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Privacy Policy

1. Introduction

Under UK data protection law, individuals have a right to be informed about how we use any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about visitors to Coombe House School (the “School”) and Dorset Centre of Excellence (the “Company”) who are required to sign in using the visitor system.

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

Dorset Centre of Excellence Limited
Donhead St Mary
Shaftesbury
SP7 9LP
United Kingdom

Telephone: 01747 449 860
Email: office@dorsetcentreofexcellence.org.uk

www.dorsetcentreofexcellence.org.uk
www.coombehouseschool.org.uk

The contact details of the designated data protection officer (DPO) for the company are listed below:

Quality Assurance Officer

Dorset Centre of Excellence Limited
Donhead St Mary
Shaftesbury
SP7 9LP

Email: – dpo@dorsetcentreofexcellence.org.uk


    2. The personal data we hold

      The personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

      • Name
      • Contact details
      • Information relating to the visit, e.g. company or organisation name, arrival and departure time, and vehicle registration number.
      • If a regular professional visitor, evidence that the individual holds an Enhanced Disclosure and Barring Service certificate.

      We may also collect, use, store and share (when appropriate) information about you that falls into ‘special categories’ of more sensitive personal data. This includes, but is not restricted to:

      • Disability, health and access requirements
      • Photographs for identification purposes
      • CCTV images captured on the property grounds

      We may also hold data about you that we have received from other organisations, including other schools and social services.

      3. Why we use this data

        We use the data listed above to:

        a) Identify you and keep you safe whilst visiting the site

        b) Keep pupils and staff safe

        c) Maintain accurate records of visits to the School and Company

        d) Provide appropriate access arrangements

          3.1 Use of your personal data for marketing purposes

          Where you have given us consent to do so, we may send you marketing information by email or text promoting school events, campaigns, charitable causes or services that may be of interest to you.

          You can withdraw consent or ‘opt out’ of receiving these emails and/or texts at any time by clicking on the ‘Unsubscribe’ link at the bottom of any such communication, or by contacting us (see ‘Contact us’ below).

          3.2 Use of your personal data in automated decision making and profiling

          We do not currently process any visitors’ personal data through automated decision making or profiling. If this changes in the future, we will amend any relevant privacy notices in order to explain the processing to you, including your right to object to it.

          4. Our lawful basis for using this data

            We only collect and use your personal data when the law allows us to. Most commonly, we process it where we need to comply with our legal obligation to keep our pupils and staff safe.

            Less commonly, we may also process your personal data in situations where:

            • We need it to perform an official task in the public interest
            • We have obtained consent to use it in a certain way
            • We need to protect someone’s vital interests (save your life, or someone else’s)

            Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you would go about withdrawing consent if you wish to do so.

            Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the processing of your data.

            4.1 Our basis for using special category data

            For ‘special category’ data, we only collect and use it when we have both a lawful basis, as set out above, and one of the following conditions for processing as set out in UK data protection law:

            • We have obtained your explicit consent to use your personal data in a certain way
            • We need to perform or exercise an obligation or right in relation to employment, social security or social protection law
            • We need to protect an individual’s vital interests (i.e. protect your life or someone else’s life), in situations where you are physically or legally incapable of giving consent
            • The data concerned has already been made manifestly public by you
            • We need to process it for the establishment, exercise or defence of legal claims
            • We need to process it for reasons of substantial public interest as defined in legislation
            • We need to process it for health or social care purposes, and the processing is done by, or under the direction of, a health or social work professional or by any other person obliged to confidentiality under law
            • We need to process it for public health reasons, and the processing is done by, or under the direction of, a health professional or by any other person obliged to confidentiality under law
            • We need to process it for archiving purposes, scientific or historical research purposes, or for statistical purposes, and the processing is in the public interest

            For criminal offence data, we will only collect and use it when we have both a lawful basis, as set out above, and a condition for processing as set out in UK data protection law. Conditions include:

            • We have obtained your consent to use it in a specific way
            • We need to protect an individual’s vital interests (i.e. protect your life or someone else’s life), in situations where you are physically or legally incapable of giving consent
            • The data concerned has already been made manifestly public by you
            • We need to process it for, or in connection with, legal proceedings, to obtain legal advice, or for the establishment, exercise or defence of legal rights
            • We need to process it for reasons of substantial public interest as defined in legislation

            5. Collecting this data

              While the majority of information we collect about you is mandatory, there is some information that can be provided voluntarily.

              Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.

              We will only collect the data that we need in order to fulfil our purposes, which are set out above.

              6. How we store this data

                We keep personal information about you while you are visiting our premises. We may also keep it beyond your visit if this is necessary, to comply with our legal obligations. Our Data Retention and Disposal procedure and guidance sets out how long we keep information about visitors. You can request a copy of our guidance from our Quality Assurance Officer whose contact details are at the end of this document.

                We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

                We will dispose of your personal data securely when we no longer need it.

                7. Who we share data with

                  We do not share information about you with any third party without consent unless the law and our policies allow us to do so.

                  Where it is legally required, or necessary (and it complies with UK data protection law), we may share personal information about you with:

                  • Our local authority – to meet our legal obligations to share certain information with it, such as where visitor information is relevant to a safeguarding concern
                  • The Department for Education
                  • Central and local government
                  • Ofsted
                  • Educators and examining bodies
                  • Suppliers and service providers – to enable them to provide the service we have contracted them for, such as catering provision or visitor management system.
                  • Our auditors
                  • Survey and research organisations
                  • Health authorities
                  • Security organisations
                  • Health and social welfare organisations
                  • Professional advisers and consultants
                  • Charities and voluntary organisations
                  • Police forces, courts or tribunals – to assist them discharging their legal duties
                  • Professional bodies
                  • The organisation/company you are representing

                  7.1 Transferring data internationally

                  Where we transfer your personal data to a third-party country or territory, we will do so in accordance with UK data protection law.

                  In cases where we have to set up safeguarding arrangements to complete this transfer, you can get a copy of these arrangements by contacting us.

                  8. Your rights

                    8.1 How to access personal information that we hold about you

                    You have a right to make a ‘subject access request’ to gain access to personal information that we hold about you.

                    If you make a subject access request, and if we do hold information about you, we will (subject to any exemptions that may apply):

                    • Give you a description of it
                    • Tell you why we are holding and processing it, and how long we will keep it for
                    • Explain where we got it from, if not from you
                    • Tell you who it has been, or will be, shared with
                    • Let you know whether any automated decision-making is being applied to the data, and any consequences of this
                    • Give you a copy of the information in an intelligible form

                    You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.

                    If you would like to make a request, please contact us (see ‘Contact us’ below).

                    8.2 Your other rights regarding your data

                    Under data protection law, you have certain rights regarding how your personal data is used and kept safe. For example, you have the right to:

                    • Object to our use of your personal data
                    • Prevent your data being used to send direct marketing
                    • Object to and challenge the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person)
                    • In certain circumstances, have inaccurate personal data corrected
                    • In certain circumstances, have the personal data we hold about you deleted or destroyed, or restrict its processing
                    • Withdraw your consent, where you previously provided it for the collection, processing and transfer of your personal data for a specific purpose
                    • In certain circumstances, be notified of a data breach
                    • Make a complaint to the Information Commissioner’s Office
                    • Claim compensation for damages caused by a breach of the data protection regulations

                    To exercise any of these rights, please contact us (see ‘Contact us’ below).

                    9. Complaints

                      We take any complaints about our collection and use of personal information very seriously.

                      If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

                      Alternatively, you can make a complaint to the Information Commissioner’s Office:

                      • Report a concern online at https://ico.org.uk/make-a-complaint/
                      • Call 0303 123 1113
                      • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5A

                      10. Contact us

                        If you have any questions or concerns, or would like more information about anything mentioned in this privacy notice, please contact our quality assurance officer by emailing 

                        11. Version control

                          Date of adoption of this notice, by or on behalf of the Proprietor

                              June 2023

                          Date of last review of this notice                                                          

                              August 2023

                          Date for next review of this notice

                              May 2024

                          Notice owner (Proprietor)                                                                        

                              Dorset Centre of Excellence


                          Use of Email Tracking Pixels

                          All emails sent by the system contain a tracking pixel. This is used to track whether each email has been opened by the recipient, and when. This information can be viewed by those users of the system with permission to view email delivery reports. We do not display any information regarding the location of the recipient. Note that the tracking pixel is only activated if the recipient chooses to download images into their email client.

                          Data Processor

                          We, Coombe House Leisure, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our myClubhouse website in accordance with our privacy policy set out above. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here: http://www.myclubhouse.co.uk/Home/PrivacyPolicy.

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