Policies & Handbooks

Introduction

This policy sets out how the website available at www.culford.co.uk and www.culfordonline.co.uk  use cookies.

What is a cookie?

When we provide services we want to make them easy, useful and reliable. These services are delivered on the internet, which sometimes involves placing small amounts of information as files on your computer, mobile phone or other device. These small files are known as cookies. Certain cookies contain a limited amount of personal information. For example, if you click “remember me” when logging in, a cookie will store your username (which could be, for example, your email address). However, most cookies used on our Websites will not collect information that identifies you, and will instead collect more general information to help us analyse how well our Websites are performing so we can improve them:

• recognising that you may already have given a username and password so you don’t need to do it for every web page requested;
• measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure that they are fast;
• analysing anonymised data to help us understand how people interact with our services so that we can make them better.

How to Manage Cookies

• You can manage these small files and learn more about them from the article Internet Browser cookies- what they are and how to manage them.
• Learn how to remove cookies set on your device

There are two types of cookie you may encounter when using our websites:

First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.

Third party cookies: these are cookies found in other companies’ internet tools which we are using to enhance our site, for example Facebook or Twitter have their own cookies, which are controlled by them.

First party cookies

The Culford School website uses cookies in several places – we’ve listed each of them below with more details about why we use them and how long they will last.

NAME	PURPOSE	TYPICAL CONTENT	EXPIRES
ASP.NET_SessionId	Enables the server to recognise the user in their current browsing session.	Used to temporarily store non-sensitive data.	When the browsing session ends.
style	Used to remember the user's style preference.	Standard View, Print View, High Visibility	24 Hours

 

Third party cookies

We use suppliers who may also set cookies on their websites’ on its behalf. The Culford School website does not control the dissemination of these cookies. The Schools website uses Google Analytics and full information about their cookies can be found here. You should check the third party websites for more information about their cookies.

PROVIDER	NAME	PURPOSE	MORE INFO
AddThis	__atuvc	Enables the share count to update when a page is shared.	AddThis Privacy and Data Practices

 

We will not use cookies to collect personally identifiable information about you.

How to control and delete cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Websites.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including what cookies have been set and how to manage and delete them, visit www.aboutcookies.org  or www.allaboutcookies.org .

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Who We Are

Culford School, Bury St Edmunds, Suffolk, I28 6TX. Charity number 11426794

Culford is an Independent Boarding and Day School for pupils aged between 1 to 18 years and is part of the Methodist Independent Schools Trust.

Culford School is the controller and processor of data for Commercial activities; the Nursery, Sports and Tennis Centre, Senior, Preparatory and Pre Preparatory School .

What this Privacy Notice is for

This notice is intended to provide information about how the School will use (or "process") personal data about individuals including: its current, past and prospective pupils; and their parents, carers or guardians (referred to in this policy as "parents") its staff; governors, volunteers, commercial customers and service providers.

This information is provided because data protection laws give individuals the right to understand how their data is used. Parents, pupils, staff, governors, volunteers, commercial customers and service providers are all encouraged to read this Privacy Notice and understand the School’s obligations to its entire community.

This Privacy Notice applies alongside any other information Culford may provide about a particular use of personal data, for example when collecting data via an online or paper form.

This Privacy Notice also applies in addition to the School's other relevant terms and conditions and policies, including:

• any contract between the school and its employees , the parents of pupils and commercial relationships;
• the School's policy on taking, storing and using images of children;
• the School’s CCTV policy;
• the School’s retention of records policy;
• the School's safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
• the School's IT policies, including its Acceptable Use Policy and ICT Policy. Anyone who works for, or acts on behalf of, the school (including employees, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice and the school's data protection policy for employees, which also provides further information about how personal data about those individuals will be used. 

Responsibility for Data Protection

Culford School’s Data Protection Lead is the Compliance Officer who will deal with all your enquiries concerning the School’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this notice and Data Protection Law.

You can write to The Compliance Officer, Culford School, Culford, Bury St Edmunds, Suffolk, IP28 6TX or email Compliance@culford.co.uk.

Why the School needs to process personal data

In order to carry out its ordinary duties to employees, volunteers, pupils, parents, commercial customers and third parties (past and present and prospective), the School needs to process a wide range of personal data about individuals as part of its daily operation.

Some of this activity the School will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its employees, parents, pupils, commercial customers and third parties.

Other uses of personal data will be made in accordance with the School’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve sensitive or special category types of data.

The School expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:

• to maintain the relationship between pupil, parents (past, present and prospective) and the School by communicating through various platforms;
• for the purposes of pupil selection (and to confirm the identity of prospective pupils and their parents);
• to provide education services, including musical education, physical training, performance sports training or spiritual development, career services, and extra-curricular activities to pupils, and monitoring pupils' progress and educational needs;
• maintaining relationships with the school community and commercial customers by communicating through various platforms;
• for the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis);
• to enable relevant authorities to monitor the school's performance and to intervene or assist with incidents as appropriate;
• to give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils;
• to enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the school;
• to safeguard pupils' welfare and provide appropriate pastoral care;
• to monitor (as appropriate) use of the School's IT and communications systems in accordance with the School's ICT Policy.
• to make use of photographic images of pupils on School IT systems, in School publications, on the School website and (where appropriate) on the School's social media channels in accordance with the School's Images Policy on taking, storing and using images of children;
• for security purposes and to monitor sports pitches including the use of CCTV in accordance with the School’s CCTV policy;
• to enable the School to fulfil it legal obligations when recruiting employees, volunteers, contractors and third parties.
• to carry out or cooperate with any school or external complaints, disciplinary or investigation process; and
• where otherwise reasonably necessary for the School's purposes, including to obtain appropriate professional advice and insurance for the school.

In addition, the School will on occasion need to process sensitive or special category personal data (concerning health, ethnicity, religion or sexual life) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or by consent where required. These reasons will include:

• to safeguard pupils' welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition or other relevant information where it is in the individual's interests to do so: for example for medical advice, for social protection, safeguarding, and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs;
• to provide educational services in the context of any special educational needs of a pupil;
• to provide spiritual education in context of any religious beliefs;
• in connection with employment of its staff, for example DBS checks, welfare, union membership or pension plans;
• as part of any school or external complaints, disciplinary or investigation process that involves such data, for example if there are SEN, health or safeguarding elements; or
• for legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.

