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Inclusion Leadership Service Applicants and Leaders privacy notice

We keep this privacy notice under regular review and was last updated in December 2021.

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.

This privacy notice is aimed at all applicants of the Inclusion Leadership of Education programme, whether successful or not (“Applicants”) and successful applicants who go on to be Leaders of the Leadership of Education programme (“Leaders”).

Who we are

Kent County Council (KCC), on behalf of the Inclusion Leadership Service provided by the LLSE Consortium (comprising Leadership Learning South East (LLSE), National Association for Special Educational Needs (NASEN), and the Education Development Trust), 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 Inclusion Leadership Service is delivered by the LLSE Consortium and provides training and peer review support to school leaders of mainstream primary and secondary schools in Kent, to assist them in reviewing and strengthening their approaches to the inclusion of pupils with Special Educational Needs and Disabilities (SEND).

Personal information we collect and use

Information collected by us

In order to provide you with details of training events, follow up to the events, provide updates, messages and share information, and in the course of administrating the recruitment process for the Inclusion Leaders of Education, and to deploy the successful candidates across schools as part of their role, we collect the following personal information when you provide it to us:

Applicants and leaders:

  • Your name, address, contact number and email address
  • Place of work and job title
  • Any information provided as part of your application for the Inclusion Leaders of Education
  • Photographs.

Leaders:

In addition to the above, if your application is successful, we will also collect the following information about you:

  • Name/s of person/people attending events (if different/in addition to your name)
  • Job title
  • Unique reference number (URN) of your school
  • Special category data (such as accessibility, dietary, health requirements) for the purpose of allowing us to make adjustments
  • Any feedback you provide on events attended. We may also take recordings of online training sessions and your consent will be sought during the registration process.

We may also take recordings of online training sessions or photographs from in-person sessions and your consent will be sought during the registration process.

How we use your personal information

We use your personal information to:

For applicants:

  • To administer the recruitment process for the Inclusion Leaders of Education
  • To communicate with you about your application and use the information you provide in order to shortlist, interview and appoint candidates.

For leaders:

  • To provide you with details of any information or events relating to the Inclusion Leadership Service
  • To co-ordinate training sessions / peer review meetings and events – we will communicate with you about sessions you are requested to attend as part of your role to support schools and any bookings you have made. Where events are conducted in person, will ensure that necessary arrangements are made for accessibility and dietary requirements. We will contact you to co-ordinate sessions around your availability, obtain feedback on events attended and to provide information about future sessions. We will also contact you to administer the process of funding release time to your school
  • To provide payment for funded release time at the appropriate day release rate to the school in which you work
  • We may record training sessions in which you are a participant, in order to offer these sessions to other potential course participants who could not attend.

For both applicants and leaders:

  • To share and disseminate relevant information about the inclusion leadership service to you that is pertinent to your role/organisation.
  • We may use photographs of you to promote the work of the Inclusion Leadership Service, but if you don’t want your images used in this way, you can let us know (details below)

How long your personal data will be kept

For successful applicants, we will hold and use the personal information that you provided to register for the service for 6 years, after which time it will be securely disposed of.  For unsuccessful applicants, we will hold and use your personal information for a maximum of 6 months after which the information is made inaccessible to system users or securely destroyed.

For Leaders, 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 events, will be stored securely and used only for the purposes detailed within this privacy notice, for 6 years or upon withdrawal of your consent, whichever comes first.

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
  • Article (6)(1)(e) - Public task: the processing of your personal information is necessary to perform a task in the public interest or for official functions

To rely on the public task lawful bases, we must have an underlying public function which allows us to process your information in this way. Our underlying public functions in relation to this service are set out 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’, which is underpinned by various pieces of legislation, such as the Children & Families Act, 2014, Part 3.

When we collect or share special category personal data, we rely upon the following legal bases under UK GDPR:

  • Article 9(2)(a) – Explicit consent: where video recordings or photographs may include information about your health, race/ethnicity or religious beliefs, we are relying on your explicit consent for this processing of your information
  • Article 9(2)(g) – Substantial public interest: where the information we use includes special categories of personal data, such as accessibility, dietary and health requirements, the processing is necessary on the basis of our public functions. We rely on the ‘equality of opportunity or treatment’ purpose condition from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data.

Withdrawing your consent

You have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.  You can withdraw your consent by by contacting the Information Resilience and Transparency Team at data.protection@kent.gov.uk.

If you consent to being part of recorded training sessions, but later decide to withdraw that consent, we will no longer use those recorded sessions (or anonymise you where possible), but will not retrieve all copies of those recorded sessions which we have provided to other potential participants whilst your consent was valid.

Objecting to the use of your images in promotional material

Photographs may be taken at events you attend and you may be included in those photographs. You will always be informed in advance that photographs will be taken.

We may use these photographs in our promotional materials, in order to promote the Inclusion Leadership Service. Although we are not relying on your consent to use these images, you can ‘opt-out’ of having your images used in this way. If you would like to do so, please email inclusion@llse.org.uk.

Please note that if you do not withdraw consent for use of your image in our promotional material but later decide that you no longer want your image used in this way, you can let us know and we will consider your objection and stop using your images where we can. Where we agree to stop using your image, we will not be able to retrieve any promotional information sent out by email (or other correspondence) before you notified us of your objection. We may also publish promotional material online, but will remove this if we agree to your objection. However, once we have published that material online, due to the nature of the internet and the fact that it is possible for individuals to copy or save that digital image without our knowledge, we will not be able to effectively remove all traces of your image.

Who we share your personal information with

We may share your personal information with the following third parties or in the following ways:

  • The Inclusion Leadership Service is delivered by the LLSE Consortium (comprising Leadership Learning South East (LLSE), National Association for Special Educational Needs (NASEN), and the Education Development Trust), and your personal information will be shared between the consortium partners and with KCC in order to co-ordinate and deliver the sessions.
  • Where you have not objected to us doing so, your photographs may be used in print and electronic form including but not limited to publications, press, websites, apps and social media platforms.
  • We will share personal information with law enforcement or other authorities if required by applicable law.
  • We may share your information with professional advisors, such as lawyers, in the exercise of defence of legal claims.

We will share personal information with law enforcement or other authorities if required by applicable law.

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 Commissioners 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 UK Information Commissioners Office (ICO) on individuals’ rights under 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.

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 who may be contacted via the Information Commissioner's website or call 03031 231113.

Read our corporate privacy statement.