Last Updated 23.05.18

St Columba's School Ltd. is an HMC coeducational independent day school for pupils aged 3–18. St Columba’s School is a company limited by guarantee, registered in Scotland, with the company registration number SC016856 and a charity registered in Scotland with the charity registration number SC012598 and whose registered office is located at St Columba’s School, Knockbuckle Road, Kilmacolm, PA13 4EQ.

The school has adopted a collegiate approach to data protection with a range of staff taking responsibility for specific areas of expertise. 

If you have any enquiries about this policy, please contact us at:
St Columba’s Senior School,Duchal Road, Kilmacolm, PA13 4AU.
St Columba’s Junior School, Knockbuckle Road, Kilmacolm, PA13 4EQ. 

Alternatively, please e-mail us at dataprotection@st-columbas.org. This will allow us to direct your enquiry to the most appropriate members of our data protection staff.

About this Privacy Policy
At St Columba’s School we will treat any personal information you provide in accordance with the law. Most significantly, this is relation to the General Data Protection Regulation (EU 2016/679) and the UK Data Protection Act 2018. The privacy of all personal data belonging to our school community is important to us.

This Policy will provide information about how the School processes personal data about individuals including: our staff; our current, past and prospective pupils; and our pupils’ parents, carers or guardians (referred to in this Policy as "parents").

Under Data Protection Law, you have a right to know how your data is processed. Staff, parents and pupils are encouraged to read this Privacy Policy and understand the School’s obligations and responsibilities to our entire community.

This Privacy Policy applies alongside any other information the School may provide about the use of personal data, for example when collecting data via an online or paper form. The Policy also covers all personal data regardless of the media on which it is stored. 

This Privacy Policy also applies in addition to the School’s other relevant terms and conditions, policies and working practices, including:
• any contract between the School and their staff or the parents of pupils, including the Enrolment Agreement;
• the policy on Taking, Storing and Using Images of Children;
• the CCTV policy;
• the Biometrics policy;
• the Data Retention policy;
• the Child Protection policy;
• Data sharing agreements with Third Parties
• School Trips and Visits Policy
• the Data Protection policy for staff;
• the Health and Safety policy;
• the Security policy;
• ICT policies, including the Acceptable Use (Computers) policies

Anyone who works for or acts on behalf of the School (including staff, volunteers, governors and service providers) should also be aware of, and comply with, this Privacy Policy. Staff who handle personal data will receive suitable training. 

Why the School Needs to Process Personal Data
As part of our daily operations, and in order to carry out our ordinary duties to pupils, parents and staff, the School may process a wide range of personal data about individuals (including current, past and prospective staff, pupils or parents).

Some of this activity is carried out so that the School can fulfil our legal rights, duties or obligations – including those under a contract with staff, or parents of their pupils.

Other uses of personal data will be made in accordance with the School’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.

The School expects that the following uses may fall within the category of our or our community’s ‘legitimate interests’:
• For the purposes of pupil selection (and to confirm the identity of prospective pupils and their parents);
• To provide education services, including musical education, physical training or spiritual development, career services and extra-curricular activities to pupils, and monitoring pupils' progress and educational needs;
• Maintaining relationships with alumni and the school community, including direct marketing or fundraising activity;
• For the purposes of donor due diligence, and to confirm the identities of prospective donors and their backgrounds and relevant interests;
• For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as diversity or gender pay gap analysis and taxation records);
• To enable relevant authorities to monitor the performance of the School and to intervene or assist with incidents as appropriate;
• To give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils;
• To enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the School;
• To safeguard pupils' welfare and provide appropriate pastoral care;
• To monitor (as appropriate) use of the School’s IT and communications systems in accordance with the Acceptable Use Policy;
• To make use of photographic and video recorded images of pupils internally in school publications, and on the School’s intranets in accordance with the policies on taking, storing and using images of children.
• To make use of photographic and video recorded images of pupils externally, online and in print, for example in newspapers or magazines, on the School’s website and official social media channels for marketing purposes or to celebrate the achievements of pupils and in accordance with the School’s policies on taking, storing and using images of children and use of social media;
• For security purposes, including CCTV in accordance with the School’s CCTV policy; and
• Where otherwise reasonably necessary for the School’s purposes, including to obtain appropriate professional advice and insurance for the School.

Special Category Personal Data (Sensitive Data)
In addition, the School may need to process special category personal data (concerning health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when carrying out Disclosure Scotland checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required. These reasons will include:
• To safeguard pupils' welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition or other relevant information where it is in the individual's interests to do so: for example, for medical advice, for social protection, safeguarding and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a pupil;
• In connection with employment of our staff, for example Disclosure Scotland checks, welfare or pension plans;
• To run any of our systems that operate on biometric data, such as for lunch or the library;
• As part of any school or external complaints, disciplinary or investigation process that involves such data, for example if there are SEN, health or safeguarding elements; or
• For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with our legal obligations and duties of care.