Types of Personal Data Processed by the School

This will include by way of example:

• names, addresses, telephone numbers, e-mail addresses and other contact details;
• car details (about those who use our car parking facilities);
• bank details and other financial information, e.g. about parents who pay fees to the school;
• past, present and prospective pupils' academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
• personnel files, including in connection with academics, employment or safeguarding;
• where appropriate, information about individuals' health and welfare, and contact details for their next of kin;
• references given or received by the School about pupils, and relevant information provided by previous educational establishments and/or other professionals or organisations working with pupils;
• correspondence with and concerning employee, pupils and parents past and present; and;
• images of pupils (and occasionally other individuals) engaging in school activities, and images captured by the School's CCTV system of any individual using the school grounds (in accordance with the School's CCTV Policy and Images Policy on taking, storing and using images of children)

How the School Collects Data

Generally, the School receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments).  Prospective parents may provide information via the School website, email and telephone.

However in some cases personal data will be supplied by third parties (for example another school, or other professionals or authorities working with that individual including agents); or collected from publicly available resources.

Who has access to Personal Data and who the School shares it with

Culford employees will have access to pupil, parent and third party information depending on their position and department within the school.

Occasionally, the School will need to share personal information relating to its community with third parties, such as:

• professional advisers such as lawyers, insurers, human resource advisers, accountants and health and safety consultants;
• government authorities such as HMRC, DfE, police or the local authority);
• appropriate regulatory bodies such as TRA, Independent Schools Inspectorate, Charity Commission,  Information Commissioners Office;
• travel operators for booking school trips; and
• Culford School Foundation, (see keeping in touch and supporting the School for more information) 

For the most part, personal data collected by the School will remain within the School, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis and with appropriate security measures). Particularly strict rules of access apply in the context of:

• medical records held and accessed only by the School Doctor and appropriate medical staff under his/her supervision, or otherwise in accordance with consent;
• School medical records held and accessed only by the School Medical Team or otherwise with consent;
• pastoral or safeguarding files;
• financial information of parents, employees and third parties.

However, a certain amount of any SEN pupil’s relevant information will need to be provided to employees more widely in the context of providing the necessary care and education that the pupil requires.

Employees, pupils and parents are reminded that the School is under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities such as the LADO or police. For further information about this, please view the School’s Safeguarding Policy.

Finally, in accordance with Data Protection Law, some of the School’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely, only in accordance with the School’s specific directions and in compliance with current data protection laws.

If you require further information about any of the School’s third party providers, please contact the Compliance Office.

How long we keep Personal Data

The School will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.

If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure or correction, please contact the Compliance Officer. However, please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such request.

A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").

If you require further information about the School’s retention of records, please contact the Compliance Officer.

Keeping in touch and supporting the School

The School will use the contact details of pupils, parents, alumni and other members of the School community to keep them updated about the activities of the School, Alumni and parent events or share them with Culford School Foundation.

Culford School Foundation is a registered charity and interacts worldwide with its community which includes: current and former students, also referred to as alumni, Old Culfordians or Old East Anglians; current and former parents; current and former staff, Governors and Trustees; and other friends of the School such as event sponsors, event attendees, charitable trusts or other relatives of former pupils and staff.

It’s aim is to build and maintain good relations across the Culford community, fostering support for a range of activities such as: university and careers networking, advice and support; connecting old friends and colleagues; organising reunions, social and sporting events; and fundraising, including for capital projects, such as those within The Campaign for Culford, and for the Culford Bursary Fund. The funds which the Foundation raises enables the School to develop and maintain its facilities as well as to offer financial support to those who could not otherwise afford to attend the School.

For further information Culford School Foundation’s management of personal information, please see the Culford School Foundation Privacy Notice

YOUR RIGHTS

Rights of access, rectification, erasure and portability 

You have various rights under Data Protection Law to access and understand how your personal data is managed by the School, and in some cases ask for it to be erased or amended or have it transferred to others, or for the School to stop processing it but subject to certain exemptions and limitations. 

Should you wish to access or amend your personal data, or wish it to be transferred to another person or organisation, or should you have some other objection to how your personal data is used, please write to the Compliance Officer.

 The School will respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).

The School will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the School may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).

Requests that cannot be fulfilled

You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations – please see further below), or information which is subject to legal privilege (for example legal advice given to or sought by the School, or documents prepared in connection with a legal action).

The School is also not required to disclose any pupil examination scripts (or other information consisting solely of pupil test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference given by the school itself for the purposes of the education, training or employment of any individual.

You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.

Pupil requests

Pupils can make subject access requests for their own personal data, provided that, in the reasonable opinion of the School, they have sufficient maturity to understand the request they are making (see section Whose Rights? below). A pupil of any age may ask a parent or other representative to make a subject access request on his/her behalf.

Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of younger pupils, the law still considers the information in question to be the child’s: for older pupils, the parent making the request may need to evidence their child's authority for the specific request. 

Pupils Senior School / aged 13 and above are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Slightly younger children / Older Prep School children may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.

Parental requests, etc.

It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about pupils without their consent. The School may consider there are lawful grounds for sharing with or without reference to that pupil.

Parents will in general receive educational and pastoral updates about their children, in accordance with the Parent Contract. Where parents are separated, the school will in most cases aim to provide the same information to each person with parental responsibility, but may need to factor in all the circumstances including the express wishes of the child.

All information requests from, on behalf of, or concerning pupils whether made under subject access or simply as an incidental request will therefore be considered on a case by case basis.

Consent

Where the school is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Examples where we do rely on consent are: e.g. certain types of uses of images. Please be aware however that the school may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.

That reason will usually have been asserted under this Privacy Notice, or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents' association has been requested).

Whose rights?

The rights under Data Protection Law belong to the individual to whom the data relates. However, the School will often rely on parental authority or notice for the necessary ways it processes personal data relating to pupils – for example, under the parent contract, or via a form. Parents and pupils should be aware that this is not necessarily the same as the School relying on consent (see section on Consent above).

Where consent is required, it may in some cases be necessary or appropriate, given the nature of the processing in question, and the pupil's age and understanding to seek the pupil's consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents’ rights at law or under their contract, and all the circumstances.

In general, the School will assume that pupils’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare. That is unless, in the School's opinion, there is a good reason to do otherwise.

However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the School may be under an obligation to maintain confidentiality unless, in the School's opinion, there is a good reason to do otherwise; for example where the School believes disclosure will be in the best interests of the pupil or other pupils, or if required by law.

Pupils are required to respect the personal data and privacy of others, and to comply with the School's IT Acceptable Use Policy and the school rules. Staff are under professional duties to do the same covered under the relevant staff policy.

DATA ACCURACY AND SECURITY 

The School will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.  Individuals must please notify the Housemistress/master, Tutor or Line Manager of any significant changes to important information, such as contact details, held about them.   

