Data Privacy Notice
St Joseph’s Nympsfield Out of School
Club and Your Personal Data
We
need to keep certain personal information about parents and children who use
our services in order to fulfil our contractual obligations and deliver the wrap
around care for those children currently attending St Joseph’s Catholic Primary
School, or are in their final pre-school year at St Joseph’s Pre-school before
moving to Primary School. Under the
Childcare Acts 2006 and 2016, we are required to adhere to the requirements
contained within the Early Years Foundation Stage (EYFS) framework together with
the DfE’s guidance “Keeping Children Safe in Education” (KCSiE) and
“After-school clubs, community activities and tuition: safeguarding guidance
for providers”. From 25 May 2018 the
processing of this personal information is governed by the General Data
Protection Regulation (GDPR) 2018.
We
only collect personal data when we have a lawful reason for doing so, and we
only use it for the purpose it was originally obtained for. We take steps to ensure that the data we keep
is accurate, up to date and secure, and we do not keep it for any longer than
is necessary. We have written policies
and procedures in place for dealing with personal data, including breaches of
security, and our staff have appropriate training and awareness of data
protection principles and procedures.
St
Joseph’s Nympsfield Out of School Club are a Data Controller for your personal
data, which means that we decide what information we need to keep about you and
why, and how we process and store that information.
What personal data do we keep and
process?
St
Joseph’s Nympsfield Out of School Club will collect only the personal
information we need to perform our functions.
When you register your child to attend the Club you are required to
register via our online booking system[1]
and this includes personal data.
Personal data can only be viewed and processed by relevant staff and/or
committee members who have access to the online booking system. Data about children is classified as
‘sensitive’ and we take extra care to keep it safe.
Kids
Club HQ have their own privacy agreement which can be viewed here.
What do we use your personal data for?
St
Joseph’s Nympsfield Out of School Club will use the information about you and
your child to enable us to comply with EYFS and KCSiE.
We
will use the contact details you give us to get in touch with you via telephone,
email and via your child’s book bag.
This is so we can send you information about your child, the Club and
other relevant news. Also, so we can
communicate with you regarding payment of fees.
How is your personal data stored?
Your
personal data is stored in the following ways:
· Kids Club HQ system (online booking system)
(electronic format): access is password protected for both parents/carers and
staff/committee, with different levels of access dependent on their needs (eg. the
Play Leader has access to add late collection charge to accounts);
· Accident records (physical format): kept in a
building with secure access. Full
accident records are kept in a locked cupboard within the building.
What is the legal basis for processing
your personal data?
Our
legal basis for processing the personal information relating to you and your
child is that we can fulfil our contract with you.
How long do we keep your personal data
for?
St
Joseph’s Nympsfield Out of School Club will keep your personal data as long as
·
you and your
child have an account on the online booking system; and
·
your child is attending
either St Joseph’s Catholic Primary School or St Joseph’s Pre-school.
Data
that is no longer required is erased after your child has ceased attending our
Club, ie. when they leave St Joseph’s Catholic Primary School or St Joseph’s
Pre-school for another school/setting.
However, we are required to keep some data because of statutory
regulations[2]. All personal data is kept securely with
limited access[3]. You can see our retention of records policy
for more details[4].
Who do we share the information with?
St
Joseph’s Nympsfield Out of School Club will only share personal information about
you or your child with another organisation if we:
·
have a
safeguarding concern about your child;
·
are required to
by government bodies or law enforcement agencies;
·
engage a supplier
to process data on our behalf (eg. to issue invoices, provide the online
booking service);
·
have obtained
your prior permission (written and/or verbal), unless there is a specific
safeguarding issue which allows us to bypass this[5].
When
you register with the online booking system we ask for your specific permission
to take photographs of your child for use on our Facebook page or on the website.
What are your rights with regard to your personal data?
Under the GDPR you have the right to:
· know
what personal data we keep about you;
· request
a copy of the personal data we hold about you[6];
· request
that we correct any personal data which is found to be inaccurate or out of
date;
· request
that we erase any personal data where it is no longer necessary for us to keep
that data;
· request
us to transmit the personal data that we hold about you to another data
controller. (This right only applies
where the processing we do is by your consent or for the processing of a
contract, and where that processing is by automatic means);
· withdraw
your consent for processing to which you have previously given your consent. (Please note that if you do this
o we will not be able to continue to
care for your child if we do not have sufficient information about them;
o
even after your child has left our
care, we have a statutory duty to retain some types of data for specific
periods of time, so cannot delete everything immediately.
Who to contact
If you have any queries or complaints, or wish to exercise
any of the above rights, please contact our
Data Protection Lead via email on chairoosc.st.josephs@gmail.com,
or write to the Club Chair, St Joseph’s Nympsfield Out of School Club, Front
Street, Nympsfield, Stonehouse, Gloucestershire GL10 3TY. We will respond to your request within 30
days from the initial date of the request even if this was via telephone or in
person.
Making a
complaint to the Information Commissioner
If you wish to make a complaint about how we use your personal
data to the Information Commissioner Office (ICO), you can contact them by
visiting their website at https://ico.org.uk/
or by calling 0303 123 1113.
St
Joseph’s Nympsfield Out of School Club is not currently registered with the ICO.
St Joseph’s Nympsfield
Out of School Club’s policies and procedures
You can access copies of all the Out of School Club’s current
policies and procedures, including those referenced in this Privacy Notice, via
the Club’s section of St Joseph’s Catholic Primary School’s website (click link
here).
[2] Section 3 of the EYFS
[3] See 5.3: Data Protection
[4] See 5.6 Retention Periods for Records
[5] See 1.2: Safeguarding and Child Protection
[6]
See 5.4 : Data Subject Access Requests