The EU General Data Protection Regulation (GDPR) includes rules on giving privacy information to those whose data is held by an organisation (data subjects). These are more detailed and specific than in the Data Protection Act (DPA) and place an emphasis on making privacy notices understandable and accessible. Data controllers are expected to take ‘appropriate measures’ to ensure that this is the case.
The School interprets this as using very clear language to outline each of the responsibilities for each of the data subject groups.
The GDPR say that the information provided to data subjects about how The Royal Grammar School Worcester (RGSW) processes their personal data must be:
• concise, transparent, intelligible and easily accessible;
• written in clear and plain language, particularly if addressed to a child; and free of charge.
These requirements are about ensuring that privacy information is clear and understandable for data subjects. These requirements are about ensuring that privacy information is clear and understandable for data subjects. This privacy notice deals with the overall privacy responsibilities of the school but includes a particular notice that applies to parents (or guardians) of children at RGS or applying to join RGS Worcester. The notice deals with two sources of data, that obtained directly from the subject and, data not obtained directly from the subject.
Mr Ian Roberts Privacy and Compliance Officer (email@example.com)
Please note, copies of the RGSW Data Protection and Images Policies are available on the website.
Where reference is made to ‘legitimate interest’ in the above policies, you do have the right to object and this should be done in writing to the Privacy and Compliance Officer, RGSW, Upper Tything, Worcester WR1 1HP.
RGSW/The School refers to RGS Worcester, RGS The Grange, RGS Springfield and RGS Dodderhill.
PRIVACY NOTICE PARENTS (OR GUARDIANS) OF CHILDREN AT RGSW, OR APPLYING TO JOIN RGSW DATA PROTECTION REGULATIONS: PRIVACY NOTICES
This Notice should be read in conjunction with the introductory paragraphs above.
This Privacy Notice will be provided to you at the time your data is being obtained, or prior to the introduction of GDPR in the case of current parents, if it is being obtained directly. Data will be processed for the purposes of responding to requests for information about joining RGSW and The School will therefore have a “legitimate interest” for processing basic personal data and sensitive personal data.
The data the School holds will be the minimum it requires to form and maintain the contract between you and RGSW. When registering an interest at RGSW we do ask you to advise your occupation as an optional field on the registration form. This information is asked as we believe it assists when communicating with parents at relevant times, aids pastoral care and for possible assistance with Careers support. RGSW may share your data with the following providers who have contracts with the School and who have equalled the school’s precautions and systems for dealing with data, these are:
• Catering contractor
• Photographers and School year book publishers
• Healthcare service providers
• IT contractors
• IT software providers
• Ministry of Defence (if the child joins the RGS CCF)
• Outdoor education centres and travel operators
• Careers advice services
• The RGSW and AOS Foundation
• The AOOE’s (The Alumni Association)
• Independent School Inspectorate
• Health and Safety Executive
• Local Authority
• Insurance Company
• Educational establishment your child transfers to
It is not necessary for data to be shared with other countries. The exception to this will be international trips that the School organises, should this be envisaged for your child, you will be contacted for your consent, the consent will be limited in time and content if it is required.
The retention period for most pupil data will be until the pupil reaches the age of 25. The School will maintain a permanent record of pupils who attend each RGS School, along with their examination results and notable achievements.
You have the right to withdraw your consent to data processing at any time, however this will only apply to certain groups of data for which you have given particular consent.
You can complain at any time about how RGSW has handled your data, the Information Commissioner is available as follows: ICO helpline is 0303 123 1113.
We will obtain the data RGSW requires from you and should we need data from other sources we will contact you within a month. We see the provision of personal data as necessary to properly admit your child to RGSW and to fulfil its obligations under the contract once your child is a pupil here.
There is no automated decision making or profiling involved in this data stream into and through RGSW. Please note: Subject to where we need consent, the School may process your personal data for the purposes of direct marketing, which is deemed to be a legitimate interest.
The School Newsletters are not considered to be a legitimate interest and therefore explicit consent is sought. This data is held by a third party (Mail Chimp) based in the US and therefore personal data is held outside the EEA for those who have given consent.