An individual has the right to request that any out of date, irrelevant or inaccurate information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the School may need to process your data, of who you may contact if you disagree.

The School will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training. 

THIS POLICY

The School 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.

QUERIES AND COMPLAINTS 

Any comments or queries on this policy should be directed to the Compliance Officer using the following contact details Compliance@culford.co.uk.

If an individual believes that the School has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school complaints / grievance procedure and should also notify the Compliance Officer. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator. 

December 2019 V1.1

Site Terms and Conditions of Use

Access and use of this website www.culford.co.uk  is provided on the following terms. By using the site you are agreeing to comply with and be bound by the following terms and conditions of use:

1. The content of this website is for general information and is subject to change without notice.
2. We do not provide any warranty or guarantee as to the accuracy, timeliness, completeness or suitability of the information and materials it contains for any particular purpose. For the avoidance of doubt, this includes materials accessed by links to websites operated by others. You should not, therefore, rely on any such information contained on either this site or others accessed from it.
3. You agree to use the Culford School website for lawful purposes only and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of it.
4. Access to the Culford website is on a temporary basis and we reserve the right to withdraw or amend the information it contains without notice. Culford School will not be liable if the website is not available for any reason.
5. Addresses of or links to other websites may appear on the site for your convenience to provide further information but we do not accept any responsibility or liability for the content of other websites. Any link should not be construed as an endorsement of any kind by Culford School. It is your responsibility to check the terms and conditions and privacy policy on any other website that you visit.
6. You may link to the Culford School website provided that it is done in a way that is fair and legal and that it does not damage Culford School’s reputation or any of its associated businesses’ reputations in any way. You must not establish a link in such a way to suggest that there is any approval or endorsement by Culford School where none exists.
7. This website and its content is copyright of Culford School © Culford School 2016. All rights reserved. Users do not have permission to capture and reproduce content or images without first seeking express written consent from Culford School.
8. Use of this website and any dispute arising out of such use is subject to the laws of England and Wales.
9. Please report any errors or inaccuracies to: communications@culford.co.uk
10. If you do not agree to these terms and conditions of use, please refrain from using the website.

Disclaimer

The information on this website is for general information purposes and is subject to change. While we aim to ensure that the information is up to date and correct, we make no representations or warranties of any kind about its completeness, accuracy and reliability or about the suitability or availability of any of the products, services or events which it describes.

We will not be liable for any loss or damage including without limitation arising from the use of this website or from any reliance on the material contained within it.

Viruses, Hacking and Computer Security

You must not misuse our site by deliberately introducing viruses, trojans, worms, malware or other material which is malicious or technically harmful. You must not attempt to gain unauthorised access to our site, the server on which our website is stored or any server, computer or database connected to our site.

We will report any such breach to the relevant law enforcement authorities. In the event of such a breach, your right to use our site ceases immediately.

We will not be liable for any loss or damage caused by any virus or other technologically harmful event that may adversely affect or infect your computer equipment, computer programmes, data or other proprietary material due to your use of our site or due to you downloading any material posted on it, or any website linked to it.

Internal Privacy Notice

In the course of your employment, engagement or other basis of work undertaken for the school, we will collect, use and hold (“process”) personal data relating to you as a member of our staff. This makes the school a data controller of your personal information, and this Privacy Notice sets out how we will use that information and what your rights are.

Who this document applies to

Academic and other staff, contractors, itinerant teachers, casual workers, temps and volunteers who may be employed or engaged by the school to work for it in any capacity, as well as prospective applicants for roles. It also applies to governors / trustees / directors.

This notice is not aimed at pupils, or parents of pupils (whether current, past or prospective) or other members of the public, nor does it inform staff how to handle the personal data of the same. This information may be found in the School’s Privacy Notice, which provides further details about how personal data will be used by the school,and the staff Data Protection Policy respectively.

About this document

This privacy notice explains how the school collects, uses and shares (or "processes") personal data of staff, and your rights in relation to the personal data we hold. 

This Privacy Notice also applies in addition to the school's other relevant terms and conditions and policies, including:

• any contract between the school and its staff, such as the terms and conditions of employment, and any applicable employment handbook. 
• the school’s CCTV and/or images policy;
• the school’s retention of records policy;
• the school's safeguarding, pastoral, anti-bullying, or health and safety policies, including as to how concerns or incidents are reported or recorded (both by and about staff); and 
• the school's IT policies, including its Acceptable Use policy. 

Please note that your contract with the school, including any document or policy forming a part of your contractual obligations to the school, may in particular be relevant to and supplement the information in this Internal Privacy Notice, to the extent that it will contain details of obligations or rights of the school under contract with you which may require the use of your personal data. However, this Internal Privacy Notice is the primary document applicable to the use of your personal data by the school. 

This Internal Privacy Notice also applies alongside any other information the school may provide about particular uses of personal data, for example when collecting data via an online or paper form.

How we collect your information

We may collect your personal data in a number of ways, for example:

• from the information you provide to us before making a job application, for example when you come for an interview;
• when you submit a formal application to work for us, and provide your personal data in application forms and covering letters, etc.; and
• from third parties, for example the Disclosure and Barring Service (DBS) and referees (including your previous or current employers or school), in order to verify details about you and/or your application to work for us.

More generally, during the course of your employment with us, as a member of staff, we will collect data from or about you, including:

• when you provide or update your contact details;
• when you or another member of staff completes paperwork regarding your performance appraisals;
• in the course of fulfilling your employment (or equivalent) duties more generally, including by filling reports or records, note taking, or sending emails on school systems;
• in various other ways as you interact with us during your time as a member of staff, and afterwards, where relevant, for the various purposes set out below.

The types of information we collect

We may collect the following types of personal data about you (and your family members and 'next of kin', where relevant):

• contact and communications information, including:
• your contact details (including email address(es), telephone numbers and postal address(es);
• contact details (through various means, as above) for your family members and 'next of kin', in which case you confirm that you have the right to pass this information to us for use by us in accordance with this Privacy Notice;
• records of communications and interactions we have had with you;
• biographical, educational and social information, including:
• your name, title, gender, nationality and date of birth;
• your image and likeness, including as captured in photographs or film recordings taken for work purposes;
• details of your education and references from your institutions of study;
• lifestyle information and social circumstances;
• your interests and extra-curricular activities;
• financial information, including:
• your bank account number(s), name(s) and sort code(s) (used for paying your salary and processing other payments);
• your tax status (including residence status);
• Gift Aid declaration information, where relevant (for example, where we help you to administer donations to charity from your pre-taxed earnings);
• information related to pensions, national insurance, or employee benefit schemes;
• work related information, including:
• details of your work history and references from your previous employer(s);
• your personal data captured in the work product(s), notes and correspondence you create while employed by or otherwise engaged to work for the school;
• details of your professional activities and interests;
• your involvement with and membership of sector bodies and professional associations;
• information about your employment and professional life after leaving the school, where relevant (for example, where you have asked us to keep in touch with you);
• and any other information relevant to your employment or other engagement to work for the school.

