Strictly Education Ltd Unified Data Privacy Notice

Strictly Education understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, employees and other people with whom we interact with and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us & This Document

This document applies to Strictly Education Ltd and its wholly owned subsidiaries and relates to the data that is shared between its parent company and subsidiaries. The subsidiaries are: Strictly Education, Strictly Education and Strictly Education 3BM - together known as ‘Strictly Education’ or ‘we’. References within the policy to parent company and member companies include Strictly Education’s parent company, Supporting Education Group and its subsidiaries.

In the first instance, we encourage any questions to be directed to Strictly Education’s Data Protection Lead, as follows: -
Data Protection Lead: Tim Hart
Email address: dpo@strictlyeducation.co.uk
Telephone number: 0330 123 2540

Registered address: Strictly Education Limited, Wallace House, 4 Falcon Way, Welwyn Garden City, Herts, AL7 1TW

The Data Protection Officer for Strictly and for the Group is Judicium Education whose details are as follows: -

Data Protection Officer:

Judicium Consulting Limited
Address: 72 Cannon Street, London, EC4N 6AE
Email: dataservices@judicium.com
Web: www.judicium.co.uk
Lead Contact: Craig Stilwell

2. What Does This Document Cover?

This document explains how Strictly Education use your personal data: how it is collected, why it is collected, and our lawful reasons for doing so, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by UK General Data Protection Regulation (the “UK GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we hold/process is set out in Part 5, below.

4. What Are My Rights?

Under the UK GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Paragraph 12.
2. The right to access the personal data we hold about you. Paragraph 11 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Paragraph 12 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Paragraph 12 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Process?

The type of personal data we collect, or process may vary according to the relationship between you and Strictly Education and according to the service that we provide to you or for your benefit, directly or indirectly. The categories of personal data processed by the various Strictly Education teams are listed below.

Employment/HR Advisory/HR Admin/DBS application teams may process the data below on clients’ employees but only where it is necessary to perform the advisory or consultancy role.

• Personal information and contact details such as name, title, addresses, date of birth, marital status, phone numbers and personal email addresses;
• Emergency contact information such as names, relationship, phone numbers and email addresses;
• Information collected during the recruitment process by the client and retained during employment including references, proof of right to work in the UK, application form, CV, qualifications;
• Employment contract information such as start dates, hours worked, post, roles ;
• Education and training details;
• Details of salary and benefits including payment details, payroll records, tax status information, national insurance number, pension and benefits information;
• Details of any dependants;
• Nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
• Information in your sickness and absence records such as number of absences and reasons (including sensitive personal information regarding your physical and/or mental health);
• Racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
• Criminal records information as required by law to enable employee to work with children;
• Trade union membership;
• Information on grievances raised by or involving the employee;
• Information on conduct and/or other disciplinary issues involving the employee;
• Details of appraisals, performance reviews and capability issues;
• Details of time and attendance records;
• Information about the use of IT, communications and other systems, and other monitoring information;
• Details of use of business-related social media;
• Images of staff captured by the School’s CCTV system;
• Your use of public social media (only in very limited circumstances, to check specific risks for specific functions within the School);
• Details in references about employee client give to others.

School clients may also ask advice which involves our processing of the following categories of data about pupils and parents: -

• Personal information such as name, pupil number, date of birth, gender and contact information;
• Emergency contact and family lifestyle information such as names, relationship, phone numbers and email addresses;
• Characteristics (such as ethnicity, language, nationality, country of birth and free school meal eligibility);
• Attendance details (such as sessions attended, number of absences and reasons for absence);
• Financial details such as monies owed and financial hardship;
• Performance and assessment information;
• Behavioural information (including exclusions);
• Special educational needs information;
• Relevant medical information;
• Special categories of personal data (including biometric data, ethnicity, relevant medical information, special educational needs information);
• Images of pupils engaging in school activities, and images captured by the School’s CCTV system.

The school governance service may process the data below but only where it is necessary to perform the role as governance advisors.

