Leamore Primary School collects and processes personal data relating to its employees in order to manage our employment relationship with you. We are committed to being transparent about how we collect and use your personal data and how we meet our data protection obligations.

Leamore Primary School may operate as either a Data Processor or Data Controller (or both) under data protection legislation. We comply with the General Data Protection Regulations (GDPR) principles when gathering and using personal information as set out in the school policies and procedures.

What personal data does the school collect?

Leamore Primary School collects, processes and retains a range of information about you.

This can be classed as either Personal Data or special category (sensitive) Personal Data and includes information such as:

• Your name, address and contact details including email address and telephone number
• Your date of birth
• Your gender  
• The terms and conditions of your employment
• Details of your qualifications, skills, experience and employment history, including start and end dates with previous employers and/or with Leamore Primary School
• Information about your remuneration, including entitlement to benefits such as pensions and/or any allowances that may apply.
• Your bank account details  
• Your national insurance number
• Information about your marital status and emergency contacts
• Information about your nationality and your right to work in the UK
• Where necessary, information about your criminal record, if you have one
• Details of the dates and times when you work, your working hours and  attendance/non attendance at work  
• Details of and reasons for absence and/or leave taken by you for example, annual leave, flexi time, sickness, bereavement, paternity, maternity, shared parental, emergency, family, study, career break etc
• Details of when you are or have been managed in line with a policy or procedure for example disciplinary, grievance, sickness absence, performance and ill health capacity. The information held may include details of meetings, discussions, correspondence, warnings, remedies, management action and/or other recommendations. Details in relation to assessment of your performance, appraisals, performance reviews and ratings, improvement plans and other related correspondence may also be held.
• Information about medical or health conditions, sickness absence management, occupational health referrals and details of a disability if disclosed, for which the school may need to make reasonable adjustments
• Equality and diversity monitoring information, for example information about your ethnic origin, sexual orientation and religion or belief

Leamore Primary School collects this information in a variety of ways. For example, data might be collected from application forms; obtained from personal documents such as your passport or driving licence; from forms completed by you at the start of or during employment; from correspondence with you; or from interviews, meetings or other assessments.

We may also collect information from you in the course of your employment for;

• Learning and Development opportunities for course bookings, issue of certificates, confirmation of successessful/unsuccessful completion and/or attendance.

• Health and Safety management, reporting and/or investigating an accident or incident

• Management in line with the school’s Policies and/or Procedures

• Payroll and Pension requirements

Leamore Primary School may also collect personal data about you from third parties for example, when collecting employment references, carrying out employment background checks with providers such as (but not limited to) the Disclosure and Barring Service (where lawfully permitted).

Where will your personal data be stored?

Your personal data may be stored in a range of different locations.

The school holds information related to you and your employment in the school  electronic ICT systems;

The school also retains information, in some instances, in a paper based (manual) format both “on” and “off” site.

All data, information and records are managed in line with the schools records management procedures and retention schedules.

Why does Leamore Primary School process your personal data?

Leamore Primary School needs to process personal data to enter into and maintain our employment contract with you. For example, the school needs to process your personal data to provide you with an employment contract, to pay you, to make lawful deductions and administer benefit and pension entitlements. This complies with Article 6 (b) of the GDPR.

Processing and recording personal data allows us to:

• Manage our employment relationship with you in line with the terms and conditions of employment and the schools policies and procedures.

• Carry out recruitment and selection.
• Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency as provided by you), and details of your occupational and statutory benefits and rights.
• Manage disciplinary and grievance cases in line with our procedures and ensure acceptable conduct within the workplace.
• Manage performance in line with our procedures, develop improvement plans, identify training needs, plan for career development and succession plan  
• Manage absence and other leave in line with our procedures so you are appropriately supported and receive pay (if applicable) and or any other benefits to which you are entitled.
• Manage resources and workforce planning activities.
• Make referrals and obtain occupational health advice, ensure that we comply with our duties as an employer, operate in line with Equality legislation and meet our obligations under Health and Safety Legislation.
• Ensure the schools workforce is managed effectively and appropriately.
• Carry out Human Resourcing activities including all associated administration.
• Provide references on request for current or former employees.
• Respond to and defend against legal and other claims.

We may also process your information to meet statutory and/or legal requirements in accordance Article 6 (c) of the GDPR that are in line with but not limited to:

• The Equality Act (2010).
• The Public Sector Equality Duty 2011.
• Health and Safety at Work etc Act 1974.
• The Human Rights Act 1998
• Trade Union and Labour Relations (consolidation) Act 1992
• Rehabilitation of Offenders Act 1974 (exceptions) order 1975
• The Protection of Freedoms Act 2012
• The Safeguarding Vulnerable Groups 2006 Act
• The Police Act 1997
• Employment Rights Act 1996
• The Public Interest Disclosure Act 1998
• Transfer of Undertakings (Protection of Employment) Regulations 2006 as amended by the Collective Redundancies and Transfer of Undertakings (Protection of Employment) (Amendment) Regulations 2014

Some special categories of personal data (sensitive) such as information about health or medical conditions are processed for the purposes of carrying out our obligations and exercising specific rights in the field of employment law in accordance with Article 9 (b).

