Privacy Policy
Date last reviewed May 2025
Date of next review May 2026
Committee approved by Finance & General Purposes
Review period 1 year
WHO WE ARE
We, Kent College, Canterbury, Whitstable Road, Canterbury, CT2 9DT, a part of
MIST, Registered Charity Number: 1142794, are a Data Controller for the purposes of
the Data Protection Act. We collect information from you and may receive information
about you from previous schools. When referring to “Kent College, Canterbury” or “The
School” we are including Garden Cottage Nursery, Kent College Junior School and
Kent College Senior School.
WHAT THIS PRIVACY NOTICE IS FOR
This policy is intended to provide information about how the school will use (or
"process") personal data about individuals including: its staff; its current, past and
prospective pupils; and their parents, carers or guardians (referred to in this policy as
"parents").
This information is provided because Data Protection Law gives individuals rights to
understand how their data is used. Staff, parents and pupils 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 the school 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 staff or the parents of pupils;
● the school's policy on taking, storing and using images of children;
● the school’s CCTV and biometrics policy;
● the school’s retention of records policy;
● the school's safeguarding, pastoral, and 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 Online Safety
policy.
Anyone who works for, or acts on behalf of, the school (including staff, volunteers,
governors and service providers) should also be aware of and comply with this Privacy
Notice and the school's data protection policy for staff, which also provides further
information about how personal data about those individuals will be used.
RESPONSIBILITY FOR DATA PROTECTION
● The School has appointed the Bursar as Data Protection Lead and endeavour
to ensure that all personal data is processed in compliance with this policy and
Data Protection Law. They can be contacted on [email protected]
WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, pupils and parents, the school needs
to process a wide range of personal data about individuals (including current, past and
prospective staff, pupils or parents) 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 staff, or parents of its
pupils.
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 special or sensitive types
of data.
The school expects that the following uses will fall within that category of its (or its
community’s) “legitimate interests”:
● 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 or
spiritual development, career services, and extra-curricular activities to pupils,
and monitoring pupils' progress and educational needs;
● Maintaining relationships with alumni and the school community, including
direct marketing or fundraising activity;
● For the purposes of donor due diligence, and to confirm the identity of
prospective donors and their background and relevant interests;
● 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 IT: acceptable use policy;
● To make use of photographic images of pupils in school publications, on the
school website and (where appropriate) on the school's social media channels
in accordance with the school's policy on taking, storing and using images of
children;
● For security purposes, including biometrics and CCTV in accordance with the
school’s biometrics and CCTV policy;
● To carry out or cooperate with any other 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 special category personal
data (concerning health, ethnicity, religion, biometrics 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
from time to time by explicit 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 co-operation with police or social services,
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 the context of any religious beliefs;
● In connection with employment of its staff, for example DBS checks, welfare,
Union membership or pension plans;
● To run any of its systems that operate on biometric data, such as for security
and other forms of pupil identification (purchases or printing.);
● 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, email addresses and other contact
details;
● car details (about those who use our car parking facilities);
● biometric information, which will be collected and used by the school in
accordance with the school's biometrics policy.
● 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 staff, 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 (in accordance
with the school's 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).
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)
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT
WITH
Occasionally, the school will need to share personal information relating to its
community with third parties, such as
● professional advisers e.g. lawyers, accountants, insurers, PR advisors and
government authorities e.g. HMRC, D of E, police or the local authority
● The Friends of Kent College and The Old Canterburians (alumni)
● appropriate regulatory bodies e.g. the Independent Schools Inspectorate, the
Charity Commision, National College of Teaching and Learning, Department
for Education and the Independent Schools Council
For the most part, personal data collected by the school will remain within the school
and its associated systems. It will always be processed by appropriate individuals
only in accordance with access protocols (i.e. on a ‘need to know’ basis). 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
express consent; and
● pastoral or safeguarding files.
However, a certain amount of any SEN pupils’ relevant information will need to be
provided to staff more widely in the context of providing the necessary care and
education that the pupil requires.
Staff, pupils and parents are reminded that the school is under duties imposed by law
and statutory guidance (including fro 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 and only in accordance with the school’s specific
directions.
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. Typically, the legal
recommendation for how long to keep ordinary staff and pupil personnel files is up to
7 years following departure from the school. However, 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, please contact the Bursar on [email protected].
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 a request.
A limited and reasonable amount of information will be kept for archiving purposes, for
example and even where you have requested you 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”).
KEEPING IN TOUCH AND SUPPORTING THE SCHOOL
The school and/or any relevant other organisation will use the contact details of
parents, alumni and other members of the school community to keep them updated
about the activities of the school, or alumni and parent events of interest, including by
sending updates and newsletters, by email and by post. Unless the relevant individual
objects, the school will also:
● Share personal data about parents and/or alumni, as appropriate, with
organisations set up to help establish and maintain relationships with the school
community, such as the Friends of Kent College, The Old Canterburians
Association and MIST (Methodist Independent Schools Trust);
● Contact parents and/or alumni (including via the organisations above) by post
and email in order to promote and raise funds for the school and, where
appropriate, other worthy causes;
● Should you wish to limit or object to any such use, or would like further
information about them, please contact the Bursar in writing. You always have
the right to withdraw consent, where given, or otherwise object to direct
marketing or fundraising. However, the school is nonetheless likely to retain
some of your details (not least to ensure that no more communications are sent
to that particular address, email or telephone number).
YOUR RIGHTS
Rights of Access
Individuals have various rights under Data Protection Law to access and understand
personal data about them held 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.
Any individual wishing to access or amend their personal data, or wishing it to be
transferred to another person or organisation, or who has some other objection to how
their personal data is used, should put their request in writing to the Bursar.
The school will endeavour to 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
you (or your child's) personal data: for example, legal requirement, or where it falls
within a legitimate interest identified in the Privacy Notice. All such requests will be
considered on their own merit.
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 e.g. 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 / Junior
School children may however be sufficiently mature to have a say in this decision,
depending on the child and their circumstances.
Parental Requests
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 biometrics, certain types of use
of images and certain types of fund-raising activity. Please be aware however that the
school may 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 relying on strict 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 policies, e.g. IT: Acceptable Use Policy and the School rules. Staff
are under professional duties to do the same covered under the relevant staff policies
and Staff Code of Conduct.
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
relevant person 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, or 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 NOTICE
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 Bursar using the
following contact details: [email protected]
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 Bursar. 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.