This notice explains how Westminster Great School and Westminster Under School (“the School”, “we” and “our”) uses (“processes”) personal data we collect about our prospective, current and former pupils on the Platform Pups, Platform and Platform+ programmes, their nominators, and their parents/guardians/carers (“you” and “your”). It applies alongside any other information we may provide about a particular use of personal data, for example when collecting data via an online or paper form.

We will publish on our website any changes we make and notify you by other communication channels where appropriate.

Index

1. Our websites
2. What types of personal data does the school use?
3. How does the school obtain my personal data?
4. Why does the school use personal data?
5. Who else sees my personal data?
6. How long do you keep personal data?
7. Responsibility for Data Protection
8. Your rights
9. Data accuracy and security
10. Queries and complaints

i.  Our websites

Our websites use cookies, a small piece of information stored on your computer in the form of a file, to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. We use Google Analytics to analyse use of our websites. The information collected will not include any information from which you will be identifiable. You can set up your browser to reject cookies, although some functionality of the website may be impaired.

We require nominators to complete our online form with details of prospective candidates for the Platform Pups, Platform and Platform+ programmes. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted via the internet; any transmission is at your own risk. Once we have received your data, we use strict procedures and security features to try to prevent unauthorised access.

ii.  What types of personal data does the School use?

When signing up to our mailing list this will include:

• Name
• Email address
• Highest level of education of the Platform candidate’s parents
• Home postcode of the Platform candidate’s family
• Current employment status of candidate’s parents

At the point of nomination this will include:

• The Platform candidate’s name, gender and date of birth
• The Platform candidate’s school and their home postcode
• An academic reference from the nominator
• Socio-economic information, such as whether the candidate is eligible for free school meals
• The name, job title and contact details of the nominator

Further information will be collected about pupils selected to take part in the programme in a registration form. This will include:

• The pupil’s name as it appears on their passport/birth certificate and the pupil’s preferred name
• Nationality
• Language spoken at home, other languages spoken fluently
• Dietary requirements, medical needs and t-shirt size
• Parent/Guardian/Carer contact name(s), relationship to pupil
• Parent/Guardian/Carer email address, postal address, telephone numbers
• Parent/Guardian/Carer employment status, occupation
• Confirmation that one parent has UK citizenship, EEA citizenship or indefinite leave to remain

At the launch event we will collect:

• A photograph of the pupil
• Email contact details of the pupil

During the programme we will:

• make and record academic assessments of pupils on the course
• where consent has been given, take photographs of pupils on the course

After the programme we will, with your consent:

• keep in touch to help us evaluate the programme and plan for its improvement.

iii.  How does the School obtain my personal data?

The initial nomination form will be completed by a member of staff from the pupil’s school. Generally, the registration form is completed by a pupil’s parent/guardian/carer, although in some circumstances this will also be completed by a member of staff from the pupil’s school.

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.

iv.  Why does the School use my personal data?

We need to use personal data to run the Platform programmes efficiently, safely and to let others know what we do here.

The following uses are undertaken in the School and the pupils’ “legitimate interests”:

• For the purposes of pupil selection (and to confirm the eligibility of prospective pupils and their parents/guardians/carers);
• To provide education services and monitor pupils’ progress and educational needs;
• To give and receive information and references about past and current pupils to/from any educational institution that the pupil attended or where it is proposed they attend;
• To safeguard pupils’ welfare and provide appropriate pastoral care;
• 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; we will not publish photographs of individuals alongside their names without the agreement of the appropriate individual;
• 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 occasions need to process special category personal data (concerning health, religion). 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 relevant 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 an appropriately sized t-shirt for the pupils on the programme;
• 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.

v.  Who else sees my personal data?

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). Particularly strict rules of access apply in the context of:

• medical information

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

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. For further information about this, please view the School’s Safeguarding Policy. Occasionally, the School will need to share personal information relating to its community with third parties, such as:

• professional advisers (e.g. lawyers, insurers and accountants);
• government authorities (e.g. HMRC, DfE, police or the local authority); and
• appropriate regulatory bodies (e.g. the Independent Schools Inspectorate, the Charity Commission or the Information Commissioner).

Finally, 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.

vi.  How long do you 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. Incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.

As a rule the following retention periods will apply:

• Unsuccessful pupils:
  Personal data from nomination form destroyed 6 months after submission.

• Successful pupils:
  Medical information, dietary requirements and t-shirt size will be destroyed on the completion of the programme. Other information, including academic and socio-economic data will be retained until the year in which the pupil turns 25. This is to enable the school to evaluate the success of the Platform programme and provide references for pupils.

If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant be considered for erasure, please contact the Bursar. 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 request. In particular, even where you have requested that 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”).

vii.  Responsibility for Data Protection

The School’s Bursar has responsibility for Data Protection. He handles requests and enquiries concerning the School’s uses of your personal data (see section on Your Rights below) and endeavours to ensure that all personal data is processed in compliance with the School’s Data Protection policy and Data Protection Law. You can email the Bursar: bursar@westminster.org.uk.

viii.  Your rights

→ Rights of access, etc.

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.

Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Bursar.

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 one month in the case of requests for access to information).

The School will be better able to respond quickly to smaller, targeted requests for information. 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).

→ Requests that cannot be fulfilled

You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents/guardians/carers 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).

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 personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.

→ Pupil requests

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 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.

Pupils of the age of 13 or over 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. Younger pupils may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.

→ Parents’ 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.

→ 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). 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, usually asserted under this Privacy Notice.

→ Whose rights?

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.

ix.  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 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 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.

x.  Queries and complaints

Any comments or queries on this policy should be directed to the Bursar. Please email: bursar@westminster.org.uk.

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 utilise the School’s 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.

Last updated:
January 2022