Where this is necessary for your employment or other engagement to work for us, we may also collect special categories of data, and information about criminal convictions and offences, including:

• information revealing your racial or ethnic origin;
• trade union membership, where applicable;
• information concerning your health and medical conditions (for example, where required to monitor and record sickness absences, dietary needs, or to make reasonable adjustments to your working conditions or environment);
• information concerning your sexual life or orientation (for example, in the course of investigating complaints made by you or others, for example concerning discrimination); and
• information about certain criminal convictions (for example, where this is necessary for due diligence purposes, or compliance with our legal and regulatory obligations);

However, this will only be undertaken where and to the extent it is necessary for a lawful purpose in connection with your employment or other engagement to work for the school.

The bases for processing your personal data, how that data is used and whom it is shared with

(i) Entering into, or fulfilling, our contract with you

We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, such as a contract of employment or other engagement with us. In this respect, we use your personal data for the following:

• administering job applications and, where relevant, offering you a role with us;
• carrying out due diligence checks on you, whether during the application process for a role with us or during your engagement with us, including by checking references in relation to your education and your employment history;
• once you are employed or engaged by us in any capacity, for the performance of the contract of employment (or other agreement) between you and us;
• to pay you and to administer benefits (including pensions) in connection with your employment or other engagement with us;
• monitoring your attendance and your performance in your work, including in performance appraisals;
• promoting the school to prospective parents and others, including by publishing the work product(s) you create while employed by or otherwise engaged to work for  the school;
• for disciplinary purposes, including conducting investigations where required;
• for other administrative purposes, for example to update you about changes to your terms and conditions of employment or engagement, or changes to your pension arrangements;
• for internal record-keeping, including the management of any staff feedback or complaints and incident reporting; and
• for any other reason or purpose set out in your employment or other contract with us.

(ii) Legitimate Interests  

We process your personal data because it is necessary for our (or sometimes a third party's) legitimate interests. Our "legitimate interests" include our interests in running the school in a professional, sustainable manner, in accordance with all relevant ethical, educational, charitable, legal and regulatory duties and requirements (whether or not connected directly to data protection law). In this respect, we use your personal data for the following:

• providing you with information about us and what it is like to work for us (where you have asked for this, most obviously before you have made a formal application to work for us);
• for security purposes, including by operating security cameras in various locations on the school's premises;
• to enable relevant authorities to monitor the school's performance and to intervene or assist with incidents as appropriate;
• to provide education services to pupils;
• to safeguard pupils' welfare and provide appropriate pastoral care;
• to carry out or cooperate with any school or external complaints, disciplinary or investigatory process;
• for the purposes of management planning and forecasting, research and statistical analysis;
• in connection with organising events and social engagements for staff;
• making travel arrangements on your behalf, where required;
• contacting you or your family members and 'next of kin' for business continuity purposes, to confirm your absence from work, etc.;
• publishing your image and likeness in connection with your employment or engagement with us;
• to monitor (as appropriate) use of the school's IT and communications systems in accordance with the school's IT: acceptable use policyand government guidance such as KCSIE. 

(iii) Legal Obligations

We also process your personal data for our compliance with our legal obligations, notably those in connection with employment, charity / company law, tax law and accounting, and child welfare. In this respect, we use your personal data for the following:

• to meet our legal obligations (for example, relating to child welfare, social protection, diversity, equality, and gender pay gap monitoring, employment, and health and safety);
• for tax and accounting purposes, including transferring personal data to HM Revenue and Customs to ensure that you have paid appropriate amounts of tax, and in respect of any Gift Aid claims, where relevant;
• for the prevention and detection of crime, and in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities. 

(iv) Special categories of data

We process special categories of personal data (such as data concerning health, religious beliefs, racial or ethnic origin, sexual orientation or union membership) or criminal convictions and allegations for the reasons set out below.

• We will process this data on the basis that such processing is necessary to carry out obligations and exercise rights (both yours and ours) in relation to your employment.
• In particular, we process the following types of special category personal data for the following reasons:
• your physical or mental health or condition(s) in order to record sick leave and take decisions about your fitness for work, or (in emergencies) act on any medical needs you may have;  
• recordingyour racial or ethnic origin in order to monitor our compliance with equal opportunities legislation; 
• trade union membership, in connection with your rights as an employee and our obligations as an employer;
• categories of your personal data which are relevant to investigating complaints made by you or others, for example concerning discrimination, bullying or harassment; 
• data about any criminal convictions or offences committed by you, for example when conducting criminal background checks with the DBS, or where it is necessary to record or report an allegation (including to police or other authorities, with or without reference to you); 
• We will process special categories of personal data for lawful reasons only, including because:
• you have given us your explicit consent to do so, in circumstances where consent is appropriate;
• it is necessary to protect your or another person's vital interests, for example, where you have a life-threatening accident or illness in the workplace and we have to process your personal data in order to ensure you receive appropriate medical attention;
• it is necessary for some function in the substantial public interest, including the safeguarding of children or vulnerable people, or as part of a process designed to protect others from malpractice, incompetence or unfitness in a role (or to establish the truth of any such allegations); or
• it is necessary for the establishment, exercise or defence of legal claims, such as where any person has brought a claim or serious complaint against us or you.

Sharing your information with others

For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. We may disclose limited personal data (including in limited cases special category or criminal data) to a variety of recipients including:

• other employees, agents and contractors (eg third parties processing data on our behalf as part of administering payroll services, the provision of benefits including pensions, IT etc. – although this is not sharing your data in a legal sense, as these are considered data processors on our behalf);
• DBS and other relevant authorities and agencies such as the Department for Education, NCTL, the ICO, Charity Commission and the local authority;
• external auditors or inspectors;
• our advisers where it is necessary for us to obtain their advice or assistance, including insurers, lawyers, accountants, or other external consultants;
• third parties and their advisers in the unlikely event that those third parties are acquiring or considering acquiring all or part of our school or trading trust, or we are reconstituting or setting up some ;
• when the school is legally required to do so (by a court order, government body, law enforcement agency or other authority of competent jurisdiction), for example HM Revenue and Customs or police.
• We may also share information about you with other employers in the form of a reference, where we consider it appropriate, or if we are required to do so in compliance with our legal obligations.

