Privacy Policy

Developing Xcellence in Youth-TRC understands that customers care about the use and storage of their personal information and we value your trust in allowing us to do this in a careful and sensible manner. We have created this privacy policy statement in order to demonstrate our commitment to the privacy of our customers.

 We are committed to protecting and respecting you, your students, and or the students’ parents/carers privacy. This policy (together with our terms and conditions as stated within the Host Agency and Participation Agreement) sets out the basis on which any personal data we collect from you, your students, and or the students’ parents/carers, or that which you provide to us, will be processed. This means that we are responsible for, and control the processing of, the personal information you, your students, and or the students’ parents/carers provide to us when using the services of Developing Xcellence in Youth-TRC.

For the purpose of the Data Protection Act 1998 (the Act), the Data Protection Act 2018, once in force, and the General Data Protection Regulation (GDPR), the Data Controller is Developing Xcellence in Youth-TRC, 15 Ramshead Crescent, Seacroft Leeds, LS14 1PE. Our nominated representative for the purpose of the Act is Mr Christopher Manners.

In those cases where we need your consent to process your information, we will ask you to make a positive indication (e.g. to tick a box or insert your contact details on the relevant form requiring consent). By actively providing us with your consent, you are stating that you have been informed as to the type of personal information that will be processed, the reasons for such processing, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject and that you have read and understood this privacy policy. By using the services of Developing Xcellence in Youth-TRC you are accepting and consenting to the practices described in this policy.

We may collect and process the following data about you, your students, or the students’ parents/carers:

The information you give us:

When you register to use Developing Xcellence in Youth-TRC or submit a complaint using our service, you give us personal information and information about you, your students, or the students’ parents/carers.

The information you or your students, or students’ parents/carers give us may include:

* full name;

* postal address;

* email address;

* telephone number;

* payment details;

* geo-location;

* disability and health information;

* voice recordings;

and information provided to us as part of you, your students, or the students’ parents/carers access to our services.

e.g.

* Customer feedback or surveys as part of your experience of Developing Xcellence in Youth’s      personal development services;

* Register entry in the booking diary (Electronic)at DXU TRC’s offices;

* Raised complaints or disputes with us, or if we are involved in a legally recordable incident at your premises (e.g. in relation to Health and Safety and also Safe Guarding reporting);

* The personal information collected in the above manner may also include the following information about you or your students, or students’ parents/carers:

* Details of the nature of student referrals through pen portraits.

* Other third-party (agency) reports on the student.

* Notes made from verbal information obtained through attendance at Early Help meetings, and other consultations.

*Relevant medical information pertaining to the student’s behaviour.

Information we may collect about you or your students, or students’ parents/carers would include the following information:

Details of homelife circumstances (details on parents/carers; including occupations, siblings and other relevant family members and home occupants, where a student lives, friendships and relationships).

School performance information, (Verbal, ATL Reports, Planner, exam results). Attendance and exclusion.

We may receive information about you, your students, or the students’ parents/carers from Third party sources relating to the student, i.e. medical information, social services, whether the child is ‘Looked After’, which we will add to the information we already hold about you, your students, or the students’ parents/carers in order to help us provide our products and services in accordance with your requirements and to ensure that the quality of data we have relating to you, your students, or the students’ parents/carers is maintained properly.

Information of concern/interest, Physical markings, i.e. cuts and bruises and the nature of their occurrence, incidences of absconding from school or the home environment, substance use/misuse, sexual activity. Gang related and criminal activity, bullying, mental and physical health concerns. General student welfare issues relating to rest, eating, leisure time activities, standard of dress and turnout and general well-being.

We only process your data when we have a lawful reason for doing so. The lawful reason we use to process your personal data may differ for each processing activity.

The personal information that we collect is so that we can provide you, your students, or the students’ parents/carers with the personal development services, products or information you have requested it is processed under Legitimate Interest. This means that it is in the interests of both the data subject (you, your students, or the students’ parents/carers) and Developing Xcellence in Youth-TRC to process the data, so that the issues relating to the student referral can be supported and resolved in the shortest time. We have conducted a balancing test to ensure that Developing Xcellence in Youth-TRC’s interests do not outweigh those of the data subject.

We keep your personal information in line with our data retention policy and will only retain it for as long as is necessary for the purpose(s) for which we originally collected it.

