Privacy Policy

DATA PROCESSOR:

Alpha Plus Group Ltd

Company number 03704941

50 Queen Anne Street

London W1G 8HJ

DATA CONTROLLER:

Pembridge Hall School (also referred as “the School”)

18 Pembridge Square,

London, W2 4EH

Alpha Plus Group Ltd is part of Inspired Education Holdings Limited (“Inspired Education Group”), which is a company registered in England with number 09268120 and registered address in Sixth Floor, 3 Burlington Gardens, London, W1S 3EP, United Kingdom. Inspired operates numerous affiliated schools globally via its regional offices in United Kingdom, Europe, Africa, Middle East, Asia-Pacific and Latin America.

1. INTRODUCTION

This policy is drafted following the UK GDPR and the DPA 2018.

Our Group’s Data Protection Officer can be contacted at this address, by telephoning 020 7487 6000 or by emailing dpo@alphaplusgroup.co.uk.

2. SOURCES AND TYPES OF PERSONAL DATA WE PROCESS

We process personal data directly from parents and / or students of legal age or their legal representatives and tutors. The personal data processed are mainly the following:

• Name and contact information such as address, email and telephone number of the pupil,

parent, guardian and fee payer;

• Pupil date and country of birth, ethnicity and country of residence, passport number or

national identity, card details and visa status;

• Information relating to pupil education history such as previous schools and education

institutions, courses completed, dates of study, attendance records and examination results;

As part of this, we may collect references from previous schools or educational institutions as required by the application process;

• Information relating to fees such as banking details, scholarships and bursaries;
• Information which may assist with provision for the appropriate medical and pastoral care of

the pupil such as any disability, medical, or dietary issues. This may also include information

about family or personal circumstances where this is relevant to the assessment of

suitability to receive a bursary;

• A photograph of the pupil will be kept. This will be for identification purposes only and we

will seek consent for any other usage.

Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:

• Information about health status or provision of health care linked to a specific individual;
• Behavioural information;

• Special educational needs;

• Biometric information;
• Ethnicity;
• Religion or ideology;

3.  HOW WE COLLECT AND PROCESS PERSONAL DATA

Wetherby School collects information in several ways, including:

• Personally and over the phone;
• Through our website, not only through our online forms but also from our cookies;
• From email and hand delivery paper documentation including job applications, invoices, letters or consent forms;
• Through online tools such as apps, educational platforms and other software used by our Schools;
• Through any CCTV cameras located at our premises or sites;
• Through third parties, such as legally authorised individuals, professionals or authorities working with or on behalf of the individual;

– Employment data: If you want to send us your CV through our website, the section “Careers”, you will have to create an account to make use of the employment platform and to send us your employment application. Your information will be shared with Inspired Education Group as the owner of the platform Global Careers Site in the terms exposed at: https://careers.inspirededu.com/data-privacy-statement  and incorporated in the files owned by Alpha Plus Group Ltd where the application was submitted. The Alpha Plus Group Ltd’s Human Resources department will process your data with the purpose to include your candidacy in our selection processes.

4.  LAWFUL BASIS AND PURPOSES FOR WHICH WE PROCESS PERSONAL DATA 

– The primary use of the personal data we collect is to support the learning and development of pupils during their time at schools or colleges in the Group, whilst ensuring the wellbeing and safeguarding of the pupils.

– We will process personal data because it is necessary for the performance of a contract with you,

or prior to admitting pupils, in order to take steps towards entering into a contract with you. We will use your data in order to:

• Communicate with you before enrolment of a pupil, as part of the admissions’ process.
• Provide suitable provision and services for the pupil following admission.
• Deal with any feedback or concerns you may have.
• Manage Clubs & Wraparound Care activities.
• Provide educational services which may not be set out in our Agreement, but which are nevertheless a part of our academic and educational mission.
• Monitor and evaluate the performance and effectiveness of our School.
• Carry out research and statistical analysis.
• Maintain and improve the academic, corporate, financial, estate and human resource management of the School.
• Provide religious and pastoral care.
• Promote equality and diversity.
• Seek advice on our rights and obligations, for instance where we need our own legal advice.
• Recover monies owed to us.
• Fundraising purposes.
• To comply with our legal obligations, we may use your personal data in order to:
• Meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements.
• For the prevention and detection of crime.
• To assist with investigations, including criminal investigations carried out by the police and other competent authorities.

We may also process your personal data where:

• It is necessary for medical purposes (e.g., medical diagnosis, provision of health or social care or treatment, or a contract with a health professional.
• It is necessary to protect the vital interests of the pupil or another person.
• We have a legitimate business interest to do so.
• We have the specific or where required explicit consent of the data subject to do so.
• It is necessary for the safeguarding of children or individuals at risk.
• Where we believe there is a legitimate interest, we may also contact parents or pupils to promote our services on matters such as openings on waiting lists at sister schools, opportunities within the Parent Teacher Associations or friends of the School or for Alumni events and activities.

You may request to be excluded from data being processed in this way.

