Privacy Policy

How We Use Your Information
Privacy Notice for Parents

Clowns Nursery
May 2018

Parent Privacy Notice – Key Information

This information contains the key information how and why we collect your personal information and what we do with that information. Personal information is information that identifies you and relates to you.

If you have any questions about this notice please contact the Operations Manager.

What is personal information?
Personal information is information that identifies you as an individual and relates to you.

This includes your contact details, next of kin and financial information. We may also hold information such as your religion or ethnic group. CCTV recordings and photos are also personal information.

How and why does Clowns collect and use personal information?

We set out below examples of different ways in which we use personal information and where this personal information comes from. Clowns’ primary reason for using your personal information is to provide educational services to your child. We have reviewed the information that we hold to ensure that we only collect and process personal information where we have a lawful basis to do so, for example, where it is necessary for the legitimate interests of the running of Clowns and/or legally required.

• We obtain information about you from our registration form.
• We may have information about any family circumstances which might affect your child’s welfare or happiness.
• We use CCTV outside Clowns to make sure the nursery site is safe. CCTV is not used in private areas such as toilets. CCTV policy is available upon request.
• We will send you information to keep you up to date with what is happening at Clowns. For example, by sending you information about activities taking place (e.g. fundraising events) and/or term dates.
• We will process financial information about you in relation to the payment of fees.

Sharing personal information with third parties

• In accordance with our legal obligations, we may share information with local authorities, for example, where we have any safeguarding concerns.
• On occasion, we may need to share information with the police.
• We may also need to share information with our legal advisors for the purpose of obtaining legal advice.
• We may share some information with our insurance company, for example, where there is a serious incident at Clowns.
• When your child leaves us to attend school or another nursery, we may need to provide that school with information about you.
• We may share information about you with others in your family, such as another parent or step-parent. For example, where this is part of our obligation to take care of your child, as part of our wider legal and regulatory obligations, or in connection with school fees.
• We will need to share information if there is an emergency, for example, if you are hurt whilst on Clowns’ premises.

Our legal grounds for using your information

This section contains information about the legal basis that we are relying on when handling your information.

Legitimate interests
This means that the processing is necessary for legitimate interests except where the processing is unfair to you. Clowns relies on legitimate interests for most of the ways in which it uses your information.

Specifically, Clowns has a legitimate interest in:
• Providing educational services to your child;
• Safeguarding and promoting the welfare of your child (and other children);
• Promoting the objects and interests of Clowns. For example, so that we can contact you if unpaid fees are due;
• Facilitating the efficient operation of Clowns; and
• Ensuring that all relevant legal obligations of Clowns are complied with.

Necessary for a contract
We will need to use your information in order to perform our obligations under our contract with you. For example, we need your name and contact details so that we can update you on your child’s progress and so that we can contact you if there is a concern.

Legal obligation
Where Clowns needs to use your information in order to comply with a legal obligation, for example to report a concern to Children’s Services. We may also have to disclose your
information to third parties such as the courts, the local authority or the police where legally obliged to do so.

Public interest
Clowns considers that it is acting in the public interest when providing education.

Clowns must also comply with an additional condition where it processes special categories of personal information. These special categories are as follows: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information and information about sex life or orientation. In these cases, we may rely on the following legal bases for handling your information:

Substantial public interest
The processing is necessary for reasons of substantial public interest.

Vital interests
To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.

Legal claims
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.

Medical purposes
This includes medical treatment and management of healthcare services.

We may ask for your consent to use your information in certain other ways. If we ask for your consent to use your personal information you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please speak to the Operations Manager if you would like to withdraw any consent given.

Sending information to other countries

We may send your information to other countries where we communicate with you when you are overseas (for example, during the summer holidays).

The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

If the country that we are sending your information to is not on the list or is not a country within the EEA then it might not have the same level of protection for personal information as there is in the UK.

For how long do we keep your information?

We keep your information for as long as we need to in order to educate and look after your child. We will keep some information after your child has left Clowns, for example, so we can find out what happened if you make a complaint.

In exceptional circumstances we may keep your information for a longer time than usual but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.