How long your information is kept

Personal data relating to unsuccessful job applicants is deleted within 3 months of the end of the application process, except where we have notified you we intend to keep it for longer (and you have not objected).

For employees, subject to any other notices that we may provide to you, we may retain your personal data for a period of 7 years after your contract of employment (or equivalent agreement) has expired or been terminated.

However, some information may be retained for longer than this, for example incident reports and safeguarding files, in accordance with specific legal requirements. Please see our Retention of Records policy.

Your rights

Please see our External Privacy Notice which has details of your rights as a 'data subject', which are the same as if you were any member for the public. You can find out more about your rights under applicable data protection legislation from the Information Commissioner’s Office website available at www.ico.org.uk. 

This notice

The school will update this Internal 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.

Contact and complaints

If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you should contact the School’s Compliance Officer compliance@culford.co.uk or raise the matter through the grievance procedure detailed in the employment handbook.

If you are not satisfied with how we are processing your personal data, or how we deal with your complaint, you can make a complaint to the Information Commissioner: www.ico.org.uk. The ICO does recommend you seek to resolve any issues with the data controller initially prior to any referral. 

Culford School Foundation’s Privacy Notice

Culford School Foundation exists to friendraise and fundraise for the School. We are committed to protecting your personal information, using it in accordance with data protection laws and not doing anything with your information that you would not reasonably expect.

This privacy notice explains how we collect and use your data and what you need to do if you would like to change the data we hold and how we use it.

What does the Culford Foundation do and why do we hold your data?

The Culford Foundation interacts worldwide with its community which includes: current and former students, also referred to as alumni, Old Culfordians or Old East Anglians; current and former parents; current and former staff, Governors and Trustees; and other friends of the School such as event sponsors, event attendees, charitable Trusts or other relatives of former pupils and staff.

Culford School is a registered charity, administered by the Methodist Independent Schools Trust.

The Foundation’s aim is to build and maintain good relations across the Culford community, fostering support for a range of activities such as: university and careers networking, advice and support; connecting old friends and colleagues; organising reunions, social and sporting events; and fundraising, including for capital projects, such as those within The Campaign for Culford, and for the Culford Bursary Fund. The funds which the Foundation raises enables the School to develop and maintain its facilities as well as to offer financial support to those who could not otherwise afford to attend the School.

To help us do this, the Culford School Foundation currently uses and maintains a relationship management database called the Raiser’s Edge to enable us to communication with all our stakeholders.

We also use Culford Online (NetCommunity) which is the online directory for alumni of Culford School and the East Anglian Schools and helps to support friendraising and fundraising by the Foundation. It enables registered users to engage with the Foundation by providing a password protected platform to create a personal profile that can be shared with other alumni, where the individual allows it. Culford Online may also be used: to make event bookings; pay for tickets and merchandise; to make gifts and donations; and access obituaries that are posted online. Communications preferences regarding the information you wish to receive from Culford Foundation can also be managed by the profile holder.

How we collect personal information

• Data on current pupils is transferred from the School database to the Foundation database after a pupil leaves.
• When you give information to us directly; whether in writing, online, face to face or over the telephone. For example when you sign up for an event, request a copy of the alumni magazine, make a donation, sponsor an event or activity, complete a leavers’ or other contact form or tell us your news, which could be for inclusion in our alumni communications and publications.
• When you register with Culford Online and input your own contact details which you can update at any time and is password protected.
• When you book an event through Culford Online.
• We may supplement information that you give us with publicly available data from elsewhere, such as from LinkedIn or other online media, news articles, magazines, books, directories or other published sources.

We do this so that we can (i) potentially connect current students and recent leavers with others in their field (ii) invite you to appropriate friendraising events; and (iii) ensure that any fundraising approach we may make is appropriate, tailored to your interests where possible and, we hope, will not cause you any offence.

We do not communicate directly with alumni under the age of 18 ie pupils who left Culford prior to completing Sixth Form. Pupils who leave at a younger age may be kept in touch, on request, via their parents or guardians until they reach 18 years of age.

What do we do with your data?

The personal data which the Culford School Foundation holds about you will only be used by Culford School Foundation for friendraising and fundraising purposes.

We use the contact details of the constituents on our database to send you information about the activities, events, future plans and fundraising appeals for the School, together with news from alumni and other relevant stakeholders. This includes updates and newsletters both by email and by post.

Most alumni records contain education, contact details and career information. Some may contain photographs of you while at School or attending an event for example. Contact with the School and donations are also recorded along with any sibling or other family links if known. In some cases other data may include contact information for partners as well as financial and other data you have disclosed to us or which we have derived from publicly available sources in order to maximise the School’s fundraising potential.

If you have registered with Culford Online, the Foundation uses your Culford Online personal information to communicate with you using your chosen methods about events, fundraising, current and former pupils and staff; and Culford School news. This may be via electronic communications or hard copy publications such as Hartley News and FOCuS.  

We may also use your address details to send you direct marketing information by post, telling you about friending and fundraising opportunities and events that we think may interest you.

In addition to disclosure as permitted or required by law, data may be disclosed on a considered and confidential basis to officers, governors, employees and/or staff of Culford School, MIST (Methodist Independent Schools Trust) and auditors or other official bodies e.g. The Charity Commission.

We may pass data to other organisations, known as Data Processors, who provide specific services such as printers, mailing houses, wealth screening services and fundraising consultants to the Culford School Foundation. They are required to delete or destroy all such information once they have completed the agreed activities carried out on our behalf. 

The Foundation does not retain any bank card information. Third party payment processors Global Payments is used for payments processed over the telephone or in person. Any payment details provided by you through Culford Online are securely processed directly by a third party provider Blackbaud Merchant Services.

We do not sell, share or swap information with any third parties for their own use and will not provide your contact information to other alumni or others without your consent.

Use of Images

We use school photographs to promote events and reunions, both upcoming and for those that have taken place, as well as for Throwback Thursday on Facebook, for example, and other similar nostalgic promotional activities on social media. We do our best to ensure that we are within copyright but owing to the age of some images and records it is not always possible to establish ownership.

If you have any concerns regarding the use of images, including any requests for images of you not to be published, please email: foundation@culford.co.uk

Protecting Your Data & Security

Culford Foundation’s relationship management database, the Raisers’ Edge and Culford Online (NetCommunity) is owned and hosted by Blackbaud on servers in the United States. Blackbaud, its subsidiaries and its affiliates are certified under the EU-U.S. Privacy Shield Framework which covers the collection, storage, transfer, use and other processing of Personal Data transferred from the European Union and Switzerland, respectively, to the United States.