Types of Personal Data
This will include by way of example:
• names, addresses, telephone numbers, email addresses and other contact details;
• car details;
• biometric information, which will be collected and used by the School in accordance with their Biometrics policy
• bank details and other financial information, e.g. about parents who pay fees to the School
• past, present and prospective pupils’ academic, disciplinary, admissions and attendance records (including information about any special needs) and examination scripts and marks;
• personnel files, including in connection with academics, employment or safeguarding;
• where appropriate, information about individuals’ health, and contact details for their next of kin;
• references given or received by the School about pupils and staff and information provided by previous educational establishments and/or other professionals or organisations working with individuals; and
• images of pupils (and occasionally other individuals including staff and parents) engaging in school activities, and images captured by the CCTV system (in accordance with the School’s policies on the use of CCTV, taking, storing and using images of children and social media);

How the School Collects Data
Generally, the School receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments). 

In some cases, personal data may be supplied by third parties (for example another school, or other professionals or authorities working with that individual); or collected from publicly available resources.

At the point of data collection we remind Data Subjects of their rights and the purposes for which the data may be used. If data being collected is of a sensitive nature, specific consent is sought. 

Who Has Access to Personal Data
Occasionally, the School will need to share personal information relating to our community with third parties, such as the SQA and the NHS.
Mostly, personal data collected by the School will remain within the School and will be processed and seen by appropriate individuals in accordance with their ‘need-to-know’. Particularly strict rules of access apply in the context of:
• medical records held and accessed only by appropriate medical staff or those under their supervision, or otherwise in accordance with express consent; and
• pastoral or safeguarding files.

If you complete a form to contact us through this website, we will normally store the information provided in a database. This information will be passed to one or more departments within the school in order to ensure that your enquiry is dealt with in the most appropriate way. We will not sell, trade or offer this information to others.

In order that we may provide an appropriate education for pupils with Special Educational Needs (SEN) we will need to provide staff with relevant information.

Staff, pupils and parents are reminded that the School is under duties imposed by law and statutory guidance, including that set out in the Children’s Hearings (Scotland) Act 2011 (implemented in 2013), the National Guidance for Child Protection in Scotland 2014 and the Children and Young People (Scotland) Act 2014, to record or report incidents and concerns that arise or are reported to them, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files and, in some cases, referrals to relevant authorities. For further information about this, please enquire about our Child Protection Policy.

Finally, in accordance with Data Protection Law, some of the School’s processing activity is carried out on their behalf by third parties, such as Information Management systems, web developers or cloud storage providers. This is always subject to Data Sharing Agreements or contractual assurances that personal data will be kept securely.

How Long We Keep Personal Data
The School will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the School will keep ordinary pupil records for up to 7 years following departure from the School and staff records for up to 10 years following the end of their employment with the School. Incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements. Some routine information (such as class test results) may be kept for a much shorter period. Individual Departments or Faculties will review data being stored on an annual basis.

If you have any specific queries about how this policy is applied, or wish to request that personal data which you no longer believe to be relevant is considered for deletion or erasure, please contact the School at dataprotection@st-columbas.org. However, please bear in mind that the School may have lawful and necessary reasons to hold on to some personal data even following such a request.

A limited and reasonable amount of information will need to be kept. For example, even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").

Keeping in Touch and Supporting the School 
The School would like to use the contact details of parents, alumni and other members of the school community to keep them updated about the School’s interesting events. This will include sending updates and newsletters, by email and by post. 

Should you wish to limit our contact or object to any such use of your personal data, or would like further information about it, please contact the Marketing Manager or Development Manager in writing at our Senior School address.  You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the School is nonetheless likely to retain some of your details as “suppression records” (to ensure that no more communications are sent to that particular address, email or telephone number).

Your Rights
Rights of Access
Individuals have various rights under Data Protection Law (subject to certain exemptions and limitations) to access personal data about them held by the School. In some cases, you can ask for it to be erased or amended or have it transferred to others, or for the School to stop processing it.

Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the school.

The School will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within the statutory time limits (30 days in the case of requests for access to information).

The School will be better able to respond quickly to smaller, targeted requests for information. We are very willing to fulfil our obligations so please help us by being as specific as possible. 

Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations), or information which is subject to legal privilege (for example legal advice given to or sought by the School, or documents prepared in connection with a legal action).

