PRIVACY NOTICE

Welcome to our privacy notice. Luton Junior School (”We”) are committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how Luton Junior School collects and processes your personal data and the personal of data of your children through your use of this website, including any data you or your child may provide directly through this website.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (the Act) and the EU General Data Protection Regulation (GDPR), the data controller is Luton Junior School of Luton Road, Chatham, Kent, ME4 5AW. Our ICO registration number is Z5819906.

Our nominated Data Protection Officer (DPO) is Ciaran McCann and you may contact our DPO to find out more about the way we treat and use personal data via email at office@lutonjnr.medway.sch.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.



Who is the Privacy Notice for?

This privacy notice describes the way we treat and use personal data that we collect about any child or adult that uses our services. We believe that it is important that children also understand how we look after their personal data and what their privacy rights are so we have created a dedicated privacy notice for children.



If you do not provide personal data

If we need to process the data you provide us with about yourself to fulfil our service and you fail to provide that data when requested, we may not be able to perform the service. We will of course notify you if this is the case at the time.

Please note that as a parent or guardian of a child who has signed up to use our services, you are responsible for your child’s use of our services.



What information do we use?

We will collect and process the following data about you:

Information you give us about you or your child. This is information about you or your child that you give us by filling in forms on our website (www.lutonjuniorschool.co.uk) that you may access directly or through another website, or by corresponding with us by phone, e-mail or otherwise. It only includes basic personal data required for you to be able to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include your full name, address, e-mail address and phone number.

Information we collect about you. With regard to each of your visits to our website we will automatically collect the following information:

↦ technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

↦ information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our service number.

Information we receive from other sources. This is information we receive about you or your child if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies). We will notify you when we receive personal data about you from them and the purposes for which we intend to use that information.



Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.



How do we use this information?

We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the service agreement we are about to enter into or have entered into with you

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

• Where we need to comply with a legal or regulatory obligation

• Where it is in the vital interests of your child or any other member of our school

Generally we do not rely on consent as a legal basis for processing your personal data.

Information you give to us. We will use this information:

↦ to carry out our obligations arising from any service agreements entered into between you and us and to provide you with the information and services that you request from us;

↦ to notify you about important changes to our service.

Information we collect about you. We will use this information:

• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

↦ to improve our website to ensure that content is presented in the most effective manner for you and for your device;

↦ to allow you to participate in interactive features of our service, when you choose to do so;

↦ as part of our efforts to keep our website safe and secure;

Information we receive from other sources. We may receive personal data about you from selected third parties that we work with or that provide us with a service and public sources.



Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you or your child. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing either to you directly or to your child.

We do not market directly to children without your explicit consent.

You can ask us to stop sending you marketing messages to you or your child at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at office@lutonjnr.medway.sch.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service agreement that you have entered into with us.



Third-party marketing

We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.

We will not share child data with any third party solely for their marketing purposes.



Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at office@lutonjnr.medway.sch.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



How do we share your information?

You acknowledge and agree that from time to time we have the right to share your personal information with selected third parties including select business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or public authorities where necessary.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

• If Luton Junior School or substantially all of its assets are acquired by a third party, in which case personal data held by it about you and / or your children will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of Luton Junior School, our students, parents or others. This includes exchanging information with other companies and organisations for the purposes of child protection, fraud protection and the health and safety of our teachers and students.



Where do we store your information?

All personal data we process is processed by our staff in the UK.

For the purposes of IT hosting and maintenance this information is located on servers within the European Economic Area.

Please contact us at office@lutonjnr.medway.sch.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.

However and unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website at transmission stage; any transmission is at your own risk.



How long do we keep your information for?

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.

We are required under the Education Act 2002 to keep any child data that we hold about our students until they attain the age of 25 after which time it will be destroyed. We will keep parents’ data for the same amount of time as we hold their child’s data for to enable us to communicate with you if required for any matters that may arise.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

In some circumstances you can ask us to delete your data. See below for further information.



What are your rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.



Exercising your rights

If you wish to exercise any of your rights set out above, please email us at office@lutonjnr.medway.sch.uk.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.



Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.



Changes to our Privacy Notice


Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail.

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