Privacy Policy

The following is a statement about the Somersfield Academy (the “School”) privacy policy (the “Policy”). The Policy provides information about how we use Personal Information (as defined below).

We use Personal Information about prospective, current and past students and their parents; staff, suppliers and contractors; donors, friends and supporters; and other individuals connected to or visiting the Schools. The Personal Information we use takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples may include:

  • names, addresses, telephone numbers, e-mail addresses and other contact details;

  • family details;

  • admissions, academic, disciplinary and other education-related records, information about special educational needs, references, examination scripts and marks;

  • education and employment information;

  • images, audio and video recordings;

  • financial information (i.e. for bursary assessment or for fundraising);

  • course, meetings or events attended. (collectively, “Personal Information”)

As a School, we need to use some Sensitive Personal Information (i.e. concerning health, ethnicity, religion or medical information) and criminal record information about some individuals (particularly students and staff). We do so by all applicable laws and in particular by the Personal Information Protection Act, 2016 (‘PIPA’).

Collecting, Handling and Sharing Personal Information

We collect most of the Personal Information we use directly from the individual concerned (or in the case of students, from their parents). In some cases, we collect Personal Information from third parties (for example, referees, previous schools, or professionals or authorities working with the individual) or from publicly available resources.

Personal Information held by us is used by appropriate members of staff for the purposes for which the Personal Information was provided. We take appropriate technical and organisational steps to ensure the security of Personal Information about individuals, including policies around the use of technology and devices, and access to School systems.

We do not transfer Personal Information to any overseas third party unless we are satisfied that the Personal Information will be afforded an equivalent level of protection.

In the course of School business, we share Personal Information (including Sensitive Personal Information where appropriate) with third parties such as examination boards, the School doctors, the School’s professional advisors and relevant authorities. Some of our systems are provided by third parties, i.e. hosted databases, School websites or cloud storage providers. This is always subject to contractual assurances that all Personal Information will be kept securely, used only by our specific directions and that such third parties represent that they are compliant with PIPA.

Purposes for Which We Use Personal Information

We use Personal Information to support the School’s operation. The following is a non-exhaustive list of how Personal Information is likely to be used:

  • Support student learning;

  • For student selection and admission to the School (and to confirm the identity of prospective students and their parents);

  • Monitor and report on their progress;

  • Provide education services, including musical education, physical training or spiritual development, career services, and co-curricular activities to students, and monitoring students' progress and educational needs;

  • Assess how well the school is doing as a whole;

  • Maintain relationships with alumni, staff and the School community, including direct marketing or fundraising activity;

  • Undertake donor due diligence, and confirm the identity of prospective donors and their background and relevant interests. The School may analyze publicly available information about potential donors to make appropriate requests;

  • Keep parents, alumni, staff and other members of the school community updated about the activities of the School including fundraising, alumni and parent events of interest;

  • Monitor students’ email communications, and internet use to ensure compliance with School policy;

  • Where appropriate, promote the School through the School’s media sources (including the use of photographs or images);

  • Enable relevant authorities to monitor the School's performance and to intervene or assist with incidents as appropriate;

  • Give and receive information and references about past, current and prospective students, including relating to outstanding fees or payment history, to/from any educational institution that the student attended or where it is proposed they attend; and to provide references to potential employers of past students;

  • Give and receive information and references about past, current and prospective staff;

  • Enable students to take part in national or other assessments, and to publish the results of public examinations or other achievements of students of the School;

  • Safeguard students' welfare and provide appropriate pastoral care;

  • Make use of photographic and video images of students and staff in school publications, on the School website and (where appropriate) on the School's social media channels by the School's policy on taking, storing and using images of children;

  • Ensure security such as using CCTV cameras ;

  • Carry out or cooperate with any school or external complaints, disciplinary or investigation process;

  • Support the School's administrative requirements including obtaining appropriate professional advice and insurance for the School.

  • In addition, the School will, on occasion, need to use Sensitive Personal Information by any rights or duties imposed on it by law.

  • These reasons will include:

  • To safeguard student and staff welfare and provide appropriate pastoral (and where necessary, medical) care, and 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: e.g. for medical advice, for social protection, safeguarding, and cooperation with police or social services, for 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 student;

  • To provide spiritual education in the context of any religious beliefs;

  • In connection with the employment of its staff to run any of its systems that operate on biometric data, such as for security and other forms of student identification (lockers, School shop purchases etc.);

  • As part of any school or external complaints, disciplinary or investigation process that involves such Personal Information, e.g. if there are learning, health or safeguarding elements;

  • For legal and regulatory purposes (e.g. child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.

How Long We Keep Personal Information

We retain Personal Information only for a legitimate and lawful reason and only for so long as necessary or required by law. If you have any specific queries about our record retention periods or wish to request that your Personal Information is considered for erasure, please contact privacy@somersfield.bm.

Your Rights

You have various rights under PIPA to access and understand the Personal Information we hold about you, and in some cases to ask for it to be erased or amended or for us to stop using it, but subject to certain exemptions and limitations.

You always have the right to withdraw consent, where given, or otherwise object to receiving generic or fundraising communications. Please be aware however that the School may have another lawful reason to use the Personal Information in question even without your consent. That reason will usually have been asserted under this Policy or may exist under some form of contract or agreement with the individual.

If you would like to access or amend your Personal Information or would like it to be transferred to another person or organisation, or have some other objection to how your Personal Information is used, please make your request in writing to privacy@somersfield.bm.

We will respond to any such written requests as soon as is reasonably practicable. We will be better able to respond quickly to smaller, targeted requests for information. If the request is excessive or similar to previous requests.

You should be aware that certain information is exempt from the right of access. This may include information which identifies other individuals or information which is subject to legal privilege. We are also not required to disclose any student examination scripts (though examiners' comments may fall to be disclosed), nor any confidential reference given by the School for the education, training or employment of any individual.

Student Information

The rights under PIPA belong to the individual to whom the information relates. However, we will often rely on parental consent to use Personal Information relating to students (if consent is required) unless, given the nature of the user in question, and the student's age and understanding, it is more appropriate to rely on the student'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, we will assume that students’ consent is not required for ordinary disclosure of their Personal Information to their parents, unless, in the School's opinion, there is a good reason to do otherwise.

However, where a student seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their Personal Information being disclosed to their parents, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example where the School believes disclosure will be in the best interests of the student or other students, or is required by law.

Students can make subject access requests for their Personal Information, provided that they have sufficient maturity to understand the request they are making. Our students are generally assumed to have this level of maturity. A person with parental responsibility will generally be entitled to make a subject access request on behalf of students, but the information in question is always considered to be the children at law. A student of any age may ask a parent or other representative to make a Personal Information access request on their behalf. Moreover (if of sufficient maturity) their consent or authority may need to be sought by the parent making such a request.

Change of Details

We try to ensure that all Personal Information held about an individual is as up to date and accurate as possible. Please notify privacy@somersfield.bm of any significant changes to important information, such as contact details, held about you or your child.

Our privacy notice should be read in conjunction with the School’s other policies and terms and conditions which refer to PIPA.

We will update this Privacy Notice from time to time. Any substantial changes that affect how we use your Personal Information will be notified on our website and to you directly, as far as practicable.

If you believe that we have not complied with this Policy or have acted otherwise than by PIPA, please contact privacy@somersfield.bm.