Purpose of this privacy notice

This privacy notice aims to give you clear and detailed information about:

• how we collect and process your personal data
• the legal grounds allowing us to do so
• how we look after your personal data
• your privacy rights
• how the law protects you.
  
  

Controller

Under data protection law the controller of your personal data decides how and why your personal data will be processed and takes responsibility for looking after your personal data. The controller of your personal data will be REDHILL.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Postal Address: Redhill (Haverfordwest), The Garth, Haverfordwest, SA61 2UR.

Data Protection Officer: Jo Morris

Email address: office@redhillprepschool.co.uk

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

When we issue a new version of this privacy notice we will post a message on our websites advising of this.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, curriculum vitae (CV), covering letter, academic record, employment history and references and images captured by CCTV.
• Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data).
• Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
• Contact Data includes your home address, email address and telephone numbers, next of kin and emergency contact information.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when accessing our website www.catscolleges.com or any of the websites of our subsidiaries accessed from that website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our websites and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose. Where Aggregated Data can directly or indirectly identify you we will use it in accordance with this Privacy Notice.

If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with education services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data by filling in application forms, by sending us your CV, covering letter, teaching video submissions or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

• create an account on our website;
• request marketing information is sent to you;
• apply for one of our courses;
• apply for a job;
• complete a survey; or
• give us some feedback.
  
  

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as those set out below:

• Educational agents – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
• Parents or parental approved representatives – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
• Universities – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
• Named Referees – Identity Data and Contact Data
• Recruitment agencies – Identity Data and Contact Data
• Disclosure and Barring Service – Criminal Conviction Data
• Providers of technical, payment and delivery services – Contact, Financial and Transaction Data.
• Technical Data from the following parties:

1. analytics providers;
2. advertising networks; and
3. search information providers.
   
   

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.

Our legal basis for using your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).
• Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).
• Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).
• Where you have given us your consent to process your personal data (CONSENT).
• Where there is an emergency situation, for example, if you needed emergency medical treatment (VITAL INTERESTS).
  
  

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending third party direct marketing communications to you via email or text message.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You have the right to withdraw your consent at any time by contacting us. Please see Section 10: Your legal rights

How we use your personal data

How we use your personal data

5.a PROSPECTIVE STUDENTS AND AGENTS

Purpose/Activity	Type of Data	Legal Basis
To register you on our website and subscribe to our services	Identity	Contract
	Contact
	Marketing and Communications Data	Consent
To process your application form and correspond with you including:	Identity	Contract
(i) Processing deposits and tuition fees	Financial

5.b ENROLLED STUDENTS

Purpose/Activity	Type of Data	Lawful Basis
To register you for our services as an enrolled student	Identity	Contract
	Contact
	Financial
	Transaction
	Special Category	Consent
To provide you with ongoing services after enrolment including:	Identity	Contract
(i) provision of core teaching and learning services	Contact
(ii) administration including maintaining student records, processing fees, managing accommodation	Financial
(iii) providing services including library, IT and information services and other student support services (excluding welfare and medical)
To provide you with ongoing services after enrolment in respect of student welfare and medical services	Identity	Contract
	Special Category	Consent
To provide you with reports on your child’s progress	Identity	Contract
	Contact
To process student complaints and grievances	Identity	Legitimate interests (It is in the interest of both parties for us to investigate and attempt to resolve complaints and grievances)
	Contact
	Special Category	Consent
To carry out internal research and statistical analysis	Identity	Legitimate interests (to monitor and evaluate the performance and effectiveness of our courses)
To capture images on CCTV used by our school and nursery	Identity	Legitimate interests (the company has an organisational requirement to maintain the security of its premises and for the prevention and investigation of crime)
To monitor attendance and compliance with attendance regulations and to identify any support needs	Identity	Legal obligation
	Contact
To conduct lesson observations using sound and video recording software	Identity	Legitimate interests (It is appropriate for the company to monitor teaching quality and to share examples of good practice as an internal training resource.)
To take photographs and videos of students for marketing purposes (including for use in brochures, on our website and in promotional videos)	Identity	Consent
To use examples of students’ work in class for the improvement of teaching and learning practice.	Identity	Legitimate interests (It is appropriate for us to share examples of good practice during lessons. Some items may be named.)

5.c PROVISION OF PERSONAL DATA TO THIRD PARTIES (INTERNAL AND EXTERNAL)

