Privacy Policy

---

1. Introduction 

All Things SEN - The Quay is committed to protecting the privacy of your personal data. This notice sets out how All Things SEN - The Quay uses the information that you provide us with, in order for us to help continue to support the lives of children, young people and their families. It explains when and why we collect personal information about the people we support, who support us, who provide us with services, who visit our website or work or apply to work with us – as well as how we use that information, the conditions under which we may disclose it to others and how we keep it secure.

Joint Directors Steven Lane and Dean Frances-Hawksley are the ‘data controllers’ for the purposes of UK data protection law.

Any questions regarding this Privacy Policy should be sent by email to dean@allthingssen.co.uk  or steven@allthingssen.co.uk. If you are unhappy with the way we process your data, you can also make a complaint to the Information Commissioners Office (ICO) which regulates the use of information in the UK. They can be contacted by Telephone 03031231113, by going on their website to complete their complaint form www.ico.org.uk/make-a-complaint, or you can write to them at: Information Commissioner’s Office, Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF.

2. What information do we collect and where from?

2.1 Learners 

In order to carry out our work, we collect personal information about the children and young people we support, as well as their guardians (parents or carers). Such information includes names, addresses, contact details such as telephone numbers and email addresses, dates of birth (learners only) and up to date medical information (learners only). 

We collect information when you give it to us directly. We store information on learners and guardians in order to support our services and meet legal requirements of duty of care. Your data may also be used, where relevant, to advise you of events, news and marketing which may be of interest. 

Photographic (including video) records of learners and educational activities are a part of our data collection and ongoing assessment process. They support communication with parents, careers, relevant persons in schools (where the learner is on roll), and Local Authorities. Should we wish to use any of these images on our website or social media in order to promote the organisation, we will always seek explicit consent to do so. You do not have to agree that we may use yours or your child’s image: it is entirely your choice. 

2.2 Staff

In keeping with Safer Recruitment in Education protocols, all existing and prospective staff are subject to enhanced DBS checks. In our recruitment process, as well as contact details, date of birth, telephone numbers etc. we ask for relevant medical history (‘relevant’ meaning it may impact on staff’s ability to carry out the work). 

3. How do we use your personal information? 

We use your personal information to carry out the educational/therapeutic functions and activities of All Things SEN - The Quay, and to comply with our legal obligations in respect to duty of care, safeguarding and basic health and safety. 

We use your information to:

• keep a record of your relationship with us,      for internal administrative purposes, and to let you know about changes to      our services or policies that may affect you
• look into, and respond to, complaints, claims,      or any other issues
• process your data when you work for the organisation
• process your data when you apply to work for      the organisation 

We will process information to ensure all submissions are handled and fulfilled correctly and to the highest standard.

4. Data retention and keeping information up to date

In line with UK GDPR guidance, your details and supporting paperwork will be retained for no longer than is necessary, and then either deleted, anonymised or archived. In order to accurately report on the activities of the organisation and demonstrate our impact, we need to be able to report on certain services provided, as well as demonstrate our level of interaction with funding authorities, parents, and related professionals. Therefore, some data will be kept longer than other data.

For more information, please ask us directly by emailing dean@allthingssen.co.uk, or writing to Data Controller, All Things SEN – The Quay, Former Customs House, Sharpness Docks, Berkeley, GL13 9UD.  

5. Accuracy of your personal information. 

All Things SEN - The Quay will endeavour to ensure that the personal information we hold is accurate, complete, and up to date. If you become aware of any inaccuracy in the personal information we hold about you, we encourage you to contact us so we can update any personal information we hold about you.

6. Who has access to your information and how do we keep it safe? 

All Things SEN - The Quay regards the security of your personal information as a priority and takes several precautions to protect your personal information from loss, misuse, unauthorised access, modification or disclosure. We remind you, however, that the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.

We will not share your information or the information about children without the prior knowledge and consent of their parents or guardians unless the law requires it.

We will never sell, trade, or rent your information to third parties.

All data is kept secure on a secure password protected, encrypted system. Any hard copies of data are kept in a cupboard in an office locked office or cupboard and all systems are password protected.

