1. INTRODUCTION

 

Reach  is committed to protecting and preserving the privacy of visitors to its website and other people with whom it communicates electronically (for example, by email). Under data protection law, individuals have a right to be informed about how Reach uses any personal data which it holds about them. When we refer to "you" or "your" in this notice, we are referring to you as an individual visiting our website or communicating with us electronically. We refer to Reach as “Reach”, “we”, “our” or “us”.

 

Reach compromises of a number of different organisations within its model. Currently these are:

  • Reach Academy
  • Reach Children’s Hub
  • Reach Sixth Form
  • Feltham Convening Project
  • Reach Training.

We comply with this right by providing privacy notices (sometimes called fair processing notices). This notice sets out information about our collection and processing of personal information related to visitors to our website and other people with whom we communicate electronically. We have separate privacy notices for parents and pupils attending our Academy and other services and for our members of staff and contractors and suppliers.

We are the data controller for the purposes of data protection law.

Our Data Protection Officer (DPO) is Hannah Pope.

This Privacy Notice should be read in conjunction with our Data Protection Policy.

 

  1. THE PERSONAL DATA WE HOLD

The personal information that we will collect about you falls into the following categories:

Information collected automatically by our website

Our website collects some limited information about you automatically when you visit the site using your electronic device (this could be a computer desktop, laptop, phone, tablet, television). We do not seek to identify you from this information or do anything with it that will affect you individually. To the extent practicable, we aggregate and/or remove anything that could be used to identify you from this information before we use it, including (where possible) anonymising IP (Internet Protocol) addresses.

This information includes, or may in the future include:

  • the IP address from which you access our website
  • information about the device used to access the site
  • your approximate location
  • the pages that you click on our site
  • the time that you spend on the site.

Information that you input to our website

Some pages on our website invite you to input information about yourself – for example, we have links for google forms on the Reach Sixth Form website where you can make an application to join us; on the Academy website, there are google forms where parents/carers can request time off for religious observance and time off for appointments etc).

In those cases the information sought is clear on the relevant page/form.

Information that you send to us by email or other electronic means

You may also send us information about yourself by email or other electronic means (for example, through Facebook or Twitter). In that case we will record your name and basic contact details and, of course, the information that you include in your communication.

When we invite you to provide information about yourself, it is entirely up to you whether you give us the information or not. Often, however, we will not be able to do something that you are asking for (for example, respond to an enquiry) if you do not give us the information.

 

  1. SPECIAL CATEGORY DATA

The information we hold is not normally classed as special category data. This includes any information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, genetic or biometric data. If we do hold any such data about you, we will inform you.

 

  1. WHY WE USE THIS DATA

We use your personal information for the following purposes:

  • Information collected automatically by our website

We use this information to improve our website and other materials that we provide through it. We do not use it to do anything that will affect you individually.

  • Information that you input to our website

The purposes for which we use this information (for example, to respond to your enquiry or to process your application to join our Academy or Sixth Form) are explained on the web pages where we ask you to submit it.

  • Information that you send to us by email or other electronic means

We use this information to communicate with you, to respond to any enquiries that you may raise, and to manage our relationship with you.

Your personal information also forms part of our relationships with visitors to our website, and we use these records to oversee and assess our programmes and derive insights for the future development of our services. The records may also in some circumstances be used as evidence of these various matters, should a disagreement arise.

We will not sell or rent your personal information or use or share your personal information for marketing purposes, unless you provide us with consent for us to do so.

We may need to use or disclose your personal information in order to comply with our legal obligations.

 

  1. OUR LEGAL BASIS FOR USING THIS DATA

We only collect and use personal data when the law allows us to. As set out above, we will not sell or rent your personal information or use or share your personal information for marketing purposes, unless you provide us with consent for us to do so.

We may need to use or disclose your personal information in order to comply with our legal obligations.

We may occasionally seek your consent to allow us to process your personal information – for example, if you ask us to send you details of our programmes, we may ask for your consent to use your contact details in order to send you this information.