Personal data about Governors: -

• Names, addresses and occupations;
• Email addresses (usually personal as well as business);
• Other identifiers such as date of birth, phone numbers;
• DBS details (where applicable);
• Application details (in application to become a governor);
• Business and pecuniary interests (to determine no conflict);
• Appointment and resignation information.

The Payroll team may process the data below but only where it is necessary to perform the role of payroll contractor.

• Personal information and contact details such as name, title, addresses, date of birth, marital status, phone numbers and personal email addresses;
• Employment contract information such as start dates, hours worked, post, roles;
• Details of salary and benefits including payment details, payroll records, tax status information, national insurance number, pension and benefits information;
• Details of time and attendance records.

Strictly Education process personal data on its staff (including temporary staff, casual staff and volunteers) as well as prospective applications.

• A job applicant’s CV and any cover wording as well as relevant recruitment checks;
• Proof of right to work in the UK;
• Personal information and contact details such as name, title, addresses, date of birth, phone numbers and email address;
• Emergency contact information;
• Details of sickness and absence;
• Performance records;
• Education and training records
• Information on conduct (including disciplinary issues) and records of complaints/concerns;
• Details of salary and benefits including payment details, payroll records, tax status information, national insurance number, pension and benefits information.

Other teams across Strictly Education including (but not limited to) Schools Finance, Facilities Services, Technology and MIS support may process the data below but only where it is necessary to perform the role as a service provider.

• All items of personal information listed in previous sections
• Any data supplied in order to perform is contracted or consultative role which may include personal and special category information regarding pupils or employees

Data processed by Supporting Education Group

Supporting Education Group may process personal data where it is necessary to enable the smooth running of Strictly Education, Supporting Education Group and its subsidiaries. Personal data will consist of names and roles of persons employed by clients of the group which may be shared within the group for the purpose of cross-marketing services.

6. What Is Your Reason For Holding/Processing My Personal Data?

Under the UK GDPR, we must always have a lawful basis for processing/using personal data. The lawful bases for processing are set out in Article 6 of the UK GDPR. The reasons why Strictly Education hold/process your personal data are:

• Because we need to do so in order to perform a contract that we have with you or are taking steps to enter into with you.
• Because we have your consent to hold/process your data.
• Because we have a legal obligation to hold/process the data regardless of whether any contract exists between us.
• Because we have a legitimate interest in holding/processing your data, or there is a legitimate third-party interest and there is not a good reason to protect the individual’s personal data which overrides those legitimate interests.

7. For What Purpose Do You Use My Personal Data?

The purposes for which Strictly Education use your personal data may be one or more of the following:

• Communicating with you to inform you of our services
• Communicating with you with the purpose of entering into a contract with you
• Providing, administering and managing our contract with you.
• Supplying our services to you or for your benefit.
• Personalising and tailoring our services for you or for your benefit.
• Communicating with you on matters that may fall outside the immediate contractual obligations but arise in the course of supplying our services to you
• Advising your employer, where we are engaged as their HR/Employment law advisers, health and safety advisers or school finance and governance advisers –
  • On all matters pertaining to your employment or role
  • On all matters relating to the application and interpretation of health and safety policies and procedures to your employment or role
  • On all matters relating to the operational and educational needs of a school, including clerking and governance
• Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
• We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Where the data relates to a contractual relationship between us and you where it may potentially come to be considered evidence in a dispute, we shall keep that data up to six years after that relationship has ended.
• Where the data consists of information that we are required to retain by law, we shall keep the data as long as we are required to do so.
• Where there is no contractual relationship between us but there exists a risk of litigation where the data may potentially come to be seen as evidence or somehow material, we shall keep the data as long as that risk is live and material.
• Where the information is required for effective operation of our accounts or business operations, we shall keep the data, but no longer than for that required purpose and in accordance with financial best practice requirements.
• Where the purpose for which the data was lawfully acquired is still live we shall keep the data, but no longer than is required by law.

9. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the UK GDPR or to equivalent standards by law.