The School is also not required to disclose any pupil examination scripts (or other information consisting solely of pupil test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference given by the School for the purposes of the education, training or employment of any individual. We are in most cases happy to discuss academic performance and parents wishing to discuss issues should contact House staff in line with our normal procedures.

However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Policy.  All such requests will be considered on their own merits.

Pupil Requests 
A version of the Privacy Policy has been made specifically for pupils. At St Columba’s School, we believe that teaching pupils about their data rights is a significant part of their education in the modern world. Heads of House or class teachers are willing to discuss any reasonable data protection issues and data rights with pupils.

Pupils can make subject access requests for their own personal data. If they have, in the reasonable opinion of the School, sufficient maturity to understand the request they are making then the request will be respected. A pupil of any age may ask a parent or other representative to make a subject access request on his/her behalf.

Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of younger pupils, the law still considers the information in question to be the child's. For older pupils, the parent making the request may need to provide evidence of their child's authority for the specific request.

Pupils at Senior School are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Slightly younger children/older Junior School children may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.

Parental requests
Parents will often have a legitimate interest or expectation in receiving certain information about pupils without their consent. The School may consider there are lawful grounds for sharing that information with or without reference to that pupil. 

Parents will in general receive education and pastoral updates about their children, in accordance with the Enrolment Agreement. Where parents are separated, the School will aim to provide information to each parent or legal guardian with parental responsibility, in accordance with choices indicated in the Enrolment Agreement, but may need to factor in all the circumstances, including the express wishes of the child.  

Consent 
Where the School is relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations).  Examples of when we do rely on consent are: biometrics, certain uses of images, certain types of fundraising activity. Please be aware however that the School may not be relying on consent but have another lawful reason to process the personal data in question.

That reason will usually have been asserted under this Privacy Policy, or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents’ association has been requested).

Whose Rights?
Rights under Data Protection Law belong to the individual to whom the data relates. However, the School will often rely on parental authority or notice for the necessary ways they process personal data relating to pupils – for example, under the parent contract, or via a form. Parents and pupils should be aware that this is not necessarily the same as the School relying on strict consent (see section on Consent above).

Where consent is required, it may in some cases be necessary or appropriate – given the nature of the processing in question, and the pupil's age and understanding – to seek the pupil's consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the child, the parents' rights at law or under their contract, and all the circumstances.
In general, the School will assume that pupils’ consent is not required for ordinary disclosure of their personal data to their parents, e.g. for the purposes of keeping parents informed about the pupil's activities, progress and behaviour, and in the interests of the pupil's welfare. That is unless, in the opinion of the School, there is a good reason to do otherwise.

However, where a pupil seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to their parents, the School may be under an obligation to maintain confidentiality unless, in the School’s opinion, there is a good reason to do otherwise; for example, where the School believe disclosure will be in the best interests of the pupil or other pupils, or if required by law.

Pupils are required to respect the personal data and privacy of others, and to comply with the School’s ICT Acceptable Use policy for pupils and the school rules. Staff are under professional duties to do the same covered under the ICT Acceptable Use policy for staff, Data Protection policy, policy on Taking, Storing and Using Images of Children and Social Media Policy. 

Data Accuracy and Security 
The School will endeavour to ensure that all personal data held in relation to an individual is as up- to-date and accurate as possible. Individuals must notify the School of any significant changes to important information, such as contact details, held about them.

An individual has the right to request that any out-of-date, irrelevant or inaccurate information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the School may need to process your data, and whom you may contact if you disagree.

The School will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around the use of technology and devices, and access to school systems. All staff and governors will be made aware of these policies and their duties under Data Protection Law and will receive relevant training.

This Policy 
The School will update this Privacy Policy from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable. 

Queries and Complaints 
Any comments or queries on this policy should be directed to 
dataprotection@st-columbas.org.

An individual has the right to lodge a formal complaint with the Information Commissioner’s Office (ICO), but the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator.

If you feel that we have not acted in accordance with your Data Privacy Rights, please inform us and let us rectify the matter as promptly as we can. 

Cookie Policy 
Last Updated: 23.5.2018 

Thank you for visiting St Columba’s School.  

We hope that you enjoy using our site. We’ve prepared this Cookie Policy to help you better understand and to feel more confident about how we use cookies on our site located at: www.st-columbas.org. We have tried to keep this document as short as we legally can. However, the full text wording is important and legally binding. Please read the following carefully to understand our views and practices regarding cookies and how we use them when you visit our site. 

For convenience, we have divided our data protection policies into two separate pages:

1. Our Privacy Policy  
You can find our privacy policy above which explains generally how we collect, use, store, and protect your personal information. 
 
2. Our Cookie Policy 
This policy explains more about how we may collect personal information about you via cookies (it also explains what cookies are). 
 
If you have any questions please do not hesitate to contact us at dataprotection@st-columbas.org or, if you prefer to call or write to us, then you can find our contact details at the bottom of this page. 

Who We Are 
St Columba’s School Ltd is a company limited by guarantee registered in Scotland with the company number SC016856 and a charity registered in Scotland with the charity number SC012598. Our registered office is at St Columba’s School, Knockbuckle Road, Kilmacolm, PA13 4EQ.  

But, for the purposes of this Cookie Policy, it’s just easier if we refer to ourselves as “we”. 
 
What is a Cookie 
We use various technologies on our site to collect information that helps us improve your online experience. We refer to these technologies which include cookies, collectively as “cookies”. This Cookie Policy explains the different types of cookies used on our site and how you can control them. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device. Cookies are widely used throughout the Internet in order to make sites or other online services work or to be better or more efficient. They can do this because sites and other online services can read and write to the cookies stored on your device, enabling them to recognise you and remember important information that will make your use of them more convenience, for example, by remembering your preferences, username, or showing you pages that you seemed to have a particular interest in. 

If you consent to us storing cookies on your computer or other electronic device then you agree that we can store and access cookies as described in this policy. 

How You Consent To Us Placing Cookies 
When you visit our site you should see a pop-up directing you to this Cookie Policy and our Privacy Policy. 

By clicking or selecting the “I Agree” button that appears in the pop-up then you are demonstrating to us that you are freely giving us informed and specific consent for us to place cookies on your device for the purposes specified in this Cookie Policy and you are accepting and consenting to the practices described. 

If you do not click or select the “I Agree” button that appears in the pop-up then we will not place cookies on your device.

If you do not see a pop-up then you may have already accepted our Cookie Policy and our Privacy Policy. You may also be using a pop-up blocker or similar tools that may prevent this policy from being brought to your attention. Please ensure that any pop-up blockers are disabled when you use our site. If you’re unsure then scroll down to the bottom of this page where we explain how you can manage your cookies. 
 
What Do You Use Cookies For? 
Our site uses cookies to distinguish you from other users of our site and to save and retain certain parameters about you and your usage of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. 
There are two different categories of cookies that we may use on our site:   

Essential cookies: These are cookies that are essential for the operation of our site. They include, for example, cookies that enable the site to work correctly on a mobile device or display the correct information regarding the calendar. These cookies are essential for using our site and, therefore, if disabled can severely affect your use of our site.

Analytical/performance cookies: Performance cookies allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily. These cookies also allow us to see overall patterns of usage on our site and help us record any difficulties you may have with our site.

If you would like more information about cookies and how you can manage the settings on your computer, you can visit http://www.allaboutcookies.org/manage-cookies/.
 
Cookies We Use 
You can find more information about the individual cookies we use on our site and the purposes for which we use them in the table below: 

Third Parties 
Please note that third parties (including, for example, web traffic analysis services such as Google Analytics) may also use cookies, over which we have no control. 

How Do I Control Cookies? 
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. You may also delete any cookies stored on your computer at any time. 

You can find out more about changing cookie settings on your computer by visiting http://www.allaboutcookies.org/manage-cookies/. 

How Long is Cookie Information Stored? 
Different cookies may be stored for different periods of time. In many cases these cookies are updated automatically each time you visit our site or may expire and be deleted by your computer automatically. It is important to understand that when a cookie is placed on your computer it will reside on your hard drive until it expires and is deleted or it may reside on your hard drive until you manually delete it – this entirely depends on your individual browser settings and we do not have control over this. 

Please remember that you can delete or change the way in which you store cookies on your computer at any time. 

Changes to our Cookie Policy 
We may need to change this Cookie Policy if it’s necessary for legal reasons or to reflect changes to our services or the purpose for which we use cookies. In any case, the provisions of this Cookie Policy may be changed without prejudice to your rights. When we change our Cookie Policy we will make the updated Cookie Policy available on our site and we will also update the “Last Updated” date at the top of this page. 

Any changes to our Cookie Policy will come into effect 30 days after we post it on our site. During that period you’re welcome to contact us if you have questions about the changes. If you have an account for our site then we may reset your login and seek new consent if there is a change in the purpose for which we may use cookies. 

More About Your Privacy 
Please also check out our Privacy Policy above which gives more information about how we protect your privacy. 

Contact Us 
If you have any questions, comments or requests regarding our Cookie Policy then please do not hesitate to get in touch with us. Queries should be directed to: 
 
Head of Finance & Operations
St Columba’s School Ltd
Knockbuckle Road
Kilmacolm
PA13 4EQ

Email: dataprotection@st-columbas.org.