When you or your child registers to become a WNAT pupil, we will need to collect Personal Information from you to enable us to provide our services. This information is often provided directly by you or your parents, guardians or carers and includes Personal Information such as your name, age, address, home telephone number and other information we need to contact you. We may also need to collect information relating to your first language, ethnic and religious background, your nationality at birth and if you are eligible to receive free school meals.

Much of the information we have listed above will come directly from you on your admission application, but we may also receive information from your former school as well.

Once you become a pupil at one of our schools we will also begin to collect additional Personal Information such as, assessment data, attendance information, details relating to your behaviour, relevant medical information and if you require any support from us or our specifically selected external educational support partners such as Norfolk County Council.

We only ever collect and use the information that we need to provide you with our educational services such as learning support, providing appropriate pastoral care, monitoring your progress, providing reports regarding your development and assessing the quality of our educational services. We are also obliged by law to collect and share certain Personal Information as part of our legal obligations to provide Census information and fulfil our duties to promote safeguarding and wellbeing of our pupils.

We will inform you if the information we collect is mandatory or voluntary and we will always ensure that a lawful basis exists for processing the Personal Information we hold on your behalf. If we require your consent to process your Personal Information, we will always notify you of your rights and exactly what you are consenting to. If you are volunteering any sensitive Personal Information to WNAT under consent, we will ensure that your consent is given explicitly and all consents you provide will be recorded. Any consent for processing you provide to WNAT can be withdrawn at any time by contacting the dpo@westnorfolkacademiestrust.co.uk

We are required to share information about our pupils with the Department for Education (DfE) under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and amendments. If we share pupil information with any other external body, we will always ensure that a lawful basis exists at all times and the Personal Information is shared under an agreement between WNAT and the receiving body.

If you apply to become a staff member at WNAT or take a position within one of our schools, we will need to collect certain information from you to ensure we provide a safe learning environment for our pupils, an adequate working environment for you and to enable us to perform our obligations to you under the contract of employment or the terms under which you have engaged with WNAT. This information will include;

• Personal identifying information (name, address, employee/teacher number, NI number);
• Contact details (email, phone number, home address);
• Security and safeguarding information (outcomes of DBS checks, relevant background information, references)
• Professional qualifications and work/CV history;
• Financial information to allow us to pay you (bank details, invoice information)
• HR information (performance reviews, absence records, relevant sickness/health information, contract terms)

We will process this information under the lawful basis of requirement to perform the terms of your employment

Contract or service the agreement between yourself and WNAT. If we are collecting sensitive information from or about you, we will always ensure that an exemption to the prohibition to processing such data always applies.

We are required by law to share some of the Personal Information we collect from our staff with the DfE and the local authorities as part of our normal activities.

We will require specific information from you to enable us to engage with you in one of these important roles within WNAT. This will include your name, address, email and phone contact details and relevant background and security check information we require for your specific role.

We are required to collect and use this information to provide our services under the public interest lawful basis of processing or to meet our legal obligations for processing when engaging with individuals in these roles.

When your school joins WNAT, we require Personal Information from the staff, pupils, governors and all other people involved with the operations of that school.  We have to receive this information for the purposes of running your school (in the way detailed in this “HOW WE USE YOUR DATA” section) and incorporating it into our Trust.

If we have inherited Personal Information from your school, you have the same rights (explained in this Privacy Notice) as everybody else that WNAT holds data on and we will process your Personal Information for the same reasons outlined in this section.

We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

The collected information is used to provide an overview of how people are accessing and using the Website. It is not used for any additional purpose, such as to profile those who access the Website.

If we are required to store or process your data outside of the UK

We shall not transfer any personal data to any country outside the UK unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.

How long we keep your personal data.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

WNAT appoints a Data Protection Officer to oversee Data Protection across the whole Trust. The Data Protection Officer can be contacted by writing to DPO, West Norfolk Academies Trust, Queensway, King’s Lynn, PE30 4AW or emailing the dpo@westnorfolkacademiestrust.co.uk

You can object to us processing your Personal Information in certain circumstances.

You have the right to object to us handling your Personal Information when:

• we are handling your Personal Information based on processing in the performance of a task carried out in the public interests (as described in the “How do you use my data” section above). If you ask us to stop handling your Personal Information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Information should continue
• for marketing purposes. If you ask us to stop handling your Personal Information on this basis, we will stop.

Our obligations under Data protection Law and your options to control your Personal Information

You can exercise the following rights to your data by contacting us at the dpo@westnorfolkacademiestrust.co.uk

Right of access

You are entitled to receive confirmation as to whether your Personal Information is being processed by us, as well as various other information relating to our use of your Personal Information. you also have the right to a copy of the Personal Information which we are handling regarding you.

If you are requesting Personal Information as a pupil or a parent acting on their behalf, the Education (Pupil Information) Regulations 2005 do not apply to our schools as we are an Academy. However, you may make a formal Subject Access Request in the usual way provided under Data Protection Legislation.

To make a formal request, please contact the dpo@westnorfolkacademiestrust.co.uk. The information you request must relate to you or another person that you have authority to act on their behalf. WNAT will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, WNAT reserves the right to refuse your request for access to Personal Information.

If you are unhappy with how we have managed your request for Personal Information, you always have the right to follow the complaints procedure below.

Right to rectification

You have the right to require us to rectify any inaccurate Personal Information we hold about you. you also have the right to have incomplete Personal Information we hold about you completed, by providing a supplementary statement to us.

Right to restriction

You can restrict our processing of your Personal Information where:

• you think we hold inaccurate Personal Information about you;
• our handling of your Personal Information breaks the law, but you do not want us to delete it; or
• we no longer need to process your Personal Information, but you want us to keep it for legal reasons

Where you exercise your right to restrict us from using your Personal Information, we will then only process your Personal Information when you agree, except for storage purposes and to handle legal claims.

Right to data portability

You have the right to receive the Personal Information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your Personal Information.

Right to erasure

You have the right to require us to erase your Personal Information which we are handling in the following circumstances:

• we no longer need to use your Personal Information for the reasons we told you we collected it for;
• where we needed your consent to use your Personal Information and you have withdrawn your consent;
• you object to our use of your Personal Information and we have no compelling reason to carry on handling your Personal Information;
• our handling of your Personal Information has broken the law; or
• we must erase your Personal Information to comply with a law we are subject to.

Right to complain

If you are unhappy with how your request has been handled you can contact the Data Protection Officer or Director of Operations for WNAT at the dpo@westnorfolkacademiestrust.co.uk

Alternatively, you have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).

We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information.

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the 'Last updated' section below. We will endeavour to notify all of our current service users of any updates to this notice via email, and we will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Please contact us at the dpo@westnorfolkacademiestrust.co.uk  if you have any questions, comments or requests regarding this Privacy Notice.