Third Party Service Providers working on our behalf:

Your data is shared (through operational necessity) with our IT providers, including our database provider, web-hosting company, and email provider. We ensure that these data processors are compliant with data protection legislation. Data is shared for the purposes of completing tasks and providing services to you on our behalf (for example to send you progress information relating to your child). Please be reassured that we will not release your information to third parties for them to use for their own direct marketing or other purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

7. Your rights and choices

7.1 Legalities

The Law on Data Protection is derived from various pieces of legislation including the Data Protection Act, Privacy and Electronic Communications Regulation and the General Data Protection Regulation (the ‘GDPR’). The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing, and using personal information fall into the GDPR’s definition of processing. The GDPR provides six legal grounds under which personal information can be processed in a way that is lawful. For the processing to be permitted by law, at least one of the legal grounds must apply.

The four legal grounds that are most relevant to All Things SEN - The Quay’s use of your personal information are:

• Consent
• Legitimate Interest
• Contract
• Legal Obligation

7.2 Processing your personal data?

All Things SEN - The Quay will only process your personal information if we have:

1. asked you and have a record of your express      consent for us to do so;
2. a ‘Legitimate Interest’ to do so in order to      support our educational purposes. Our use will be fair and balanced and      never unduly have an impact on your rights;
3. a contract with you that we can only fulfil by      using your personal information, e.g. to send you an item that you have      requested;
4. a legal obligation to use or disclose      information about you.

In extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another person’s). This is the ‘vital interest’ ground for using your personal information. After the emergency, we will always try to inform you about how we had to use your information in that extreme situation.

We will never prioritise our interests as an alternative provision over your rights as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this policy. 

7.3 Consent

Where All Things SEN - The Quay has asked for your consent for processing your data, this can be withdrawn at any time by emailing either dean@allthingssen.co.uk or steven@allthingssen.co.uk, or by writing to Data Controller, All Things SEN – The Quay, Former Customs House, Sharpness Docks, Berkeley, GL13 9UD.  

We will only ask you for your consent where you have a genuine choice in how we process your information. In most instances we will use other grounds for processing than consent.

7.4 What is Legitimate Interest?

This legal ground for processing means that organisations can process your personal information if they

1. have a genuine and legitimate reason for doing      so and
2. do not harm any of your rights and interests      as an individual.

We do not unduly prioritise our legitimate business interests over your interests as an individual. We always respect your rights. We consider your interests based on previous communications, as well as what we consider your expectations to be, and assess whether we are using your personal information in a way that matches your relationship with us. We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.

When it is necessary, we will contact you for administrative purposes. 

7.5 Anonymity 

Where it is lawful and practicable, we will allow individuals to deal with us on an anonymous basis. For example, if we receive a telephone enquiry, we will not require that the enquirer gives us their name, although depending on the nature of the enquiry, we may not be able to answer it unless they do. 

7.6 Your Rights 

The GDPR gives you rights as a data subject. You have:

• the right to request from us access to your      personal data;
• the right to request from us rectification of      your personal data;
• the right to request from us erasure of your      personal data;
• the right to request from us restriction of      processing your personal data;
• the right to object to our processing of your      personal data;
• the right of data portability;
• if we are processing your personal data on the      basis of your consent, you have the right to withdraw your consent at any      time. This does not affect the lawfulness of processing based on your      consent before you withdrew it; and
• You have the right to complain to the ICO by      visiting https://www.ico.org.uk.

7.8 Freedom of Information

Under data protection legislation, you have the right to request access to information that we hold. To make a request for your personal information, or be given access to your or your child’s All Things SEN - The Quay record, you may contact us by emailing  dean@allthingssen.co.uk or steven@allthingssen.co.uk, or by writing to Data Controller, All Things SEN - The Quay Former Customs House, Sharpness Docks, Berkeley, GL13 9UD.. 

7.9 If you do not wish for us to contact you

Please just let us know by emailing, dean@allthingssen.co.uk or steven@allthingssen.co.uk, or by writing to Data Controller, All Things SEN - Former Customs House, Sharpness Docks, Berkeley, GL13 9UD.

8. Changes to this Notice

If All Things SEN - The Quay updates or changes this Privacy Policy, the changes will be made on this page. Your continued use of All Things SEN - The Quay website following the posting of changes will mean you accept those changes.