Privacy notice for Early Career Teachers (ECTs)
Under data protection law, individuals have a right to be informed about how the organisation uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.
This privacy notice explains how we collect, store and use personal data about Early Career Teachers.
We, the organisation, are the ‘data controller’ for the purposes of data protection law.
Our data protection officer is Jon French (see ‘Contact us’ below).
The Personal Data we hold
We process data relating to those we employ, or otherwise engage, to work as part of or engage with our organisation. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:
• Contact details
• Teacher Registration Number (TRN)
• Date of birth
• Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process
• Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships
• Performance information
• Photographs
We may also collect, store and use information about you that falls into "special categories" of more sensitive personal data. This includes information about (where applicable):
• Race, ethnicity, religious beliefs, sexual orientation and political opinions
• Trade union membership
• Health, including any medical conditions, and sickness records
Why we use this data
The purpose of processing this data is to help us run the organisation and services we deliver for ECTs, including to:
• Register you with the Appropriate Body service
• Enabling key programme information to be shared with you
• Submission of results/outcomes relating to your programme
• Enable equalities monitoring
• Improve the management of workforce data across the sector
Our lawful basis for using this data
In order for our use of your personal data to be lawful, we need to meet one (or more) conditions in the data protection legislation. For the purpose of this project, the relevant condition(s) that we are meeting are:
Contract: Article 6 (1) (b) “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”
The collection and sharing of this type of data is necessary in order to execute the contract in ensuring the ECT is registered with the Teacher Registration Agency.
And in terms of any special category data we process, such as TRNs, this is also lawful to ensure statutory compliance with the registration of ECTs for induction.
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:
• Fulfil a contract we have entered into with you
• Comply with a legal obligation
• Carry out a task in the public interest
• Deliver a service you have registered for as part of your professional development
Less commonly, we may also use personal information about you where:
• You have given us consent to use it in a certain way
• We need to protect your vital interests (or someone else’s interests)
• We have legitimate interests in processing the data
Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so.
Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the school’s use of your data.
Collecting this information
While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us.
Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.
How we store this data
Personal data is stored in line with our Data Protection Policy.
We create and maintain a record for all ECTs registered with us. The information contained in this file is kept secure and is only used for purposes directly relevant to your registration and professional development.
Once your engagement with us has ended, we will retain this file and delete the information in it in accordance with appropriate body requirements.
Data sharing
We do not share information about you with any third party without your consent unless the law and our policies allow us to do so.
Where it is legally required, or necessary (and it complies with data protection law), we may share personal information about you with:
• Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns
• The Department for Education (Teacher Regulation Agency) to meet the statutory requirements of the Appropriate Body.
• Suppliers and service providers – to enable them to provide the service we have contracted them for, such as Quality Assurance by an external person/organisation
• Our regulator Ofsted
• Our auditors
• Security organisations
• Police forces, courts, tribunals
• Professional bodies
Transferring data internationally
Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
Your rights
How to access personal information we hold about you
Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school holds about them.
If you make a subject access request, and if we do hold information about you, we will:
• Give you a description of it
• Tell you why we are holding and processing it, and how long we will keep it for
• Explain where we got it from, if not from you
• Tell you who it has been, or will be, shared with
• Let you know whether any automated decision-making is being applied to the data, and any consequences of this
• Give you a copy of the information in an intelligible form
You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.
If you would like to make a request, please contact our data protection officer.
Your other rights regarding your data
Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:
• Object to the use of your personal data if it would cause, or is causing, damage or distress
• Prevent your data being used to send direct marketing
• Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person)
• In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
• Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact our data protection officer.
Complaints
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our data protection officer.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
• Report a concern online at https://ico.org.uk/concerns/
• Call 0303 123 1113
• Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Contact us
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:
Jon French
Data Protection Officer
[email protected]
0115 6848295
This notice is based on the Department for Education’s model privacy notice.