• We may ask for your consent to use your information in certain ways as an alternative to relying on any of the legal bases set out in this notice and in the UK GDPR. For example, with the aim to celebrate school’s achievements and to keep a record of the history of the student, we may take photographs and recorded images of students to be shared in, e.g., yearbooks, school website and or social networks etc, always based on informed consent from parents or students of legal age; The School may also share these images with Inspired Education Group under consent from parents or students of legal age.

Under your consent, we will send commercial communications. You will be able to unsubscribe from the receipt of such commercial communications by clicking in the “unsubscribe” section.

Any use of information before consent is withdrawn remains valid. Please contact our DPO (dpo@alphaplusgroup.co.uk)  if you would like to withdraw any consent that you have given.

5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In processing personal data and/or sensitive personal data, the school or college may have reason

to share personal data and/or sensitive personal data with a third party. Where this is required the

third party will have been assessed to ensure they have appropriate procedures in place to protect

the data, and only the data required to fulfil the specific purpose shall be passed.

Some of these circumstances are as follows:

• Disclosures connected with safeguarding and SEN support – e.g., local authorities, educational psychologist or speech therapist.
• School nurse (where the school nurse is not direct employed by the group).
• CAMHS (Child and Adolescent Mental Health Service).
• The Local Authority as and when required under education legislation.
• The Department for Education (DfE) as required under legislation.
• Other agencies or organisations when required under regulatory legislation only.
• Where a bursary or scholarship has been applied for with the funding organisation – such as the Gold Standard Charitable Trust.

• For international pupils with the Home Office where required.
• Catering and boarding suppliers – e.g., to ensure that allergies can be taken into account when preparing meals.

• IT suppliers – to allow the creation of accounts for various IT systems used within the group.
• Where we consider there to be a risk to yourself or others, we may share limited information both internally and with relevant third parties (e.g., ambulance, Police, NHS trusts etc) to ensure proper support is available.

• Examination boards/assessment centres.
• Exit/destination schools (including references).
• Where we have your consent, we may share data with marketing service providers for the purpose of creating marketing assets (e.g., brochures, promotional videos). Sensitive personal data will never be shared outside the Group without the explicit permission of the data subject other than under those conditions specified under Data Protection Law such as to protect the vital interests of the data subject, another person, or under law or court order.

6. INTERNATIONAL DATA TRANSFERS

In the event that for the execution of the educational agreement (which could include the use of IT tools and platforms offered from outside the EEA and United Kingdom) or for the management of student exchange programs, personal data need to be transferred to countries outside the EEA and United Kingdom, including third countries that do not guarantee an adequate level of protection, or in the event that you consent to the processing of your data by our parent company Inspired Education Holdings Ltd., (e.g., in the case of the use of your photograph) or the Inspired Education Group schools ( https://www.inspirededu.com/about-us/our-schools), we will ensure that they are carried out under the adequate guarantees and always adopting security measures recognised in international standards, such as standard contractual clauses or any other relevant complementary safeguards. In any case, Inspired Education Group guarantees the adoption of protocols aimed at guaranteeing the confidentiality of personal data.

7.  Conservation of data

Personal information will only be retained for the period of time required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be safely destroyed or made anonymous.

8. YOUR RIGHTS

Under the data protection regulations, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations.

You have the right to:

• Be informed, at the time when personal data is collected, about the data processing.
• Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
• Ask for the erasing of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
• Obtain the rectification of your personal data providing a supplementary statement;
• Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
• Obtain data portability of your personal information in a structured, commonly used and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
• Object to processing for direct marketing purposes;
• The right not to be subject to a decision based solely on automated processing;
• Withdraw your consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You can request the exercise of your rights by sending a written request, along with a copy of your ID card, to our Data Protection Officer’s email address: dpo@alphaplusgroup.co.uk.

9. MINORS

Our School will not collect and process, under any concept, data from individuals under 13 years old. Consent from parents or legal representatives will be always required.

1o. STORING AND SECURING INFORMATION

The School shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.

11.  COMMON USE WITH SOCIAL NETWORKS

This website contains links to parent’s portal and other educational platforms in addition to social networks as Instagram. Our School is not responsible for the privacy practices or the content of such sites. You should be aware that the processing of your personal information is carried out by those sites and governed by their respective privacy policies.

If you do not want these sites to collect and process your information, please review their corresponding privacy policies and / or disconnect from it before using our Services.

12. COOKIES USED IN OUR WEBSITE

We use cookies to provide you with a better experience in the use of our website, as well as to store information about our visitors. This information is related to your session ID and are a way of monitoring single user access.

The Web server is allowed to remember some data concerning the user, such as his preferences for visiting the pages of this server, name and password, products that are more interesting, etc.

The Cookies that we use in our website and that require informed consent by the user are the functional cookies and the targeting cookies. Consent is not required for required cookies, which are those of a technical nature necessary for the operation of the website or the provision of services expressly requested by the user.

13. COMPLAINTS

If you are not satisfied with our response, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Data Protection Officer at: dpo@alphaplusgroup.co.uk.

You also have the right to file a complaint before the Information Commissioner’s Office at: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/.

14. PRIVACY NOTICE UPDATES

We may need to update this privacy notice periodically, so we recommend that you review this information from time to time.

This version was last updated in October 2023