All information is held and transmitted securely on our database.

Culford School and their third party suppliers are compliant with the PCI DSS Safer Payments programme when completing payment transactions.  For further information on PCI DSS Safer Payments Programme please visit https://www.pcisecuritystandards.org/pci_security/ .

Our Responsibilities: Basis for Processing

The law requires us to tell you the legal basis on which we process your data:

• Consent

In specific situations, we can collect and process your data with your consent for example, when you tick a box to receive email newsletters on Culford Online;

• Contractual obligations

In certain circumstances, we need your personal data to fulfill our contractual obligations to you for example, if you make payment through Culford Online to book an event or make a donation;

• Legal compliance

If the law requires us to, we may need to collect and process your data, for example; if you gift aid a donation, we are required to tell HMRC the name and postcode of the donor and the date and amount of the donation;

• Legitimate Interest

In all other cases we are processing your data based on your pre-existing relationship with Culford or the East Anglian Schools, which establishes a legitimate interest in our sharing with you news of developments at Culford, our fundraising programme generally, and the social and networking opportunities that we offer our community. It is on this basis that we hold and process the information that you or others have supplied to us, and use it in the manner set out in this Privacy Notice.

How long do we keep your data for?

We pride ourselves on offering a lifelong relationship with our alumni and former staff; many individuals remain in contact with us until they die. As relationships are often long term ones, we expect to maintain and update your data for as long as that relationship exists. You may ask us to cease contact at any time by contacting: foundation@culford.co.uk or telephone 00 44 1284 385310 or update your personal profile using Culford Online.

Data Control: Your Rights

You will receive our general news and information as described above, including about our events and our development and fundraising programmes, unless you ask us not to.

If you are registered with Culford Online, we will communicate with you based on your personal preferences chosen at registration. Culford Online allows you to update your personal information and communication preferences at any time.

You have the right to receive copies of the information we hold on you and, in some cases, to object to how we process it. If we do hold information about you, you can ask to correct any mistakes.

If you wish to make a Subject Access Request to find out if we hold any personal information, please contact the Compliance Officer at the address detailed below or email: compliance@culford.co.uk

If you have any queries, wish to restrict data processing or sharing, including use for fundraising or marketing of events or do not want to be contacted at all, please inform us:

Culford School Foundation, Culford School, Bury St Edmunds, Suffolk IP28 6TX

Tel: 00 44 (0)1284 385310                  Email: foundation@culford.co.uk

 

Please note, minimal information is always retained to make sure we do not contact you inadvertently. Our privacy notice and data protection policy are under constant review and any changes will be published on our website, via our email links and can be provided in hardcopy on request.

Compliance

 

If you believe we have not complied with this Privacy Notice or have acted otherwise than in accordance with current Data Protection Law, please direct your concerns or complaint to:

The Compliance Officer          Tel: 00 44 (0)1284 728615     Email: compliance@culford.co.uk

You may also refer the matter to the Information Commissioner’s Office (ICO) although the ICO recommends that steps are taken to resolve it directly with us, before involving them.

Updates & Changes to our Privacy Notice

This privacy notice and Culford Foundation’s policies are subject to regular review. 

Last updated May 2018

Employment applications, current and previous employees

Any information provided by you during the recruitment process will be used for the express purpose of processing your employment application, or to fulfil legal or regulatory requirements for recruitment and essential to assessing your suitability for employment within the School. We do not collect any information in excess of what is required and we do not retain it for longer than is necessary.  

You are not required to provide us with the information we ask for but it may influence your application if we do not have the information we require for a successful application to work in a School.

If you apply using our online application form you will be required to use our website. This information will be passed to the recruitment team who will shortlist applications for interview.

We may use the following recruitment agencies Pure, Compass Point, Reedand Hays. They collect information on our behalf which will be used to assess your suitability for the role. We post job vacancies using indeed and our school website. 

Any data generated from the interview process will be stored as part of your application process and will be retained for 3 months, but no longer than a year if unsuccessful or the duration of employment plus a minimum of 7 years.

An offer of employment will be conditional and we will ask you for information in order to carry out pre-employment checks. We are required to confirm your identity, your right to work in the United Kingdom, required safeguarding checks for working in education, your fitness to work via a health questionnaire and to seek assurances to your professional conduct, trustworthiness and reliability.

The School uses a third party service provider Atlantic Data Ltd. to carry out Disclosure and Barring Services Checks (DBS). This is only carried out with your express permission. It is a condition of employment that all employees have a successful DBS check.

All archived employment records are stored on a dedicated server in the UK. All current employment records are held in electronic and paper filing systems.

Please read our Internal Privacy Notice

 on how we collect and process your personal data during and after employment at the school.

Visitors to our website

The Culford website is hosted by Finalsite UK. When you visit www.culford.co.uk we use a third party service via Finalsite UK, Google Analytics to collect internet log information and details of visitors’ behaviours whilst using the website. Our marketing department use this information to understand the number of visitors to the website and which parts of the website attract the most use. If we wish to collect personally identifiable data through the website, we will make it clear this is what we are doing and we will explain what we intend to do with it.

E – Newsletters and Culford Post

The School communicates to Parents and Guardians via Culford Post which is hosted by Schoolpost. We use MailChimp and SurveyMonkey

We gather statistic about emails opened and number of clicks to help the school monitor and improve our communication platforms.

Individuals who contact us via social media

The school uses Instagram, Facebook, Twitter, LinkedIn and Google to build relationships with parents, pupils and friends of Culford School.

Please click on the links above for more information on their compliance to data protection laws.

Visitors to our website

The Culford website is hosted by Finalsite UK. When you visit www.culford.co.ukwe use a third party service via Finalsite UK, Google Analyticsto collect internet log information and details of visitors’ behaviours whilst using the website. Our marketing department use this information to understand the number of visitors to the website and which parts of the website attract the most use. If we wish to collect personally identifiable data through the website, we will make it clear this is what we are doing and we will explain what we intend to do with it.

Culford School CCTV Policy

The purpose of this policy is to regulate the management and operation of the Closed Circuit Television (CCTV) System Culford School (the School). It also serves as a notice and a guide to data subjects (including pupils, parents, employees, volunteers, governors, visitors to the School and members of the public) regarding their rights in relation to personal data recorded via the CCTV system (the System). 

The System is administered and managed by the School, who act as the Data Controller. This policy will be subject to review from time to time, and should be read with reference to the School's Data Protection Policy. For further guidance, please review the Information Commissioner's CCTV Code of Practice (accessible here link).

All fixed cameras are in plain sight on the School premises and the School does not routinely use CCTV for covert monitoring or monitoring of private property outside the School grounds. 

The School's purposes of using the CCTV system are set out below and, having fully considered the privacy rights of individuals, the School believes these purposes are all in its legitimate interests. Data captured for the purposes below will not be used for any commercial purpose.

Objectives of the System

• To protect pupils, staff, volunteers, visitors and members of the public with regard to their personal safety.
• To support the management of safeguarding on school grounds.
• To protect the school buildings and equipment, and the personal property of pupils, staff, volunteers, visitors and members of the public.
• To support the police and community in preventing and detecting crime, and assist in the identification and apprehension of offenders or vehicles.
• To provide evidence of damage or loss to the School’s insurance company.
• To monitor the security and integrity of the School site and deliveries and arrivals.
• To monitor staff and contractors when carrying out work duties.
• To monitor and uphold discipline among pupils in line with the schools handbooks,which are available to parents and pupils on the School website or on request.

Positioning

• Locations have been selected, both inside and out, that the School reasonably believes require monitoring to address the stated objectives.
• Adequate signage has been placed in prominent positions to inform staff and pupils that they are entering a monitored area.
• No images will be captured from areas in which individuals would have a heightened expectation of privacy, including changing and washroom facilities.
• No images of public spaces will be captured except to a limited extent at site entrances and around boarding and teaching buildings.

Maintenance 

• The CCTV System will be operational 24 hours a day, every day of the year. 
• The IT Manager will check and confirm that the System is properly recording and that cameras are functioning correctly, on a regular basis.
• The System will be checked and (to the extent necessary) serviced regularly.

​Supervision of the System

• Employees authorised by the School to conduct routine supervision of the System may include Caretakers, IT technicians, supervisors at the sports centre and relevant staff on duty.
• Images will be viewed and/or monitored in a suitably secure and private area to minimise the likelihood of or opportunity for access to unauthorised persons.

Storage of Data

• The day-to-day management of images will be the responsibility of the IT Manager, or such suitable person as the IT Manager shall appoint in their absence.
• Images will be stored for [e.g. 2-4 weeks], and automatically over-written unless the School considers it reasonably necessary for the pursuit of the objectives outlined above, or if lawfully required by an appropriate third party such as the police or local authority.
• Where such data is retained, it will be retained in accordance with the Act and our Data Protection Policy. Information including the date, time and length of the recording, as well as the locations covered and groups or individuals recorded will be recorded in the system log book.

Access to Images

• Access to stored CCTV images will only be given to authorised persons, under the supervision of the IT Manager, in pursuance of the above objectives (or if there is some other overriding and lawful reason to grant such access).  
• Individuals also have the right to access personal data the School holds on them (please see the Data Protection Policy), including information held on the System, if it has been kept. The School will require specific details including at least to time, date and camera location before it can properly respond to any such requests. This right is subject to certain exemptions from access, including in some circumstances where others are identifiable.
• The IT Manager must satisfy themselves of the identity of any person wishing to view stored images or access the system and the legitimacy of the request. The following are examples when the IT Manager may authorise access to CCTV images:
• Where required to do so by the Headmaster, the Police or some relevant statutory authority;
• To make a report regarding suspected criminal behaviour;
• To enable the Designated Safeguarding Lead or his/her appointed deputy to examine behaviour which may give rise to any reasonable safeguarding concern;
• To assist the School in establishing facts in cases of unacceptable pupil behaviour, in which case, the parents/guardian will be informed as part of the School’s management of a particular incident;
• To data subjects (or their legal representatives) pursuant to an access request under the Act; 
• To the School's insurance company where required in order to pursue a claim for loss or damage to insured property; or
• In any other circumstances required under law or regulation.
• Where images are disclosed as detailed  above a record will be made in the system log book including the person viewing the images, the time of access, the reason for viewing the images, the details of images viewed and a crime incident number (if applicable).
• Where images are provided to third parties under the above rights, wherever practicable steps will be taken to obscure images of non-relevant individuals.

Other CCTV systems

• The School does not own or manage third party CCTV systems, but may be provided by third parties with images of incidents where this in line with the objectives of the School's own CCTV policy and/or its school rules.
• Many pupils travel on coaches provided by third party contractors and a number of these coaches are equipped with CCTV systems. The School may use these in establishing facts in cases of unacceptable pupil behaviour, in which case the parents/guardian will be informed as part of the School’s management of a particular incident.
• The Tennis Performance Centre houses cameras recording pupil and coach training sessions, that are then steamed live onto an online streaming service. This allows parents to view their child’s training session from anywhere in the world.  Access to this service is restricted and regular access updates will occur to support the restricted access to the service. The school will ask for consent for pupils and or parents using this facility and signage is in place to make individuals aware of the recording taking place within the premises.  These recording are retained for no longer the 5 hours.

Complaints and queries

If you have any further questions about the School's CCTV system, or its use of CCTV, or requests for copies, should be referred to The Compliance Officer. Compliance@culford.co.uk

CCTV FOOTAGE ACCESS REQUEST

The following information is required before the school can provide copies of or access to CCTV footage from which a person believes they may be identified.

Please note that CCTV footage may contain the information of others that needs to be protected, and that the school typically deletes CCTV recordings after a two week period.

Name and address: (proof of ID may be required)
Description of footage (including a description of yourself, clothing, activity etc.)
Location of camera
Date of footage sought
Approximate time (give a range if necessary)

 

Signature*……………………………………

 

Print Name…………………………………….                Date ………………..

* NB if requesting CCTV footage of a child under 13, a person with parental responsibility should sign this form. For children 13 or over, the child's authority or consent must be obtained except in circumstances where that would clearly be inappropriate and the lawful reasons to provide to the parent(s) outweigh the privacy considerations of the child.

Taking, Storing and Using Images

This Policy 

This Policy is intended to provide information to pupils and their parents, carers or guardians (referred to in this policy as "parents"), employees, volunteers and Governors about how images of pupils are normally used by Culford School ("the school").  It also covers the school's approach to the use of cameras and filming equipment for educational and marketing purposes by employees, and at school events and on school premises by parents and pupils themselves, and the media. 

It applies in addition to the school's terms and conditions/parent contract, and any other information the school may provide about a particular use of pupil images, including e.g. signage about the use of CCTV; and more general information about the use of pupils' personal data, e.g. the school's Privacy Notice. Images of pupils in a safeguarding context are dealt with under the school's Safeguarding Policy.

General points to be aware of

Certain uses of images are necessary for the ordinary running of the school; other uses are in the legitimate interests of the school and its community and unlikely to cause any negative impact on children. The school is entitled lawfully to process such images and make decisions about how to use them, subject to any reasonable objections raised.

Parents who accept a place for their child at the school are invited to indicate agreement to the school using images of him/her as set out in this policy, by signing a consent form. However, parents should be aware of the fact that certain uses of their child's images may be necessary or unavoidable (for example if they are included incidentally in CCTV or a photograph).

We hope parents will feel able to support the school in using pupil images to celebrate the achievements of pupils, sporting and academic; to promote the work of the school, and for important administrative purposes such as identification and security. 

Any parent who wishes to limit the use of images of a pupil for whom they are responsible should contact the Communication department, marketing@culford.co.uk in writing. The School will respect the wishes of parents/carers (and indeed pupils themselves) wherever reasonably possible, and in accordance with this policy.

Parents should be aware that, from around the age of 13 and upwards, the law recognises pupils' own rights to have a say in how their personal information is used – including images.

Use of Pupil Images in School Publications and Online Streaming

Unless the relevant pupil or his or her parent has requested otherwise, the School will use images of its pupils to keep the school community updated on the activities of the school, and for marketing and promotional purposes, including:

• external internet streaming of live recordings of pupils and coaches during specified sports performance lessons. Viewing of these recording is restricted by the school to relevant pupils, parents and Culford employees;
• on internal displays (including clips of moving images) on digital and conventional notice boards within the school premises;  in communications with the school community (parents, pupils, staff, Governors and alumni) including by email, on the school intranet and by post; 
• on the school's website and, where appropriate, via the school's social media channels, e.g. Twitter, Instagram and Facebook. Such images would not normally be accompanied by the pupil's full name without permission; and
• in the school's prospectus, and in online, press and other external advertisements for the school.  Such external advertising would not normally include the pupil's names and in some circumstances, the school will seek the parent or pupil's specific consent, depending on the nature of the image or the use. 

The source of these images will predominantly be the school's staff (who are subject to policies and rules in how and when to take such images), or a professional photographer used for marketing and promotional purposes, or occasionally pupils. The school will only use images of pupils in suitable dress and the images will be stored securely and centrally. 

Use of Pupil Images for Identification and Security

All pupils are photographed on entering the school and, thereafter, when moving to the Prep or Senior School for the purposes of internal identification.  These photographs identify the pupil by name, year group, house and tutor group and are held on the school pupil management systems.

CCTV is in use on school premises, and will sometimes capture images of pupils. Images captured on the school's CCTV system are used in accordance with the School External and Internal Privacy Notice and CCTV Policy/ any other information or policies concerning CCTV which may be published by the school from time to time.

Use of Pupil Images in the Media 

Where practicably possible, the school will always notify parents in advance when the media is expected to attend an event or school activity in which school pupils are participating, and will make every reasonable effort to ensure that any pupil whose parent or carer has refused permission for images of that pupil, or themselves, to be made in these circumstances are not photographed or filmed by the media, nor such images provided for media purposes. 

The media often asks for the names of the relevant pupils to go alongside the images, and these will be provided where parents have been informed about the media's visit and either parent or pupil has consented as appropriate. 

Security of Pupil Images 

Professional photographers and the media are accompanied at all times by a member of staff when on school premises. The school uses only reputable professional photographers and makes every effort to ensure that any images of pupils are held by them securely, responsibly and in accordance with the school's instructions. 

The school takes appropriate technical and organisational security measures to ensure that images of pupils held by the school are kept securely on school systems and protected from loss or misuse. The school will take reasonable steps to ensure that members of staff only have access to images of pupils held by the school where it is necessary for them to do so. 

All staff are given guidance on the school's Images Policy on taking, storing and using images of pupils, and on the importance of ensuring that images of pupils are made and used responsibly, only for school purposes, and in accordance with school policies and the law. 

Use of Cameras and Filming Equipment (including mobile phones) by Parents 

Parents, guardians or close family members (hereafter, parents) are welcome to take photographs of (and where appropriate, film) their own children taking part in school events, subject to the following guidelines, which the school expects all parents to follow: 

• When an event is held indoors, such as a play or a concert, parents should be mindful of the need to use their cameras and filming devices with consideration and courtesy for cast members or performers on stage and the comfort of others. Flash photography can disturb others in the audience, or even cause distress for those with medical conditions; the school, therefore, asks that it is not used at indoor events.  
• Parents are asked not to take photographs of other pupils, except incidentally as part of a group shot, without the prior agreement of that pupil's parents. 
• Parents are reminded that such images are for personal use only. Images which may, expressly or not, identify other pupils should not be made accessible to others via the internet (for example on Facebook), or published in any other way.
• Parents are reminded that copyright issues may prevent the school from permitting the filming or recording of some plays and concerts.  The school will always print a reminder in the programme of events where issues of copyright apply. 
• Parents may not film or take photographs in changing rooms or backstage during school productions, nor in any other circumstances in which photography or filming may embarrass or upset pupils. 
• The school reserves the right to refuse or withdraw permission to film or take photographs (at a specific event or more generally), from any parent who does not follow these guidelines, or is otherwise reasonably felt to be making inappropriate images. 
• The school sometimes records plays and concerts professionally (or engages a professional photographer or film company to do so), in which case CD, DVD or digital copies may be made available to parents for purchase.  Parents of pupils taking part in such plays and concerts will be consulted if it is intended to make such recordings available more widely. 

 Use of Cameras and Filming Equipment by Pupils 

All pupils are encouraged to look after each other and to report any concerns about the misuse of technology, or any worrying issues to a member of the pastoral staff. 

The use of cameras or filming equipment (including on mobile phones) is not allowed in toilets, washing or changing areas, nor should photography or filming equipment be used by pupils in a manner that may offend or cause upset.  The material must be appropriate and not used in an inappropriate manner. Pupils must not take, use, share, publish or distribute images, video or sound of others without their permission. 

The misuse of images, cameras or filming equipment in a way that breaches this Policy, or the school's Anti-Bullying, Data Protection, IT Acceptable Use and, Safeguarding Policies is always taken seriously, and may be the subject of disciplinary procedures or dealt with under the relevant safeguarding policy as appropriate. 

Use of Cameras and Filming Equipment by Culford Employees, volunteers or governors

Employees are not permitted to use their own devices, such as mobile phones and cameras, to record pupils, this includes when on school trips. However, with the express permission of the Headmaster, images, video or sound can be taken provided they are transferred immediately and solely to the school’s network and deleted from the employee's device.

Colleagues should monitor other colleagues use of recording on their own devices and put protocols in place to ensure images have been removed from personal devices.