Champs Learning is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with the data protection principles and the Data Protection Act (DPA).
Changes to data protection legislation (GDPR May 2018) shall be monitored and
implemented in order to remain compliant with all requirements.
The legal bases for processing data are as follows –
(a) Consent: the member of staff//parent has given clear consent for the organisation to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for the member of staff’s employment contract or placement contract.
(c) Legal obligation: the processing is necessary for the organisation to comply with the law (not including contractual obligations)
The members of staff responsible for data protection are mainly Anuradha
Kothikar(Director) and Louise Formicola (Academic Coordinator). However, all staff
must treat all information in a confidential manner and follow the guidelines as set
out in this document.
Champs Learning is also committed to ensuring that its staff are aware of data protection policies, legal requirements and adequate training is provided to them through our regular training service.
The requirements of this policy are mandatory for all staff employed by Champs Learning and any third party contracted to provide services within Champs Learning.
Our data processing activities will be registered with the Information Commissioner’s
Office (ICO) as required of a recognised Data Controller. Details are available from
the ICO: https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/
Changes to the type of data processing activities being undertaken shall be notified to the ICO and details amended in the register.
Breaches of personal or sensitive data shall be notified within 72 hours to the individual(s) concerned and the ICO.
All data within the organisation’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates. The definitions of personal and sensitive data shall be as those published by the ICO for guidance.
The principles of the Data Protection Act shall be applied to all data processed:
ensure that data is fairly and lawfully processed
process data only for limited purposes
ensure that all data processed is adequate, relevant and not excessive
ensure that data processed is accurate
not keep data longer than is necessary
process the data in accordance with the data subject's rights
ensure that data is secure
ensure that data is not transferred to other countries without adequate protection.
We shall be transparent about the intended processing of data and communicate
these intentions via notification to staff, parents and pupils prior to the processing of
Notifications shall be in accordance with ICO guidance and, where relevant, be written in a form understandable by those defined as ‘Children’ under the legislation.
There may be circumstances where the organisation is required either by law or in the best interests of our s or staff to pass information onto external authorities, for example local authorities, Ofsted, or the department of health. These authorities are up to date with data protection law and have their own policies relating to the protection of any data that they receive or collect.
The intention to share data relating to individuals to an organisation outside of our organisation shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information.
Any proposed change to the processing of individual’s data shall first be notified to them.
Under no circumstances will the organisation disclose information or data:
that would cause serious harm to the child or anyone else’s physical or mental health or condition
indicating that the child is or has been subject to child abuse or may be at risk of it, where the disclosure would not be in the best interests of the child
recorded by the pupil in an examination
that would allow another person to be identified or identifies another person as the source, unless the person is an employee of the organisation or a local authority or has given consent, or it is reasonable in the circumstances to
disclose the information without consent. The exemption from disclosure does not apply if the information can be edited so that the person’s name or identifying details are removed
in the form of a reference given to another organisation or any other place of education and training, the child’s potential employer, or any national body concerned with admissions.
In order to assure the protection of all data being processed and inform decisions on
processing activities, we shall undertake an assessment of the associated risks of
proposed processing and equally the impact on an individual’s privacy in holding
data related to them.
Risk and impact assessments shall be conducted in accordance with guidance given by the ICO.
Security of data shall be achieved through the implementation of proportionate
physical and technical measures. Nominated staff shall be responsible for the
effectiveness of the controls implemented and reporting of their performance.
The security arrangements of any organisation with which data is shared shall also be considered and where required these organisations shall provide evidence of the competence in the security of shared data.
All individuals whose data is held by us, has a legal right to request access to such
data or information about what is held. We shall respond to such requests within one
month and they should be made in writing to:
2 Bath Road
Hounslow - TW3 3HJ
No charge will be applied to process the request.
Personal data about students will not be disclosed to third parties without the consent of the child’s parent or carer, unless it is obliged by law or in the best interest of the child. Data may be disclosed to the following third parties without consent:
If a pupil transfers from Champs Learning to its sister companies, their academic records and other data that relates to their health and welfare will not be forwarded onto the new organisation. They have to submit their data again to the new company in their required format. This will support a smooth transition from one organisation to the next and ensure that the child is provided for as is necessary. It will aid continuation which should ensure that there is minimal impact on the child’s academic progress as a result of the move.
As obliged under health legislation, the organisation may pass on information regarding the health of children in the organisation to monitor and avoid the spread of contagious diseases in the interest of public health.
If a situation arises where a criminal investigation is being carried out we may have to forward information on to the police to aid their investigation. We will pass information onto courts as and when it is ordered.
In order to protect or maintain the welfare of our students, and in cases of child abuse, it may be necessary to pass personal data on to social workers or support agencies.
Organisations may be required to pass data on in order to help the government to monitor the national educational system and enforce laws relating to education, if this comes in to place.
Where any personal data is no longer required for its original purpose, an individual can demand that the processing is stopped and all their personal data is erased by the organisation including any data held by contracted processors.
Images of staff and students may be captured at appropriate times and as part of
educational activities for use in organisation only.
Unless prior consent from parents/pupils/staff has been given, the organisation shall not utilise such images for publication or communication to external sources.
It is the organisation’s policy that external parties (including parents) may not capture images of staff or pupils during such activities without prior consent.
Hard copy data, records, and personal information are stored out of sight and in a
locked cupboard. The only exception to this is medical information that may require
immediate access during the organisation day. This will be stored with the
organisation medical coordinator.
Sensitive or personal information and data should not be removed from the organisation site, however the organisation acknowledges that some staff may need to transport data between the organisation and their home in order to access it for work in the evenings and at weekends. This may also apply in cases where staff have offsite meetings or are on organisation visits with pupils.
The following guidelines are in place for staff in order to reduce the risk of personal data being compromised:
Paper copies of data or personal information should not be taken off the organisation site. If these are misplaced, they are easily accessed. If there is no way to avoid taking a paper copy of data off the organisation site, the information should not be on view in public places or left unattended under any circumstances.
Unwanted paper copies of data, sensitive information or pupil files should be shredded. This also applies to handwritten notes if the notes reference any other staff member or pupil by name.
Care must be taken to ensure that printouts of any personal or sensitive information are not left in printer trays or photocopiers.
If information is being viewed on a PC, staff must ensure that the window and documents are properly shut down before leaving the computer unattended. Sensitive information should not be viewed on public computers.
If it is necessary to transport data away from the organisation, it should be downloaded onto a USB stick. The data should not be transferred from this stick onto any home or public computers. Work should be edited from the USB and saved onto the USB only.
USB sticks that staff use must be password protected.
These guidelines are clearly communicated to all organisation staff, and any person who is found to be intentionally breaching this conduct will be disciplined in line with the seriousness of their misconduct.
The organisation recognises that the secure disposal of redundant data is an
integral element to compliance with legal requirements and an area of
All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner with demonstrable competence in providing secure disposal services.
All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process.
Disposal of IT assets holding data shall be in compliance with ICO guidance: https://ico.org.uk/media/fororganisations/documents/1570/it_asset_disposal_for_organisations.pdf
The organisation has identified a qualified source for disposal of IT assets and collections. The organisation also uses Shred-it to dispose of sensitive data that is no longer required.