Under the EU's General Data Protection Regulation (GDPR) personal data is defined as:
"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".
- Who we are
- How we collect information
- What we use your information for
- Sharing your information
- Your rights as a data subject
- Retention Policy
- Special categories of personal information
- Security and storage of information
- Transfers outside of Europe
- Other sites
1. Who are we
The BTSA is a partnership of three lead schools; The Appleton School, The King John School and Kingston Primary School.
Financal management: The Appleton School, Croft Road, Benfleet, Essex SS7 5RN.
The BTSA is dedicated to strengthening and developing teaching and learning throughout our locality to ensure all students receive an education that positively impacts on their progress and attainment.
Under the GDPR regulations, BTSA does not require a Data Protection Officer however our management can be contacted on:
Tel: 01268 754137
2. How we collect your information
We will collect information from you if you:
- have booked onto a course or event on our website, via email or by any other method or medium; this will include your name (including school name), address, contact details (including telephone number and email address) and your payment details;
- apply to join our teacher training programme, attend a recruitment event or provide information through the recruitment process;
- registered as a member on our website; this will include your name, school, address, email address and telephone number;
- complete online forms, take part in surveys, write posts on any message boards, post any blogs, download information such as templates, or participate in any other interactive areas that appear on our website or which we offer to you from time to time;
- provide your contact details to us when registering to use or accessing any product or service we provide;
- contact us offline e.g. by telephone, fax, email or post.
3. What we use your information for
We will use your information to assist us in the production, delivery and invoicing of any training or service that you may have requested or we have provided. We may also contact you for feedback on your request. In relation to teacher training registration, we are required to authenticate identity, administer accounts, share details with schools and recruitment institutions, share site updates and enable third parties to contact you in relation to teaching opportunities. We may use your personal data for internal purposes such as auditing, data analysis and research to improve our products, services, website and customer communications.
We may also use your information to send important notices, such as communications about CPD or events, school support, funding applications and any changes to our terms, conditions and policies.
BTSA may use your information to contact you with details about our training and services which we feel could be of interest to you.
You have the right at any time to stop us from contacting you for marketing purposes. If you wish not to be contacted by us, you can send an email request to firstname.lastname@example.org
4. Sharing your information
We will pass your personal data on to third-party service providers when requested by government/teaching authorities as part of our funding agreement contract. Any third parties that we may share your data with are obliged to keep your details securely (e.g. other schools, organisations, ITT providers, payment providers, delivery facilitators, website hosts where relevant) and to use them only to fulfil the service they provide you on our behalf. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so otherwise.
We may pass collective information about the use of our website or our products or services to third parties but this will not include information that can be used to identify you.
We will disclose your information if we are required to do so by law. We may disclose your information to enforcement authorities if they ask us to, or a third party in the context of actual or threatened legal proceedings, provided we can do so without breaching data protection laws.
5. Your rights as a data subject
As a data subject, you will have the following rights:
- right to access - you have the right to request a copy of the information that we hold about you
- right of rectification - you have the right to correct data that we hold about you that is inaccurate or incomplete
- right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records
- right to restriction of processing - where certain conditions apply to have a right to restrict the processing
- right of portability - you have the right to have the data we hold about you transferred to another organisation
- right to object - you have the right to object to certain types of processing such as direct marketing
- right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling
- right to judicial review - in the event the BTSA refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below
How to access what personal data we hold about you
BTSA, at your request, can confirm what information we hold about you and how it is processed. If BTSA does hold personal data about you, you can request the following information:
- identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU
- contact details of the data protection officer, where applicable
- the purpose of the processing as well as the legal basis for processing
- if the processing is based on the legitimate interests of the BTSA or a third party, information about those interests
- the categories of personal data collected, stored and processed
- recipient(s) or categories of recipients that the data is/will be disclosed to
- if we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely
The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information:
- how long the data will be stored
- details of your rights to correct, erase, restrict or object to such processing
- information about your right to withdraw consent at any time
- how to lodge a complaint with the supervisory authority
- whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
- the source of personal data if it wasn't collected directly from you
- any details and information of automated decision making, such as profiling and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
What forms of ID will I need to provide in order to access this?
BTSA accepts a minimum of two of the following forms of ID when information on your personal data is requested:
- driving licence
- another form for ID which leaves no doubt of the data owner
To request access or obtain a Subject Access Request (SAR) form, please contact email@example.com
6. Retention policy
BTSA will only keep your personal information for as long as we reasonably require it and only for as long as Data Protection Legislation allows. We process and hold certain items of personal data for a minimum of 7 years as required to coincide with HMRC and accounting records.
Where there is the possibility of litigation, a Freedom of Information or Data Protection official request or appeal, records must not be destroyed until the process has been completed.
7. Special categories of personal data
We may ask to 'view' an item of 'special' personal data if being asked to hand over any data as we are required to identify an authorised recipient in order to prevent a data breach.
9. Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage.
Some communications sent over the internet, such as email, may not be secured unless they are encrypted. Although we do our best to monitor and improve how we protect your personal data, we cannot guarantee the security of your data which is transmitted to our website or other products and services via an internet or similar connection and any transmission of data to our site is at your own risk. If we have given you (or you have chosen) a password to access certain areas of our website, product or services please keep this password safe - we will not share this password with anyone.
10. Transfers outside Europe
Personal data in the European Union is protected by data protection laws but please note that countries outside the EEA may not have the same standard of data protection legislation as countries within the EEA.
11. Other sites
In the event that you wish to make a complaint about how your personal data is being processed by BTSA or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority which is the Information Commissioner's Office (ICO). Further information can be obtained at www.ico.org.uk or by telephoning 0303 123 1113.
You can report a concern directly with the ICO, if BTSA fails to handle your complaint in an appropriate manner: https://ico.org.uk/concerns/
Please send any initial complaints to: firstname.lastname@example.org or contact directly on Tel: 01268 754137