10. Do You Share My Personal Data?

Strictly Education will not share any of your personal data with any third parties for any purposes, subject to these exceptions:

• To make effective the objectives of a contract that we have with you or for your benefit
• Where we have your consent to share your data
• Where we are legally obliged to do so by statute, a court order or other type of legal obligation

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above. If in the exceptional circumstance that any personal data is transferred outside of the EEA (where, for instance, a laptop is taken on holiday to US), we will take suitable steps in order to ensure that your personal data is treated safely and securely.

11. How Can I Access My Personal Data?

If you want to know what personal data Strictly Education have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12. Cookie Policy

Effective Date: 08-Nov-2023
Last Updated: 08-Nov-2023

What are cookies?
This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to manage the cookie settings.

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.

How do we use cookies?
As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.

The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

Types of Cookies we use

Necessary

Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.

• Cookie - PHPSESSID
  • Duration - Session
  • Description - This cookie is native to PHP applications. The cookie stores and identifies a user's unique session ID to manage user sessions on the website. The cookie is a session cookie and will be deleted when all the browser windows are closed.
• Cookie - __cf_bm
  • Duration - 29 minutes
  • Description - This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.
• Cookie - cookie-yes-consent
  • Duration - 1 year
  • Description - CookieYes sets this cookie to remember users' consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors.

Analytics

Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

• Cookie - _ga_*
  • Duration - 1 year, 1 month, 4 days
  • Description - Google Analytics sets this cookie to store and count page views.
• Cookie - _ga
  • Duration - 1 year, 1 month, 4 days
  • Description - Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.

• Cookie - CONSENT
  • Duration - 2 years
  • Description - YouTube sets this cookie via embedded YouTube videos and registers anonymous statistical data.
• Cookie - CLID
  • Duration - 1 year
  • Description - Microsoft Clarity set this cookie to store information about how visitors interact with the website. The cookie helps to provide an analysis report. The data collection includes the number of visitors, where they visit the website, and the pages visited.
• Cookie - _clck
  • Duration - 1 year
  • Description - Microsoft Clarity sets this cookie to retain the browser's Clarity User ID and settings exclusive to that website. This guarantees that actions taken during subsequent visits to the same website will be linked to the same user ID.
• Cookie - _clsk
  • Duration - 1 day
  • Description - Microsoft Clarity sets this cookie to store and consolidate a user's pageviews into a single session recording.
• Cookie - SM
  • Duration - Session
  • Description - Microsoft Clarity cookie set this cookie for synchronizing the MUID across Microsoft domains.
• Cookie  MR
  • Duration - 7 days
  • Description - This cookie, set by Bing, is used to collect user information for analytics purposes.

Performance

Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.

• Cookie - SRM_B
  • Duration - 1 year, 24 days
  • Description - Used by Microsoft Advertising as a unique ID for visitors.

Advertisement

Advertisement cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.

• Cookie - YSC
  • Duration - Session
  • Description - Youtube sets this cookie to track the views of embedded videos on Youtube pages.
• Cookie - VISITOR_INFO1_LIVE
  • Duration - 5 months, 27 days
  • Description - YouTube sets this cookie to measure bandwidth, determining whether the user gets the new or old player interface.
• Cookie - MUID
  • Duration - 1 year, 24 days
  • Description - Bing sets this cookie to recognise unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations.
• Cookie - ANONCHK
  • Duration - 9 minutes
  • Description - The ANONCHK cookie, set by Bing, is used to store a user's session ID and verify ads' clicks on the Bing search engine. The cookie helps in reporting and personalization as well.

Other

Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.

• Cookie - VISITOR_PRIVACY_METADATA
• Duration - 5 months, 27 days

13. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

For the attention of: Tim Hart
Email address: dpo@strictlyeducation.co.uk   
Telephone number: 0330 123 2540
Postal Address: Strictly Education Ltd, Marlborough Court
Sunrise Parkway, Linford Wood
Milton Keynes,MK14 6DY

14. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available online.