4.2.2 Share with required government departments if requested 4.2.3 Provide annual accounts and PAYE/HMRC returns, including payments 4.2.4 Monitor performance 4.3 We use enquirer data to: 4.3.1 Answer queries 4.3.2 Give information on our courses, programmes and conferences if consent has been given to receive this information 4.4 We use OneCornwall partner data to: 4.4.1 Enable communication and distribute information about OneCornwall 4.4.2 Provide online biographies of our partners on our website and/or course/programme material 4.5 We use OneCornwall partner school pupils’ data to: 4.5.1 Promote OneCornwall through use of photos on our website, social media platforms and marketing 4.5.2 As part of presentations, show reels and films at OneCornwall training days or other sessions 5 How we use the information about you 5.1 We collect information about you in order to process your order, manage your account and, if you agree, to email you about other products and services that we think may be of interest to you. Registers of attendance and email addresses will be kept for up to 5 years after your last attendance on a course/programme run by OneCornwall. 5.2 We use the information collected about you from the courses you attend to personalise your repeat visits to our courses. OneCornwall, Kernow Learning and The Roseland Multi Academy Trust will not share your information for marketing purposes with external companies outside of the OneCornwall partnership unless required to do so in order for us to carry out specific functions for which we are responsible. In processing your order, we may send your details to, and also use information from, your workplace to complete your course. 6 Data sharing security 6.1 In line with the Data Protection Act 2018, we must comply with the General Data Protection Regulations (GDPR). This covers confidentiality and handling of data, security arrangements, retention and the use of data. 6.2 We will not, without your express consent, provide your personal information to any third parties for the purpose of direct marketing. 6.3 We may be required to share some personal data with the Department for Education (DfE). The Department may share information that we are required to provide them with other organisations. For further information about the Department’s data sharing process, please visit: https://www.gov.uk/guidance/data-protection-how-we-collect-and-shareresearch-data. Contact details for the Department can be found as https://www.gov.uk/contact-dfe. 7 Marketing 7.1 We would like to send you information about courses, programmes and services provided by OneCornwall. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email [email protected]. 8 Lawful basis for processing data 8.1 The lawful basis for processing data are set out in Article 6 of the General Data Protection Regulations (GDPR). At least of the listed reasons must apply whenever an organisation processes personal data 8.2 We collect and process data under the following legal basis 8.2.1 Consent – the individual has given clear consent for us to process their personal data for a specific purposes 8.2.2 Contract – the processing is necessary for a contract in place with the individual, or because they have asked the organisation to take specific steps before entering into a contract 9 Data storage 9.1 We hold delegate information for up to 5 years after the last attendance on a course or programme. Kernow Learning and The Roseland Multi Academy Trust hold employee and contractor data for the current year plus 6 years following. Enquiries, partner information and photos of OneCornwall partner school pupils are held for up to 5 years. 10 Requesting access to your personal data 10.1 All data subjects have the right to request access to information about them that we hold. 10.2 Data subjects also have the right to: 10.2.1 Object to processing of personal data that is likely to cause, or is causing damage or distress 10.2.2 Prevent processing of personal data for the purpose of direct marketing 10.2.3 Object to decisions being take by automated means (OneCornwall does not process data in this way) 10.2.4 In certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed 11 Concerns 11.1 If an individual has any concerns about how OneCornwall is using their personal data then they should contact the relevant Data Protection Officer for their area. These are listed in section 12 of this Privacy Notice. 11.2 An individual can contact the Information Commissioner’s Office should they consider this to be necessary, at https://ico.org.uk/concerns. 12 Data Protection Officers 12.1 If you work in a school in the Cornwall West and Isles of Scilly area (DfE Teaching School Hub number 8) and would like to discuss anything in this Privacy Notice, please contact the Kernow Learning Data Protection Officer: David Houghton ([email protected]) Kernow Learning, The Old Cricket Pavilion, Treninnick Hill, Newquay, TR7 2JU 12.2 If you work in a school in the Cornwall East area (DfE Teaching School Hub number 11) and would like to discuss anything in this Privacy Notice, please contact The Roseland Multi Academy Trust Data Protection Officer: Richard Clarke ([email protected]) The Roseland Multi Academy Trust, The Roseland Academy, Tregony, Truro, TR2 5SE