We retain your information for a range of purposes which determine the period of time for which we need to keep such information. For example (list is not exclusive):

* Future ongoing work with students (from year 7 up until year 11, 5 years).

* Year 11-13 students 6 months after last contact, data will be removed and destroyed.

* A statutory obligation to keep your personal information for a set period of time for example financial information (normally 6-7 years) for financial auditing purposes.

We will remove your data from our systems at the end of the applicable data retention periods, unless we are required by current or future law to retain your personal information for a longer period. If you require more information about our data retention policy, then please contact us via the contact details provided.

We use information held about you, your students, or the students’ parents/carers in order to take the necessary steps in preparation of, or to fulfil our obligations under, the student referral contract:

With regards to the information you give to us we will use this information:

 * to facilitate the resolution of, you or your students, or students’ parents/carers referral;

* to provide you or your students, or students’ parents/carers with information, products and services that you request from us;

* to notify you or your students, or students’ parents/carers about changes to our service;

* to carry out our obligations arising from any contracts entered into between you or your students, or students’ parents/carers and us.

 Information we collect about you will be used:

* to administer internal operations, including troubleshooting, data and statistical analysis and research;

* to help you, your students, or the students’ parents/carers to prioritise and manage cases;

* to improve our delivery content ensuring that services are presented and delivered in the most effective manner for you, your students, or the students’ parents/carers;

* Invoicing and taxation auditing purposes.

We may share your personal information with other staff members of our organisation Developing Xcellence in Youth-TRC and or any of the following:

* Therapists and course leaders.

* Service providers who provide IT and system administration services.

* Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

* HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

* We would have to disclose you, your students, or the students’ parents/carers personal information if we were under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Developing Xcellence in Youth-TRC, our customers, or others.

Although we will do our best to protect you, your students, or the students’ parents/carers personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

To protect your information, Developing Xcellence in Youth-TRC has policies and procedures and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. There are also measures in place to make sure that only authorised personnel can access the information.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data and (when used) they are issued with contracts, with clearly defined roles and responsibilities.

Storage

All information you provide to us is stored electronically on our secure computers. Paper written notes and printed documents are stored in locked filing cabinets within locked offices. When in transit or carrying documents on location these are stored in a combination locked case in a locked car or locked office. Where we have given you a password for the secure transfer of sensitive documents, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Destruction

Disposal of electronic data such as documents, files, emails, text messages, will be permanently deleted from electronic files and also the deleted items bin. Paper documents will be shredded and burnt on location. The removal and destruction of these items will take place after the aforementioned time scales. If computer systems are to be updated then hard drives will be removed and destroyed, this measure will also apply to obsolete data carrying devices no longer engaged in company business.

While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the Internet, we are unable to warranty the absolute security of your data when using our services.

We only use you, your students, or the students’ parents/carers personal information for the personal development of the student we are contracted to work with providing we are allowed to do this by law or if we have your consent. If you, your students, or the students’ parents/carers have previously agreed to us using your personal information for any other purposes, you may withdraw consent at any time by writing to us via the contact details previously given.

Requests to access, change, or remove your information will be handled within 30 days.

 Right of Access to your information:

if you require access to the personal data we hold about you then please email or write to us via the contact details previously given.

Right to Rectify your information:

If you believe that the information we hold about you is incorrect then please email or write to us via the contact details previously given so that the necessary amendments can be made.

The right to have your information erased:

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

Right to Restriction of Processing:

If you believe that your personal data is inaccurate, or that Developing Xcellence in Youth-TRC is processing your personal data unlawfully and you do not want your personal data erased and you wish to restrict the processing of your personal data, then please email or write to us via the contact details previously given so that necessary adjustments and instructions can be adhered to.

The right to object to processing of your data:

You have the right to request that Developing Xcellence in Youth-TRC stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to data portability:

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

The right to complain:

You can make a complaint to us by contacting us via the contact details previously given, or to the data protection supervisory authority – in the UK, this is the Information Commissioner’s Office, at https://ico.org.uk/.

It is highly unlikely that there should ever arise a need where Developing Xcellence in Youth-TRC would need to transfer your personal information to parties which are located outside the European Economic Area. In the event likely or unlikely that such a need should arise any transfer of your data would be subject to a notice of intention period and adequate levels of protection that would safeguard your privacy rights and give you remedies in the event of a security breach.

Any changes we may make to our privacy policy in the future will be forwarded to you by email.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Developing Xcellence in Youth-TRC at the email or the contact details previously given.