At Harington we are committed to protecting and respecting your privacy.
This policy explains when and why we collect personal information about Harington learners and their families and carers; the conditions under which we may disclose it to others; and how we keep it secure.
We may change this policy from time to time so please check occasionally to ensure that you’re happy with any changes.
Any questions regarding this policy and our privacy practices should be sent by email to info@harington.org.uk or by writing to: Harington, 55a Cholmeley Park, Highgate, London N6 5EH. Alternatively, you can telephone 020 3457 7997.
Policy sections:
How do we collect information from you?
What type of information is collected from you?
Who has access to your information?
How long do we keep your information?
How you can access and update your information
Security precautions in place to protect the loss, misuse or alteration of your information
Transferring your information outside of Europe
Where can you find out more information and who to contact
Who are we?
We are Harington, a local charity which provides training and education for young adults with learning disabilities and/or difficulties, helping them to prepare for future employment, further education and community life. Harington is a registered charity (no. 279376) and company limited by guarantee (no. 1467946). The registered address is 55a Cholmeley Park, Highgate, London N6 5EH.
The organisation includes The Harington Gardeners, our own garden maintenance company, and the Harington Charity Shops.
Statutory funds do not cover the full cost of our services; we rely on the generosity of individuals, companies and trusts who donate funds, and on our volunteers who give their time to support the charity.
How do we collect information from you?
We collect information about you as a learner, or as the parent or carer of a learner, when you make an application to Harington and during your time at Harington. This information is collected in person or through written correspondence.
What type of information is collected from you?
We collect, hold and share personal information about our learners and their families from previous schools, local authorities, health care professionals and the Department of Education (DfE). This includes:
· Personal information such as names, unique pupil/learner numbers and addresses
· Characteristics such as ethnicity, language, nationality, country of birth and free meal eligibility
· Safeguarding information such as court orders and professional involvement
· Attendance information such as sessions attended, number of absences and absence reasons
· Assessment information such as exam, support needs and other assessment results
· Relevant medical information such as health, allergies, medication and dietary requirements
· Information relating to Special Educational Needs and Disabilities (SEND) including Education, Health and Care Plans
· Behavioural information such as behaviour management plans, monitoring information and disciplinary action
How is your information used?
Harington will collect and use personal data relating to learners and their families and carers to:
· Support learning
· Safeguard learners
· Monitor and report on learner progress
· Provide appropriate pastoral care
· Assess the quality of our services
· Comply with the law regarding data sharing and data collection
· Produce Harington publicity material (with your consent)
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example safeguarding records or funding applications). We will hold your personal information on our systems only for as long as is necessary for the relevant activity.
Who has access to your information?
Your information will only be accessed by authorised Harington personnel for legitimate purposes. We will never sell your information to third parties or share it for marketing purposes.
Harington routinely shares relevant learner information with:
· Local authorities
· Funding agencies
· Relevant government agencies, including the Education and Skills Funding Agency (ESFA), the Learner Records Service and the Department for Education (DfE)
· Ofsted
· Qualification providers
· Future learning providers or e,mployers (with consent)
· Schools and colleges (where there is an alternative provision arrangement in place)
This data sharing is used to assess and monitor funding and attainment, meet statutory requirements, support 'joined up' planning and support, meet support needs or otherwise administer and co-ordinate your involvement with Harington.
Third Party Service Providers working on our behalf: We may store and process your information to our third party service providers (for example our email providers and database software) for the purposes of completing administrative tasks, for example to process applications or qualifications. When we use third party service providers, we disclose only the personal information that is necessary to process the task and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be assured that we will not release your information to third parties beyond Harington for them to use for their own purposes unless we are required to do so by law (for example, by a court order or for the purposes of prevention of fraud or other crime).
We may transfer your personal information to a third party if we are under a duty to disclose or share data in order to comply with any legal obligation, or to enforce or apply our terms of use, or to protect the rights, property or safety of our learners and their families and carers. However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
How long do we keep your information?
Personal data relating to learners and their families and carers is stored in line with Harington’s Data Protection Policy. Harington does not store personal data indefinitely; data is only stored for as long as is necessary to complete the task for which it was originally collected.
Your choices
Whilst the majority of the personal data you provide to Harington is mandatory, some is provided on a voluntary basis. When collecting data, Harington will inform you whether you are required to provide this data or if you have a choice in this. If we need your consent, Harington will provide you with clear and detailed information as to why the data is collected and how the data will be used.
Where Harington processes your data based on your consent, you have the right to withdraw this consent at any time by emailing: info@harington.org.uk or by calling 020 3457 7997.
If you have a concern about the way Harington and/or the DfE is collecting or using your personal data, you can raise a concern with the Information Commissioner’s Office: https://ico.org.uk/concerns/
How you can access and update your information
Under the General Data Protection Regulation 2018 you have the right to ask for a copy of the information Harington holds about you.
To make a request for your personal information, or be given access to your educational record, email: info@harington.org.uk, call us on 020 3457 7997 or write to us at: Harington, 55a Cholmeley Park, Highgate, London N6 5EH.
You also have the right to:
· Object to processing of personal data that is likely to cause, or is causing, damage or distress
· Prevent processing for the purpose of direct marketing
· Object to decisions being taken by automated means
· In certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
· Claim compensation for damages caused by a breach of the Data Protection regulations
If you have a concern about the way we are collecting or using your personal data please raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office: https://ico.org.uk/concerns/
If your contact details change, or if any of the other information we hold about you is inaccurate or out of date, please email us at: info@harington.org.uk, call us on 020 3457 7997 or write to us at: Harington, 55a Cholmeley Park, Highgate, London N6 5EH.
Security precautions in place to protect the loss, misuse or alteration of your information
Paper records that include your personal data are kept in a locked cabinet that is only accessible by authorised personnel.
Harington’s internal server/computer system is protected by a firewall and encryption. Harington uses a variety of IT systems, electronic storage systems and cloud services to manage and run its operations, for example the onsite server backup, Microsoft Office 365, Xero accounting and an online database/CRM system. Only services that meet GDPR requirements are used. All IT systems are password protected and only accessible by authorised personnel.
If we send emails to external agencies which include sensitive personal data, they will be encrypted.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
Transferring your information outside of Europe
Whilst it is avoided wherever possible, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if we use a mailing list service whose servers are located in a country outside of the EU. In these cases Harington will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
Where can you find out more information and who to contact
If you would like to find out more information about how Harington collects, uses and stores your personal data, please read our Data Protection Policy. To request a copy of the Policy please email us at: info@harington.org.uk, call us on 020 3457 7997 or write to us at: Harington, 55a Cholmeley Park, Highgate, London N6 5EH.
Review of this Policy
We keep this policy under regular review. This policy was last updated in May 2018.