Privacy Policy

INTRODUCTION

Welcome to Windlesham House School’s privacy notice.

Windlesham House School respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. (Alternatively please click on the link to download a pdf version of the Windlesham House School Privacy Policy]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DATA SECURITY

6. DATA RETENTION

7. YOUR LEGAL RIGHTS

8. GLOSSARY

(a) IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Windlesham House School collects and processes your personal data.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. This privacy notice also applies in addition to Windlesham House School’s other relevant terms and conditions and policies including;

• any contract between Windlesham House School and its staff or the parents of students;
• the school’s policy on taking, storing and using images of children;
• the school’s CCTV policy;
• Windlesham House School’s retention of records policy;
• the school’s safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
• Windlesham House School’s IT policies.

Data protection law requires Windlesham House School, as data controller for your data:

• To process your data in a lawful, fair and transparent way;
• To only collect your data for explicit and legitimate purposes;
• To only collect data that is relevant, and limited to the purpose(s) we have told you about;
• To ensure that your data is accurate and up to date;
• To ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
• To ensure that appropriate security measures are used to protect your data.

CONTROLLER

Windlesham House School is the controller and responsible for your personal data (referred to as Windlesham House School, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: The Malden Trust Limited trading as Windlesham House School

Name or title of data privacy manager: Emma Harris

Email address: eharris@windlesham.com

Postal address: Washington, Pulborough, West Sussex RH20 4AY.

Telephone number: 01903 874705

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 21 May 2018 and historic versions can be obtained by contacting us. We may need to update this notice from time to time. If the change is material, we will give you not less than two months’ notice of the change so that you can exercise your rights, if appropriate, before the change comes into effect. We will notify you of the change by contacting you at the details you have provided to us in your last correspondence.

It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform the data privacy manager of any changes in your data at the following email address: WHSoffice@windlesham.com

THIRD-PARTY LINKS AND SOCIAL MEDIA

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We and organisations connected with us (such as the Owls Alumni and other school associations) have a social media presence for the purpose of engaging with our students, alumni and visitors.

If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy notice of every website of forum that you visit or use.

(b) THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photographs.
• Contact Data includes postal address, email address and telephone numbers.
• Professional Data includes academic qualifications and achievements, references, profession, job title, employer and professional history of the same.
• Welfare Data includes grievance and disciplinary information, pastoral care records, past, present and prospective students’ academic, admissions and attendance records, (including information about special needs), examination scripts and marks, information relating to criminal convictions and allegations of criminal activity, medical records and information including dietary requirements and religious information.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of transactions you have entered with us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password to any Windlesham House School online service, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We refer to the above categories of data in the data subject category tables which can be found here.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Professional Data to calculate the percentage of students who go into a sector or industry. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity , religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Much of this information is provided by way of Welfare Data and identified as such in our information tables. We may also collect information about criminal convictions and offences (such as when carrying out DBS checks). Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. All such information is collected in accordance with this privacy notice. We have in place appropriate policy documents and/or other safeguards which we are required by law to maintain when processing such data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to enrol you if you are a student). We will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms (including in the case of students or prospective students by parents providing date by filling in forms in relation to students) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply to enrol your child as a prospective pupil with us
  • enrol your child with us;
  • make a donation to Windlesham House;
  • request access to our library;
  • keep in touch with our Development Office;
  • make a payment to us for events or services;
  • sign up as an Owls Alumni with us; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• • Technical Data from analytics providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity, Professional, Contact, Technical, Usage and Profile Data submitted by way of applications to Windlesham House School.
  • Professional Data from your previous educational establishments and/or employers if they provide references to Windlesham House.
  • Identity and Contact Data from students at Windlesham House School, family members, friends, visitors to Windlesham House School and other contacts who may provide us with information about you.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

(c) HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We may also use your personal information, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to certain special categories of (sensitive) personal data). You have the right to withdraw consent to marketing at any time by emailing our Marketing & Admissions team.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. To see this please click here for our full Privacy Policy in PDF format, regarding:

• Students
• Employees
• Alumni
• Parents/Next of Kin
• Suppliers
• Donors
• General Public

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

DISCLOSURES OF YOUR PERSONAL DATA

We do not sell your personal data to third parties. We will only share your personal data with third parties where we are allowed or required to do so by law. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our school or our assets. Alternatively, we may seek to acquire other schools or merge with them. If a change happens to our school, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Third parties who process your data on our behalf are subject to contracts under which their processing activities are managed. Where your personal data is shared with third parties, we will seek to share the minimum amount of information necessary to fulfil the purpose.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

SECTIONS GIVING MORE DETAILS

For more detailed Privacy Policy statements relating to the following please click on the link to download a pdf version of the Windlesham House School Privacy Policy:

• Student, applicant or visiting student to Windlesham House School
• Employee, volunteer, or applicant to Windlesham House School
• Alumnus of Windlesham House School
• Parent, carer or guardian, emergency contact or next of kin to a student or employee at Windlesham House School
• Supplier to Windlesham House School
• Donor of monies or archive material to Windlesham House School
• Member of the general public or a visitor who accesses our services or facilities

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

MARKETING COMMUNICATIONS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which events, services and activities may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you attended one of our events or accessed one of our facilities and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any organisation outside Windlesham House School for marketing purposes. We don’t anticipate sharing your personal data with third parties for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided to you or other use of or access to our facilities or services.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please click on the link for more information about the cookies we use.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email our Data Privacy Manager.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

(c) DATA SECURITY

We have in place, appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

(d) DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by emailing our Data Privacy Manager. We have adopted the data retention policy recommended by ISBA.

By law we have to keep some basic information (including Contact, Identity, Financial and Transaction Data) for pre-determined periods such as for tax purposes.

By law we are required to keep Welfare Data on students for 25 years for safeguarding purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

(e) YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• The right to have access to your personal data
• The right to request correction of your personal data
• The right to request erasure of your personal data
• The right to object to processing of your personal data
• The right to request restriction of processing your personal data
• The right to request transfer of your personal data
• The right to withdraw consent
• The right to object to any direct marketing
• The right to object to any automated decision-making

Information about these legal rights can be found in the Glossary. If you wish to exercise any of the rights set out above, please emailing our Data Privacy Manager. Some of your rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances and we will notify you if this is the case.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

(f) GLOSSARY

LAWFUL BASIS

Legitimate Interest – means the interest of our organisation in conducting and managing our organisation to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing our Data Privacy Manager.

Performance of Contract – means processing your data where it is necessary for the performance of a contract or agreement to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation – means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties…

• Service providers acting as processors based in the United Kingdom who provide employee related IT services in relation to pension provision, insurance, and other services, MailChimp for some email communications,, iSAMs ,a database which holds pupil and parent details and prospects and MyConcern, a pastoral care database;
• Service providers acting as processors based in the United States who provide IT and system administration services such as Google , Microsoft and Survey Monkey;
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
• Department for Education, HM Revenue & Customs, regulators (e.g. the Independent Schools Inspectorate, the Health and Safety Executive, the Information Commissioner) and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access – to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction – of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure – of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing – of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing – of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer – of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time – where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Object to any direct marketing – (for example, email marketing or phone calls) by us, and to require us to stop such marketing.

Object to automated decision-making – about you which produces legal effects or otherwise significantly affects you.