Privacy Notice – May 2018
1. Your privacy
The Independent Schools Inspectorate (“ISI”) is committed to protecting your privacy. We aim to ensure that any information you give us or which we receive or gather in the course of inspection and inspection related activities is held securely and safely.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. Lawful bases we rely on for the collection of your data
We only process your personal data where: (i) we have your consent to do so; (ii) the processing is necessary for the performance of a contract with you; (iii) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in ISI; (iv) the processing is necessary for compliance with a legal obligation to which the ISI is subject; (v) for the legitimate interest of ISI or of any party to whom the data is being disclosed.
3. Collection and use of your personal data
ISI is likely to hold information about you if any of the following apply:
- you have provided information about yourself when writing to us or telephoning us, and we have a legitimate interest in processing this personal data or the processing of this personal data is necessary for the performance of a task carried out in the public interest;
- we have received or gathered information about you in the course of our inspection work and inspection related activities, and the processing of this personal data is necessary for the performance of a task carried out in the public interest;
- you are an inspector, former inspector or at any stage of training to be an inspector and therefore have a contract with or have made a declaration to ISI;
- you work or have worked for or with ISI in any other capacity and have a contract with ISI or have given your explicit consent;
- you have contacted or used the services of ISI Consultancy Limited, or provided services to ISI Consultancy Limited and ISI Consultancy Limited therefore either has a contract with you, a legitimate interest in the processing of your personal data or the processing of your personal data is necessary for the performance of a task carried out in the public interest; or
- you are a named contact at a school we inspect and therefore the processing of your personal data is necessary for the performance of a task carried out in the public interest.
Your personal data may be processed by (or on behalf of) ISI for any of the following purposes:
- planning, scheduling and delivery of inspections;
- training and recruitment of inspectors and ISI employees;
- communication of information and guidance to inspectors, schools, and colleges;
- receiving and reporting concerns and information relevant to inspections;
- promotion and safeguarding of the health, welfare and safety of children;
- for any other purpose which you have consented to at the time of provision of your personal data.
Your personal data will be retained in accordance with ISI’s retention policy; this policy is available from ISI: please contact firstname.lastname@example.org if you would like to receive a copy.
4. Special category data
Some of the personal data we process is sensitive; in such circumstances we consider additional conditions and ensure that these requirements are met.
5. Children’s personal data
Some of the personal data we process relates to individuals under the age of 18. Our systems and processes are designed to cater for the particular protections required when collecting and processing children’s personal data.
6. How we treat your personal data
The processing of personal data is governed by the GDPR and the associated UK data protection legislation, and other relevant legislation. We follow this legislation when handling your personal data and will:
- only ask for personal data we need, and not collect too much or irrelevant information;
- protect your information, ensuring appropriate security;
- take every reasonable step to ensure that your personal data is accurate and, where necessary, kept up to date;
- ensure you are aware of your rights in relation to the personal data we hold about you;
- make sure we do not keep it longer than necessary.
ISI does not sell, rent or pass on any information about you to other organisations, other than:
- we may share your data with our subsidiary company ISI Consultancy Limited in order to inform you of the services available, provide you with advice, information or services that you have requested;
- if necessary, we may share your information with our consultants, inspectors, contractors, service providers or partners during the course of their work with us. Such third parties will be required to protect your privacy just as we would ourselves;
- we may need to pass on information to other agencies such as local authorities, when required by law or by a regulatory body (for example, the Department for Education, Home Office, Ofsted) or if asked for details by a law enforcement agency.
7. Transfer of data outside the EEA
ISI may transfer personal data outside the European Economic Area (EEA) for legitimate business purposes, for example in connection with inspections of British Schools Overseas. Where we do so, we will ensure that transferred data is fully protected and safeguarded as required by the General Data Protection Regulation.
8. Respecting your individual rights
ISI acknowledges and respects your rights in relation to the personal data we hold about you, specifically:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object;
- rights in relation to automated decision making and profiling;
- the right to withdraw any consent you have previously provided to ISI; and
- the right to lodge a complaint with a supervisory authority.
ISI acknowledges and respects that these rights apply equally to children from whom we collect personal data.
ISI acknowledges that in some circumstances the information provided to ISI (generally in relation to safeguarding concerns) includes personal data, which may be special category, about individuals who are not aware of ISI’s processing. It is unlikely to be appropriate for ISI to inform such individuals of the processing as doing so could disrupt the management of the concern and safeguarding of children. Such processing is considered by ISI to be in the substantial public interest. However, ISI operates a personal data minimization approach. ISI requests that if personal data is provided to us in relation to individuals who are not aware of the processing, the information is kept to what is necessary, and that any irrelevant personal data is redacted.
9. Exercising your individual rights
If you would like to exercise any of the rights listed above including a subject access request, or if you no longer wish to receive information from ISI, please write to us or email us using the contact details provided below.
Data Protection Compliance Manager
Independent Schools Inspectorate
9-12 Long Lane
For complaints or issues around your personal data which we are unable to resolve to your satisfaction, please refer to the ICO website: https://ico.org.uk/for-the-public/personal-information
ISI has strict requirements in relation to: entry controls to the office; secure lockable desks and cupboards; limited access to files; methods of document disposal and deletion; use of computer equipment; and network security.
11. Freedom of Information Act
As a private company, ISI is not subject to the Freedom of Information Act. You may find the information you seek on our website and sometimes we are able to supply additional information on a voluntary (non-statutory) basis.
Requests may be made in writing to the address provided above.
ISI is registered as a data controller on the Information Commissioner’s Office’s data protection register. ISI’s registration number is ZA138661 and the registered address is: CAP House, 9-12 Long Lane, London, EC1A 9HA.
Questions, comments and requests concerning this privacy statement are welcome – please contact us using the contact details provided above.
14. Updates to this Privacy Notice
This Privacy Notice was last updated in May 2018. ISI reserves the right to vary this Privacy Notice from time to time. When we make significant changes we will notify our contacts via email (unless specifically agreed otherwise) and we will publish a notification on our website.