Privacy Notice
STEP Ahead Teaching School Hub respects your privacy and is committed to complying with privacy legislation. This privacy notice explains how we collect, store, use and protect personal data about individuals who have registered with the organisation as the Appropriate Body for the Early Career Teacher (ECT) induction programme. This notice covers those undertaking the programme as well as Headteachers, Induction Coordinators, Mentors and Tutors.
The notice also covers all other professional development courses that STEP Ahead Teaching School Hub delivers.
STEP Ahead Teaching School Hub (part of the STEP Academy Trust – company number 07612865) has a Data Protection Officer whose role it is to ensure that any personal information processed by the organisation is processed fairly and lawfully (protecting your rights and ensuring we follow the law). If you have any concerns or questions regarding how we look after your personal information, please contact our Data Protection Officer: [email protected]
Handling your personal data
STEP Ahead Teaching School Hub through management, use of appropriate controls, monitoring and reviews, will:
• Use personal data in the most efficient and effective way to deliver our services.
• Collect and process only the data or information which is needed.
• Use personal data for such purposes as are described within this privacy notice.
• Strive to ensure information is accurate.
• Not retain information for longer than is necessary.
• Securely destroy data which is no longer needed.
• Take appropriate technical and organisational security measures to safeguard information.
• Ensure that information is not transferred to third parties without suitable safeguards.
• Ensure that there is general information made available to the public of their rights to access information.
• Ensure that the rights of people about whom information is held can be fully exercised under the UK General Data Protection Regulations (‘UK GDPR’).
Data we collect and hold
We may collect the following information:
• Personal identifiers and contacts (such as name, full address, phone numbers and email)
• Date of birth
• Gender
• National Insurance Number
• Employing school and contract details
• Job title
• Teacher reference number
• Qualifications and details
• Special requirements (such as accessibility needs)
• Dietary requirements
• Programme assessment information
• Absence record
• We may also hold data about participants that we have received from other organisations, including other schools, our delivery partners and the Department for Education.
Why we use this data – the ‘purposes’
The purpose of holding this data is to allow STEP Ahead Teaching School Hub to:
a) Book individuals on to, and to correspond about, training programmes and events.
b) Provide registers of attendees at events.
c) Provide trainers with information about event bookings.
d) Provide individuals with certification of course completion.
e) Provide individuals with marketing information about additional events.
f) Collect attendance information.
g) Monitor and report progress.
h) Provide additional support to learners, if relevant.
i) Complete impact evaluation reports of professional development events.
j) Complete anonymised reports of attendance at professional development for and the Department for Education, programme providers and other relevant partners.
k) Record keeping and invoicing.
l) To assess the quality of our services.
m) We use the contact information you enter when registering with us to communicate with you on legitimate interest grounds and operational matters.
n) We may periodically send promotional emails about our professional development services which we think you may find interesting.
The lawful basis on which we use this data
The lawful basis for processing data are set out in Article 6 of the UK GDPR. At least one of these must apply whenever personal data is processed:
• Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
• Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
• Vital interests: the processing is necessary to protect someone’s life.
• Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
• Legitimate interests: the processing is necessary for legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data, which overrides those legitimate interests.
Under the UK GDPR, subject to the specific circumstances, the lawful basis we intend to rely on for the processing of information for the above noted purposes are as follows:
• for the purposes of a) above in accordance with the legal basis of consent and contract
• for the purposes of e) and h) above in accordance with the legal basis of consent
• for the purposes of m) and n) above in accordance with the legal basis of consent and legitimate interests
• for the purposes of c) and d) above in accordance with the legal basis of public task and contract
• for the purposes of b), f), g), i), K), L) above in accordance with the legal basis of public task
• for the purposes of j) above in accordance with the legal basis of public task and legal obligation
In addition, where the personal data we collect is sensitive personal data, we will only process it where in addition to one of the above noted lawful bases and one of the following conditions applies (as set out under Article 9 of the UK GDPR):
• we have explicit consent (Article 9 (a));
• processing is necessary for reasons of employment, social security and social protection (Article 9 (b));
• processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent (Article 9 (c));
• processing relates to personal data which are manifestly made public by the data subject (Article 9 (e));
• processing is necessary for the establishment, exercise or defence of legal claims or judicial acts (Article 9 (f));
• processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject (Article 9 (g));
• processing is necessary for reasons of public interest in the area of public health (Article 9 (i)); and/or
• processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes (Article 9 (j)).
Please see our UK GDPR Policy for a definition of sensitive personal data.
Collecting user information
Most of the information will be collected upon registration to the services and some will be collected throughout the course via communications from STEP Ahead Teaching School Hub.
Some information you provide to us is mandatory, some however is provided on a voluntary basis. In order to comply with the UK GDPR, we will inform you whether you are required to provide certain information to us or if you have a choice in this. Where appropriate, we will ask for consent to process personal data where there is no other lawful basis for processing it. You may withdraw consent at any time.
Data Sharing
Your personal data is shared with third parties including:
• Our partners involved in the delivery of the national Full Early Career Induction Programme and the National Professional Qualification for Leading Teacher Development (NPQLTD), National Professional Qualification for Headship (NPQH), National Professional Qualification for Senior Leadership (NPQSL), National Professional Qualification for Executive Leadership (NPQEL), National Professional Qualification for Leading Teaching (NPQLT) and National Professional Qualification for Leading Behaviour and Culture (NPQLBC) programmes (and other professional development courses).
• Our regulators and auditors (such as the Department for Education), to ensure compliance with our legal obligations.
• The employing school (where appropriate).
• The Teacher Regulation Agency.
We do not share information about you with other third parties without your consent unless statutory bodies or the law requires us to do so.
From time to time, we may share information with other third parties including the following:
• the Police and law enforcement agencies;
• NHS health professionals;
• Courts, if ordered to do so;
• the Teaching Regulation Agency;
• our HR providers, for example, if we are seeking HR advice;
• our legal advisors;
• our insurance providers / the Risk Protection Arrangement.
Some of the above organisations may also be Data Controllers in their own right in which case we will be jointly controllers of your personal data and may be jointly liable in the event of any data breaches.
In the event that we share personal data about with third parties, we will provide the minimum amount of personal data necessary to fulfil the purpose for which we are required to share the data.
Requesting access to your personal data
Under data protection legislation, you have the right to request access to information about you that we hold. To make a request for your personal information, please contact [email protected]
You also have the right to:
• object to processing of personal data that is likely to cause, or is causing, damage or distress
• prevent processing for the purpose of marketing
• object to decisions being taken by automated means
• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
• claim compensation for damages caused by a breach of the Data Protection regulations
If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance by contacting STEP Ahead Teaching School Hub’s Data Protection Officer or alternatively you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns