In respect of Wellington College Prep, TWC processes personal data about prospective, current and past: pupils and their parents (which includes guardians and carers as well as anyone with parental responsibility for that pupil); staff, volunteers and members of Wellington College Prep Council; suppliers and contractors; job applicants; persons hiring Wellington College Prep facilities for education related purposes; adults and children attending an educational course (residential or non-residential), conference or other activity or event organised or hosted by Wellington College Prep (whether sole organiser or in partnership with any other organisation) (collectively "educational events); adults and children attending events hosted at Wellington College Prep and which are not educational events; donors, friends and supporters; family members of any of the foregoing; families of members of staff living on site; those who visit Wellington College Prep for any reason; and others connected with Wellington College Prep.

The personal data we process takes different forms (it may be factual information, opinion, images or other recorded information) and the type of data processed will depend on your relationship with Wellington College Prep. Examples of the personal data we process include:

• names;
• addresses, telephone numbers, email addresses and other contact details;
• biometric information;
• past, present and prospective pupils’ admissions, academic, sport, co-curricular information, pastoral, health and any special needs information, attendance and disciplinary records and examination scripts and marks;
• education and employment information;
• in respect of those who access the Wellington College Prep site, images and video footage;
• financial information;
• courses, conferences, activities, events or meetings attended;
• car details and driving licence details; and
• correspondence with and concerning individuals.

We may also need to process special category personal data (for example, regarding physical or mental health, ethnicity, religion or biometric data) and criminal records information about some individuals (particularly staff).  Where we process this type of data, we will either rely on rights or duties imposed on us by law (for example, in respect of safeguarding, health and safety or employment) or on explicit consent. 

Most of the personal data processed by us is provided by the individual (or, in the case of pupils, by their parents or, in the case of children other than pupils attending educational events, their parents or school). This may be provided via a form or simply in the ordinary course of interaction or communication. However, some personal data is provided to us by third parties (for example, previous schools, referees, the Disclosure & Barring Service, professionals or authorities working with the individual) with the consent of the individual or from publicly available resources.

For the most part, personal data held by Wellington College Prep will remain within TWC and will be processed by appropriate members of staff for the purpose for which the data was collected. As an organisation, we have taken appropriate technical steps to protect your personal data and have implemented policies addressing use of technology. Particularly strict rules of access apply in the context of medical records and pastoral or safeguarding file although a certain amount of information will need to be disseminated more widely in order to provide the necessary care and education that the pupil requires (for example, details of any allergies).

Some of TWC’s and Wellington College Prep’s systems are provided by third parties with some being hosted by TWC and others externally. Those hosted internally include certain finance and administrative functions. Those hosted externally include Wellington College Prep’s website. The organisations providing these systems are aware of the requirements of current data protection legislation including, for example, our website provider that hosts the parent portal, and iSAMS that handles pupil and staff data.

In certain circumstances, we share personal data (including, where necessary, special category personal data) with third parties in order to further the objectives and interests of Wellington College Prep and TWC and facilitate the efficient operation of Wellington College Prep and TWC. Examples of the third parties with whom we share personal data are other schools within the Wellington College family (including Wellington College, schools within the Wellington Multi-Academy Trust and the international schools), TWC’s trading subsidiary, Wellington College Enterprises Limited, relevant authorities (such as the Local Children Safeguarding Board, DBS, NCTL, UKVI, HMRC, DfE, DWP, the Charity Commission, the Independent Schools Inspectorate, the Information Commissioner), the emergency services, examination boards, third parties who run or support academic, musical, sporting or co-curricular tuition, activities and training or school trips on behalf of or in conjunction with Wellington College Prep (for example travel operators), other schools, employers, visiting doctors, other delegates at educational events and TWC’s professional advisers.

We process personal data to support Wellington College Prep and TWC’s operations, objectives and interests.  This broad purpose encompasses the following:

• the selection and admission of pupils, including the awarding of scholarships and bursaries;
• the provision of education and related services to pupils (and their parents), including academic, sporting, musical and co-curricular tuition, training and activities (and in the context of any special educational needs of a pupil), personal and spiritual development, school trips, participation in exams, administration of the school curriculum and timetable, monitoring pupil progress and needs, reporting on the same internally and to parents, provision of references and career services (including after a pupil has left Eagle House);
• the provision of wraparound and holiday childcare services to pupils, including the direct marketing, promotion, administration, monitoring, development and performance of such services.
• the safeguarding of pupil’s welfare and provision of pastoral and medical care, whether by their tutor, house master, matron or other member of the teaching or non-teaching staff;
• the selection for, the provision of education and related services, the safeguarding of welfare and provision of pastoral and medical care to those children attending educational events where the arrangement has been entered into between the parent of that child and Wellington College Prep;
• compliance with legislation and regulation, including that relating to safeguarding, health and safety, employment, charities and independent schools;
• operational management including the compilation of pupil records, the administration of invoices, fees and accounts, the management of TWC’s property, the management of security and safety arrangements (including the monitoring of Wellington College Prep’s IT and communication systems in accordance with our Code of Conduct for ICT Use) management planning and forecasting, research and statistical analysis, the administration and implementation of Wellington College Prep’s rules and policies for pupils, staff and others, the maintenance of historic archives, enabling the relevant authorities to monitor TWC’s and Wellington College Prep’s performance, and other operational purposes;
• staff administration, including the recruitment of staff, governors and other volunteers and engagement of contractors (including compliance with DBS procedures), administration of payroll, pensions, sick leave and other benefits, review and appraisal of performance, conduct of any grievance, capability or disciplinary procedures, the maintenance of appropriate human resources records for current and former staff and providing references;
• the promotion of TWC, Wellington College Prep and activities organised by it including through its own website, the prospectus and other publications and communications and including by publishing the results of public examinations or other achievements of pupils of Wellington College Prep or using photographic images of pupils in Wellington College Prep publications, on any Wellington College Prep website and, where appropriate, on Wellington College Prep social media channels;
• maintaining relationships with alumni and the wider community, including direct marketing or fundraising activity;
• conducting appropriate donor due diligence, including confirming the identity of any prospective donor and carrying out any background checks considered necessary;
• provision of educational events, including the direct marketing, promotion, administration, monitoring, development and performance of such educational events and maintenance of relationships with former attendees;
• obtaining appropriate professional advice and insurance for TWC; and
• where specifically requested by the individuals concerned.

In some situations, we have to carry out these processes in order to meet our legal obligations, whether they are imposed on us by law or through contract (such as the Terms & Conditions), staff employment contracts or Booking Terms & Conditions.  In other situations, we have obtained the consent of the relevant individual to the particular processing of the data. Wellington College Prep has determined that it has a legitimate interest in all of the remaining processes it conducts. 

Personal data will be kept securely and for no longer than is necessary or required by law. As this period will vary depending on the piece of personal data and the purpose for which it was collected, Wellington College Prep has implemented a retention programme which details the time periods for each different category. If you have any specific questions in respect of retention, please direct them in the first instance to [email protected] and, if any further information is required, to the TWC’s Legal & Compliance Director by email at [email protected] . 

Archive

It should be noted that records considered by Wellington College Prep to be of historic value are retained in Wellington College Prep’s archive indefinitely.  Personal data in the archive relating to the living individuals which is not otherwise in the public domain is not shared with third parties without that individuals’ consent.

If TWC processes personal data about you, you have a number of rights in respect of that data. Subject to certain exemptions and limitations specified by law, you can:

• require TWC to change incorrect or incomplete data;
• require TWC to delete your data;
• withdraw your consent to TWC processing certain personal data where TWC is relying on your consent to do so;
• object to TWC processing your data where we are relying on our legitimate interests to do so;
• require TWC to transfer your personal data to another organisation; or
• access and obtain a copy of your data on request.

If you would like to exercise any of these rights, please contact [email protected] in the first instance and, if any further information is required TWC’s Legal & Compliance Director by email at [email protected]  or by post at The Bursary, Wellington College, Duke’s Ride, Crowthorne, RG45 7PU.  We will respond to such written requests as soon as is reasonably practicable and in any event within the time limits permitted by law. Wellington College Prep will be better able to respond quickly to smaller, targeted requests for information. 

Data relating to children

Rights in respect of personal data belong to the individual to whom the data relates. However, in respect of children, TWC will often rely on parental authority or notice to process personal data (if consent is required) unless TWC considers that, given the age and understanding of the child and the type of processing, it is more appropriate to rely on the child’s consent. Parents should be aware that whether they are consulted or not will depend upon the interests of the child, the parents’ rights and all other circumstances.

In general, TWC will assume that a child’s consent is not required before ordinary disclosure of their personal data to their parents (for example, to keep parents informed of their child’s progress, behaviour and activities or in the interests of the child's welfare) unless TWC considers that there is a good reason to do otherwise.

However, if a child seeks to raise concerns confidentially with a member of staff and expressly withholds their consent to their personal data being disclosed to their parents, TWC may be obliged to keep the information confidential unless TWC  considers that there is a good reason to do otherwise. 

Children can make a subject access request for their own personal data if they have sufficient maturity to understand the request they are making. Pupils at Wellington College Prep are generally assumed not to have this level of maturity.  A child may ask a parent or other representative to make a request on their behalf. Whilst a parent will generally be entitled to make a subject access request on behalf their child, the personal data will always be considered to be the child’s at law and, if of sufficient maturity, that child’s consent or authority may be required to be obtained by the parent making the request. All information requests from, on behalf of or concerning children – whether made under subject access or simply as an incidental request – will therefore be considered on a case by case basis. 

Wellington College Prep will update this notice from time to time. Any substantial changes that affect your rights will be notified on our website and, as far as reasonably practicable, notified to you.

If you believe that TWC or Wellington College Prep has not complied with this notice or acted other than in accordance with data protection laws, you should notify TWC’s Legal & Compliance Director. 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 TWC and/or Wellington College Prep before involving the regulator.

May 2018