Aquinas (School Attendance Provisions) Ltd is committed to complying with the General Data Protection Regulation, Data protection Act 2018 and all other relevant privacy and data protection legislation. We treat the privacy of our employees, customers, website users, subscribers and other stakeholders very seriously and have put in place appropriate security measures to safeguard and secure the information that we collect from you. By visiting or otherwise using our website you are agreeing to the practices set out in this Privacy Policy.

This Privacy Notice will help you to understand how we protect and manage any personal data you share with us and that we hold about you, including:

How and why Aquinas collect information from you when you use our services;
Who we share your information with, why and on what basis;
What your rights over your data are.


Who We Are

We are Aquinas (School Attendance Provisions) Ltd, a limited company registered in England and Wales, company number 09685968.
Our registered address is Key Road, Clacton-On-Sea, Essex, CO15 3DA.
We are accredited under the national Community Safety Accreditation Scheme (CSAS).
You can email us at chris.koutas@aquinasprovisions.org and you can telephone us on 07717768993
Our data protection officer is Chris Koutas, Managing Director.
We are the Data Controller for any personal data for any personal data you give to us.
We are a Data Processor of information passed to us from Education Establishments in relation to assessments and progressing student attendance concerns, and for the purposes of a public task under the CSAS.


How we collect you personal data

1. ​If you are a parent or guardian and your child has been referred to us by their school, we will be passed information about you and your child by the school. They should have already made you aware of this process and what information they will have shared with us, but it will include at least:


You name and postal address;
Your telephone and/or mobile phone number;
Your child’s name, date of birth and attendance record;
During our assessment process we may collect additional information about you directly from you.

We will process this information under our own and your Legitimate Interests to meet a schools Legal Obligation. The information will be used only to perform our assessment and create a plan to address any issues and will be retained until your child transitions from their current school.

2. If you are a professional involved in safeguarding children, a medical professional, legal professional or other person involved in the attendance process or child welfare, we will hold:


Your name, agency and postal address;
Contact telephone number and/or mobile phone number;
The services you provide and any children we are aware of that you are working with.

We will process this information under our own Legitimate Interests to meet a schools Legal Obligation. The information will be used only to perform our assessment and execute a plan to address any issues and will be retained until the child’s 18th birthday as we are required to do to allow schools to comply with their legal obligations.

3. When you make a direct or online enquiry to us

When you submit an enquiry via our website, or correspond with us by telephone, email, letter or otherwise we ask for your name, school name/local authority/organisation, email address, telephone number and job title.

We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered your query to your satisfaction. We will do this based on our performance of a contract to respond to you and provide accurate information prior to our engagement to perform services for you.

More about how long we keep information about you?

In all cases our need to use your personal information will be reassessed on a regular basis and information which is no longer required will be securely disposed of.

Other than specified above, we will only keep your personal information for as long as reasonably necessary to fulfil the purpose(s) it was collected for, and to comply with our or our clients legal, regulatory and contractual obligations. The time period we retain your personal information for may differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our own or our client’s regulatory obligations. We typical keep pupil data only until the end of their full-time education however in some cases, such as if there is a dispute or legal action, we may be required to keep personal information for longer until those proceedings have concluded, and no further appeals or proceedings are possible.

We may additionally keep your personal information for up to seven years from the date any contract with you comes to an end as we are legally required or entitled to do so under our legitimate interests.

How and where we store or transfer your personal data

We will store your personal data in the UK, or upon secure encrypted servers hosted outside of the EEA with contracts and recognised adequacy agreements in place with those providers or countries, such as Canada. This means that your information will be fully protected under the GDPR.

The security of your personal data is essential to us and to protect it from unauthorised access, use, loss or disclosure, we take a number of important measures, including the following:

Hard copy personal data is stored in locked cabinets with controlled access by the school;
Our computer hardware is encrypted and all file storage and access are also encrypted which means that no data is held unencrypted on computers, laptops or other electronic devices;
Technical support and system back-ups are in place. This means that should our systems encounter difficulties, our tech support will respond same day and ensure robust measures are taken to secure data.

Sharing information

It is a necessary part of our service to work with a number of trusted partners to support parents and their children’s education. Your information may be shared with suppliers, education and local authorities, agencies and businesses, to help us to perform our consultation, attendance casework and training services for our partners. These third parties are prohibited from using your personal information or any purpose other than in relation to these services and to adhere to our privacy and data protection policies.

We will only disclose your information with other third parties with your explicit consent with the exception of the following categories of third parties:

Educational institutions (e.g. schools, local authorities and children’s social care), regulatory authorities (including recognised practitioner bodies), the department of education and Ofsted);
Health service providers in relation to your child’s physical or mental health (e.g. GP’s, psychology, psychiatry, psychotherapy or other specialists);
Legal or crime prevention agencies, youth offending and HM Courts to comply with any legal and regulatory issues, disclosures, prosecution or bringing or defending legal claims;
Any IT service providers, document management providers, contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential.


What are your rights?

You are entitled to request the following from Aquinas, free of charge. These are called your Data Subject Rights and to learn more about these, please see the Information Commissioners website https://ico.org.uk/your-data-matters/

Your information is just that, yours. To ensure we protect the confidentiality of your information, we may ask you to verify your identity, and if necessary, your authority to make a request before we proceed with that request. If you are authorising another person to make a request on your behalf, we will ask them to prove they have your permission to act. This must be a written authority to make the request or it might be a more general power of attorney.

Subject to some legal exceptions, you (or your authorised representative) have the right to:

The right to be informed (Part 12).
The right of access (Part 13);
The right to rectification (Part 14);
The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
The right to restrict processing (Part 16);
The right to data portability (Part 17);
The right to object (Part 18); and
Rights with respect to automated decision-making and profiling (Parts 19 and 20).


Questions and queries

We understand that some people may have questions, would like more clarity on how we handle their personal information, or may wish to make a Data Subject Request.

If you have any questions or queries which are not answered by this Privacy Policy, or have any concerns about how we may use the personal data we hold, please contact chris.koutas@aquinasprovisions.org

CHANGES TO THIS PRIVACY POLICY

We regularly review and, update this Privacy Policy to ensure that we meet the highest standards of transparency, accountability and to protect your privacy. We will try to ensure that anyone whose data we hold, are informed of any significant changes to our processing that may affect them, either directly or by a notice on our website homepage. We would in any event, encourage you review this Privacy Policy periodically to ensure that you are aware of any changes may have been made.

If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

This Privacy Policy is version 202101-01 and is effective from the 1st January 2021.

Complaints

We try our best to be transparent and treat the information we hold with the strictest of confidence and in adherence with our legal obligations. We encourage you to discuss any issues or concerns with our Data Protection Team, and if we cannot resolve your query to your satisfaction, you may then raise this with the UK supervisory authority, the Information Commissioners Office (ICO).

You can contact the ICO by:

Telephone on 0303 123 1113;
Via their website at www.ico.org.uk/concerns;
Write to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.