Purpose/Activity	Type of Data	Lawful Basis
Internal
To enable our companies to provide :	Identity	Legitimate interests (The transfer is necessary to enable us to provide our services. All our subsidiaries are subject to this privacy policy and other relevant policies and procedures.)
(i) application and admissions services	Contact
(ii) core teaching and learning services	Financial
(iii) student administration services and	Transaction
(iv) student welfare services	Special Category	Consent
External
To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency where you are incapable of giving consent	Identity	Vital Interests
	Contact
	Special Category	Vital Interests
To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency and where we are legally obliged to comply with a request for disclosure	Identity	Legal obligation
	Contact
	Special Category	Legal Obligation & Public Interest (in the area of public health)
To providers of activities for students	Identity	Legitimate interests (The company offers various activities as part of its courses and cannot provide these activities itself)
	Contact
	Special Category	Consent
To provide information to Schools Inspectorate (Estyn) during inspection visits	Identity	Legal obligation
	Contact	If a student provides a confidential student questionnaire to ISI as part of its review then this will be on the basis of the student providing consent at the time of submission
To local councils to enable them to assess council tax obligations (UK).	Identity	Legitimate interests (To enable REDHILL to notify councils that certain accommodation is exempt from council tax)
	Contact
To HM Revenue & Customs for reporting of financial processing activities (UK)	Identity	Legal obligation
	Contact
	Financial
	Transaction
To service providers worldwide who provide IT and system administration services	Identity	Legitimate interests (We have a business requirement to use third party providers for specialist services)
	Contact
	Special Category	Consent
To cloud hosted virtual learning environment (VLE) services	Identity	Legitimate interests (We have a business requirement to use VLEs in order to provide some teaching and learning services
	Contact
Professional advisors subject to a duty of confidentiality (e.g. lawyers, bankers, insurers, auditors)	Identity	Legitimate interest (We have a business requirement to seek specialist professional advice that cannot be provided internally)
	Contact
	Financial
	Special Category	Consent
To local authorities regarding a safeguarding concern in relation to Keeping Learners Safe or the Prevent Duty (UK).	Identity	Legal obligation
	Contact
	Financial
	Special Category	Legal obligation
To local authorities regarding withdrawal of compulsory school age children (UK)	Identity
	Contact
	Financial
	Special Category	Legal obligation
To the Police regarding a safeguarding concern or in connection with the prevention or reporting of a crime.	Identity	Legal obligation or Vital interests (depending on the circumstances)
	Contact
	Special Category	Legal obligation or Vital interests (depending on the circumstances)

5.d EMPLOYMENT CANDIDATES

Purpose/Activity	Type of Data	Lawful Basis
To assess your skills, qualifications and suitability for the role	Identity	Contract
	Contact
To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment process	Special Category	Consent
Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record)	Identity	Contract
	Contact
Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied for	Identity	Contract
	Criminal Conviction	Legal obligation
To communicate with you about the recruitment process	Contact	Contract
To comply with equal opportunities monitoring and reporting requirements	Identity	Legal obligation
	Special Category	Legal obligation and necessary for statistical purposes

5.e EDUCATIONAL STAFF APPLICANTS

Purpose/Activity	Type of Data	Lawful Basis
To assess your application for a teaching position	Identity	Contract

5.f ALL VISITORS TO THE WEBSITE

Purpose/Activity	Type of Data	Lawful Basis
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity	Legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy)
	Contact
	Profile
	Usage
	Technical
	Marketing and Communications	Consent
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Technical	Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
	Usage
To make suggestions and recommendations to you about services that may be of interest to you	Identity	Legitimate interests (to develop our services and grow our business)
	Contact
	Profile
	Usage
	Technical

5.fi PROVISIONS OF PERSONAL DATA TO THIRD PARTIES (EXTERNAL)

Purpose/Activity	Type of Data	Lawful Basis
To service providers worldwide acting as processors who provide IT and system administration services	Identity	Legitimate interests (We have a business requirement to use specialist IT and system administration providers that cannot be provided internally)
	Contact
	Technical
	Usage
	Profile
To third parties to whom we may choose to sell, transfer or merge parts of our business as our assets.	Identity	Legitimate interests (We may wish to do this as part of our business strategy)
	Contact

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the REDHILL subsidiaries for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

External Third Parties

• Educational agents
• Parents or parental approved representatives
• Government and Corporate Financial Sponsors and Embassies
• Taxi companies
• Accommodation providers
• Student insurance provider
• Approved test centres
• Medical or Public Health authorities (and where an emergency situation to any other organisations/individuals deemed necessary as assessed at the time)
• Providers of activities for students
• Local authorities
• Welsh Government

• Schools Inspectorate (

• Local councils
• HM Revenue & Customs, regulators and other authorities acting as processors
• Cloud-hosted VLE providers
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

ational transfea security

The personal data that we collect from you will be stored:

• in our own secure data centre

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data?

Details of retention periods for different aspects of your personal data are set out in the tables below:

Student Records

1. Student Recruitment

Type of data	Retention timescale
Enquiries from prospective students	1 year from last sales activity
Records of campaigns and events	1 year from last sales activity

2. Applications – Not Progressed (Closed)

Type of data	Retention timescale
Application form	2 Years after date of closure
Offer of place and related correspondence	2 Years after date of closure
Acceptance of place and related correspondence	N/A

3. Arrived/Enrolled Students – Withdrawn

Type of data	Retention timescale
Application form (incl scholarship applications)	Original course end date + 3 years
Offer of place and related correspondence	Original course end date + 3 years
Acceptance of place and related correspondence	Original course end date + 3 years
Copies of invoices	7 Years after date of Withdrawal

Candidate Records

Type of data	Retention timescale
Application forms, CVs and interview notes (unsuccessful candidates)	Last communication to candidate + 6 months
Application forms, CVs and interview notes (successful candidates)	Part of personnel file. 6 years after employment ceases.

Teaching Applicant Records

5. Teaching Applicants

Type of data	Retention timescale
Records of CV’s, covering letters and teaching video submissions	6 months from communication of employment decision.

(Please note that our stated data retention periods may be affected by the terms of reference of the Independent Inquiry into Child Sexual Abuse (IICSA). We are obliged to retain all documentation regarding a safeguarding concern for the duration of the IICSA. For more information please visit www.iicsa.org.uk).

In some circumstances you can ask us to delete your data: see Request erasure in Section 10 Your legal rights for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data – (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data – (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data – (also known as the “right to data portability”) We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer in writing with full details of your request. You can send an email to office@redhillprepschool.co.uk  or you can write to us at:

Data Protection Officer, Redhill Prep School, The Garth, Haverfordwest. SA61 2UR

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.