The school also processes other special categories of personal data (sensitive) such as information about ethnic origin, sexual orientation or religion or belief for the purposes of equal opportunities monitoring. The school is legally required to monitor this data. We collect this data with your explicit consent, which can be withdrawn at any time. When we use this data for monitoring purposes it is anonymised. You are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Who has access to your personal data?

Your employment information including personal and or special category data will be accessed by those who have an authorised, justified and or legal basis to do so.

Your information may be shared internally with authorised officers of the Council. They may include, but is not limited to, your Line Manager, Senior Managers and Human Resources Officers.

Information may be accessed for the purpose of:

• Employment
• Management
• Education
• Pensions
• Union membership
• Health and Social care such as occupational health

Leamore Primary School may also share your personal data, as required, with third parties in order to;  

• Fulfil the requirements of a contract
• Meet a statutory requirement.
• Manage the HR and payroll functions. We share personal information with HMRC, West Midlands Pensions Fund, Teachers Pensions, NHS Pensions, Equitable Life, Prudential, and the Pensions Regulator in line with our statutory obligations and in order to administer your employment records.
• Manage the recruitment process including obtaining pre-employment references from other employers, obtaining where necessary, and employment background checks from third-party providers and in some circumstances obtain a criminal records check from the Disclosure and Barring Service.
• Provide occupational health support and make referrals  
• Provide access to external IT systems.
• Provide access to training providers

How does Leamore Primary School protect your personal data?

Leamore Primary School takes the security of your personal data seriously. The school has

Internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and are not accessed except by authorised individuals.

Some of the ways in which Leamore Primary School protects your personal data include:

1. Implementing appropriate technical and organisational measures to protect the confidentiality, integrity and availability of personal data and information
2. On-going continuous review of security
3. Regular review of schools information assurance and security policies and procedures
4. On-going training and awareness for staff on information assurance and security
5. Alignment with codes of conduct, certification schemes and government guidance, including the HMG Security Policy Framework, government baseline security standards, , and the National Cyber Security Centre (NCSC)
6. Ensure that all suppliers and third party organisations undertaking work for or on behalf of the school are able to evidence full compliance with the GDPR and the schools data security protocols and that these considerations are made when procuring new services
7. Regular review of security and cyber risks

Where Leamore Primary School engages third parties to process personal data on its behalf, they do so under contract and on the basis of written instructions.

Third parties are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data and comply with data protection legislation.

How long does Leamore Primary School keep your personal data for?

Leamore Primary School will hold your personal data for the duration of your employment. The periods for which your data is held is specifically set out in the schools retention schedule.

Your rights

You have the following rights with regard to your personal information:

Right to be informed – You have the right to know the following:

• what information we intend to collect,
• why we need your information,
• the lawful basis under which we can process your information,
• how we will process your information,
• whether we share your information,
• who we might share your information with,
• your rights until the law,
• How long we will retain your information and how you can contact us.

This Privacy Notice should have detailed all of the above but if for any reason you are dissatisfied with our stewardship of your information, you have the right to lodge a complaint with the Information Commissioners Office (ICO), contact details are provided below.

Access to your information – If you would like to know what information we hold and process about you, the category of information, who we share your information with, to ascertain the accuracy of the information and the criteria we apply in processing your information, you can make a request to us in writing.

To make a subject access request and receive a copy of your personal information, contact;

Mrs Joy Barker, School Business Manager, Leamore Primary School.

Please be aware we will need you to provide appropriate identification but you can find details of this and everything else about our Subject Access Request process on our website.

We should respond to your request within 1 month of receipt but if the request is complex and more time is required we will inform you in writing.

Rectification of your information – If it is established that information we hold about you is incorrect, you have the right to request that we correct this information.

Erasure of your information – In cases where the information we hold about you is no longer required in relation to the purpose for which it was collected and where there are no lawful grounds for holding your information, you can request that this information be erased.  

The Right to Restrict processing –You can restrict us from using your information if you believe the data is inaccurate or if there are no lawful grounds for using the information but you do not want us to delete the information. In addition you can prevent us from deleting information we no longer use or need if you require it for a legal claim or defence.

Following investigation, if it is determined that the right to restrict processing should not apply the school will inform you of reasons for this before the restriction is lifted.

Right to Data Portability (only include if lawful basis for processing is performance of a contract or consent) you have the right to request that information we hold about you be transferred to another school or other controller. Your data portability request will have to be made in writing; we will assess your request in accordance with the provisions of the GDPR to ascertain if your request is covered under the law. Our response will contain our decision regarding the viability of your request and asking you to choose between the following:

• If you want the information handed to you.
• If you would like the information transferred directly to the public authority or other controller.

The school’s Data Protection Officer (DPO) is Paul Withers. If you have any questions about your rights under the GDPR, how the school uses your information, or you wish to make a complaint about how we have processed or utilised your data, Paul will be able to help.

How to contact our DPO:

Contact Address:

Office of the DPO

Resources & Transformation
Civic Centre 3rd Floor (HR Suite)

Walsall Council

Darwall Street

Walsall

WS1 1TP

Email Address: InformationMgmt@walsall.gov.uk

Contact Telephone Number:01922 650970

Should you be dissatisfied with the response you receive, you can contact the Information Commissioner’s Office (ICO) with the details given below:

ICO

Address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Email Address:

Use the online form via this link https://ico.org.uk/global/contact-us/email/

Telephone Numbers:

Calling from within the UK 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate.

Calling from outside the UK +44 1625 545 745