If we are relying on your consent, you can withdraw your consent at any time. We will make this clear when we ask for consent and explain how it can be withdrawn.

Generally, however, we need to collect and process your personal information, to the limited extent described in this privacy notice, so that we can pursue our legitimate interests in:

  • delivering our services and programmes through our various organisations, including administering, managing, delivering and improving the education we provide at our Academy and Sixth Form and at our other services and programmes and resolving any related legal issues that may arise; and
  • (if you submit information to our website or send us information by email or other electronic means) communicating with you, responding to your enquiries and managing our relationship with you, all as part of delivering and improving our services and programmes.

 

  1. COLLECTING THIS DATA

Most of the personal information we hold about you comes from you directly, either via our website, through our communications and interactions with you, such as email.

Whenever we seek to collect information from you, we make it clear whether providing it is mandatory or optional. If it is mandatory, we will explain the possible consequences of not complying.

In some cases, we may ask you to provide some personal information via a third party. We will always ensure that these third parties have appropriate safeguards in place to ensure your personal information is kept safe and secure.

 

  1. HOW WE STORE THIS DATA

We are committed to doing all we can to keep your personal information safe and secure. We have set up systems and processes to prevent unauthorised access or disclosure of your information. We also make sure that any third parties that process your information on our behalf keep your personal information secure.

We use encrypted drives to store information; we limit access to only those who need access; we keep a record of data access and modification for records on our systems; we manage and restrict all devices which have access to Reach systems or services.

  1. DATA SHARING

We do not share information about you with any third party without consent unless the law, our policies or the terms of this privacy notice allow us to do so.

Your personal information may be shared with third party service providers who host and process your information on our behalf in order to support our programmes.

We share aggregated information about the use of our website with partners but this does not involve disclosure of information from which you could be identified.

We may also need to disclose your personal information in order to protect our legal rights and comply with our legal obligations.

 

  1. TRANSFERRING DATA INTERNATIONALLY[1] 

The majority of Reach’s technology is based within the European Economic Area and is fully compliant with the UK GDPR laws. However, some of the services we use are based outside the UK and the European Economic Area. We only use these services where we are satisfied with their levels of security and we will put contractual safeguards in place. Keep in mind that when you give us personal information it could be being transferred, stored or processed in a location outside the UK and the EEA.

 

  1. INDIVIDUAL’S RIGHTS REGARDING PERSONAL DATA

Individuals have a right to make a ‘subject access request’ to gain access to personal information that we hold about them.

If you make a subject access request, and if we do hold information about you, we will:

  • Give you a description of it;
  • Tell you why we are holding and processing it, and how long we will keep it for;
  • Explain where we got it from, if not from you or your child;
  • Tell you who it has been, or will be, shared with;
  • Let you know whether any automated decision-making is being applied to the data, and any consequences of this;
  • Give you a copy of the information in an intelligible form.

Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request please contact our DPO.

 

Other rights

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:

  • Object to the use of personal data if it would cause, or is causing, damage or distress;
  • Prevent it being used to send direct marketing;
  • Object to decisions being taken by automated means (by a computer or machine, rather than by a person). Currently we do not carry out any automated decision making or profiling on the personal data we process. If this changes then we will let you know and update this Notice accordingly;
  • In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing;
  • Request the transfer of automated personal data to them or to a third party. We will provide personal data in a structured, commonly used, machine-readable format;
  • Withdraw their consent at any time where we are processing personal data on the lawful basis of consent. The individual can do this by contacting the DPO;
  • Claim compensation for damages caused by a breach of the data protection regulations.

To exercise any of these rights, please contact our DPO.

 

  1. COMPLAINTS

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our DPO.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

  • Report a concern online at https://ico.org.uk/concerns/
  • Call 0303 123 1113
  • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

  1. CONTACTING US

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our DPO:

Name:  Hannah Pope

Address: Reach Academy Feltham, 53 - 55 High Street, Feltham, London, TW13 4AB

Tel: 020 8893 1099

Email: hannah.pope@reachacademy.org.uk

 

This Notice

We will update this Privacy Notice from time to time.  Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.