Supported Employment in Schools privacy notice
We keep this privacy notice under regular review and it was last updated in January 2022.
This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.
Who we are
Kent County Council (KCC), on behalf of the Supported Employment in Schools Service provided by The Education People, collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.
The Supported Employment in Schools Service is delivered by the Specialist Employment Service within The Education People (TEP), on behalf of KCC, and provides training and consultancy to school staff in mainstream secondary schools in Kent, to assist them in embedding the principles of Supported Employment within their careers programme in order to support pupils with Special Educational Needs and Disabilities (SEND).
Personal information we collect and use
Information collected by us
Training Participants (School Staff)
In the course of providing you with details of training events, follow up to the events, providing updates, messages and sharing information, we collect the following personal information when you provide it to us:
- Name of person registering for the training
- Name/s of person/people attending events (if different/in addition to the above)
- Address
- Contact number
- Email address
- Special category data (such as accessibility, dietary, health requirements) for the purpose of allowing us to make adjustments
We may also take recordings of online training sessions or photographs at events and your consent will be sought during the registration process.
Consultant Learners
Young people who support the training as a ‘Consultant Learner’ will be working with a member of staff from their school to complete an exercise as part of one of the sessions. The staff member will be asked to demonstrate how they would assist the 'Consultant Learner' to complete a simple task. This task will be observed and filmed by the trainer. By capturing their image on the recording, some of the following personal information about the Consultant Learner may be collected, but we will not be storing this information beyond the end of the training day or sharing this more widely:
- Ethnicity
- Religious beliefs
- Special category data (such as disability or health needs)
We will seek explicit consent from parents/carers for any young person aged under 18 to participate as a Consultant Learner, or from the Consultant Learner themselves if aged over 18.
How we use your personal information
We use your personal information to:
- provide you with details of any information or events relating to the Supported Employment in Schools Service
- communicate with you about your booking for training sessions or peer review meetings, and where events are conducted in person, will ensure that necessary arrangements are made for accessibility and dietary requirements
- contact you to obtain feedback on events attended and to provide information about future sessions. This may include, video recordings of training sessions to help facilitate the delivery of the service to registered participants
- share and disseminate relevant information about the Supported Employment in Schools service to you that is pertinent to your role/organisation
- promote the work of the Supported Employment in Schools Service using your photographs, with your consent
- record a demonstration with a Consultant Learner: this will be used only by the trainer and the relevant participating member of staff to ensure that course participants can demonstrate the required level of skill (and to help them improve where necessary).
How long your personal information will be kept
We will hold and use the personal information that you provided to register for the service for 6 years, after which the information is made inaccessible to system users or securely destroyed.
Any photographs and images that are taken at the event, will be stored securely and used only for the purposes detailed within this privacy notice, for 6 years or until you withdraw your consent, whichever comes first.
Consultant Learners: any recording involving a Consultant Learner will only be kept for the duration of the training session itself and will be securely deleted by the trainer at the end of the day.
Reasons we can collect and use your personal information
We collect and use your personal information to carry out tasks with your consent to collect and use your personal data and your image (if you have given specific additional consent for photographs to be taken for a specific reason). We rely on the following legal basis under UK GDPR:
- Article (6)(1)(a) - Consent: the individual has given clear consent to process their personal data for a specific purpose
We also collect and use your personal information to carry out tasks in the public interest, in relation to the management of the programme and subsequent follow up, namely for the coordination of the Supported Employment in Schools Service to support the inclusion of children and young people with SEN in mainstream schools (as described in the SEN Code of Practice 2015, para 6.4: ‘the quality of teaching for pupils with SEN and the progress made by pupils should be a core part of the school’s performance management arrangements and it’s approach to professional development for all teaching and support staff’). We rely on the following legal basis under UK GDPR:
- Article (6)(1)(e) - Public task: the processing is necessary to perform a task in the public interest or for official functions (task or function has a clear basis in law)
When we collect or share special category personal data, including photographs or recorded training sessions there will be an additional consent form to sign. For Consultant Learners, we will seek explicit consent from parents/carers for any young person aged under 18 who is involved, or from the Consultant Learner themselves if aged over 18. For this processing we rely upon the following legal bases under UK GDPR:
- Article 9(2)(a) - Explicit consent
You may withdraw your consent at any time. If you do withdraw your consent no further personal information will be collected and the existing personal information shall only be retained in accordance with KCC’s data protection policy. If you do withdraw your consent, we will not be able to ensure that any necessary health needs are met.
Who we share your personal information with
The Supported Employment in Schools Service is delivered by the Specialist Employment Service within The Education People (TEP) and your personal information will be shared with KCC in order to co-ordinate and deliver the programme.
Your photographs may be used in print and electronic form including but not limited to publications, press, websites, apps and social media platforms (Linkedin and Twitter).
We will share personal information with law enforcement or other authorities if required by applicable law.
Recording of training exercise with Consultant Learners: Only the member of staff involved, the Consultant Learner, and the trainer will be able to watch the recording. The recording will only be played back during the training session itself, to help the staff member practice and review their skills, and will not be shared with anyone else. The recording will be securely deleted by the trainer following the training session (within 24 hours).
Your rights
Under UK GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (Subject Access Request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner's Office
- withdraw consent at any time (if applicable)
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note: your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the Information Commissioner's Office (ICO) on individuals’ rights under the UK GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Who to contact
Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.
UK GDPR also gives you right to lodge a complaint with the Information Commissioner's website or call 03031 231113.