What decisions can you make about your information?

From May 2018 data protection legislation gives you a number of rights regarding your information. Some of these are new rights whilst others build on your existing rights. Your rights include the following:
• If information is incorrect you can ask us to correct it.
• You can also ask what information we hold about you and be provided with a copy.
• You can ask us to delete the information that we hold about you in certain circumstances. For example, where we no longer need the information.
• Our use of information about you may be restricted in some cases. For example, if you tell us that the information is inaccurate we can only use if for limited purposes while we check its accuracy.

Further information and guidance

The Operations Manager is the person responsible at Clowns for managing how we look after personal information and deciding how it is shared.

Like other organisations, we need to keep your information safe, up to date, only use if for what we said we would, destroy it when we no longer need it and most importantly – treat the information fairly.

Please contact the Operations Manager if:
• You would like us to update the information we hold about you; or
• You have any questions.

Clowns Nursery also has an independent Data Protection Officer whom you can contact with queries or concerns at DPO@clownsnursery.co.uk

If you consider that we have not acted properly when using your personal information, you can contact the Information Commissioner’s Office – ico.org.uk

How We Use Your Child’s Information
Pupil Privacy Notice for Parents

Clowns Nursery
May 2018

Introduction

This information contains the key information how and why we collect your personal information and what we do with that information. Personal information is information that identifies your child as an individual and relates to your child. For example, information about your child’s progress at Clowns and any information that we need to take care of your child. Photographs of your child also count as their personal information.

We are giving you this notice because you are able to exercise your child’s data protection rights on their behalf. When your child is older (usually when they reach the age of 12) they will be considered mature enough to exercise their own data protection rights.

If you have any questions about this notice please contact the Operations Manager.

What is “personal information”?
Personal information is information that Clowns holds about your child and which identifies your child.

This includes information such as their name, date of birth, and address as well as things like medical details and progress records. Clowns may also record your child’s religion or ethnic group. CCTV, video recordings and photos of your child are also personal information.

How and why does Clowns collect and use personal information?

Clowns’ primary reason for using your personal information is to provide educational services to your child. We have reviewed the information that we hold to ensure that we only collect and process personal information where we have a lawful basis to do so, for example, where it is necessary for the legitimate interests of the running of Clowns and/or legally required.

We set out below examples of different ways in which we use personal information and where this personal information comes from.
• We need to tell all appropriate members of staff if your child is allergic to something or might need extra help with some tasks.
• We may need to report some of your child’s information to the government. For example, we will need to let the local authority know if we have any concerns about your child’s welfare.
• We will need information about any court orders which relate to your child. This is so that we can safeguard your child’s welfare and wellbeing and the other children at Clowns.
• Depending on where your child will go when they leave Clowns, we will need to provide their information to prospective schools. For example, we will share information about your child’s progress and provide references. We may need to pass on information which they need to look after your child.
• We will need to share information with the police or our legal advisers if something goes wrong or to help with an injury.
• We may share some information with our insurance company to ensure that we have the insurance cover that we need.
• We will share your child’s progress records with you so you can support their schooling.
• We will only share your child’s information with other people and organisations when we have a good reason to do so. In exceptional circumstances we may need to share it more widely than we would normally.
• We may use photographs of your child for School’s website, with your express permission. We may continue to use these photographs after your child has left the school.
• We use CCTV outside Clowns to make sure the nursery site is safe. CCTV is not used in private areas such as toilets. CCTV policy is available upon request.
• If you have any concerns or questions about the above, please speak to the Operations Manager.

Our legal grounds for using your information

This section contains information about the legal basis that we are relying on when handling your child’s information.

Legitimate interests
This means that the processing is necessary for legitimate interests except where the processing is unfair to you. Clowns relies on legitimate interests for most of the ways in which it uses your information.

Specifically, Clowns has a legitimate interest in:
• Providing your child with early years education;
• Safeguarding and promoting the welfare of your child (and other children);
• Promoting the objects and interests of Clowns;
• Facilitating the efficient operation of Clowns; and
• Ensuring that all relevant legal obligations of Clowns are complied with.

Legal obligation
This applies when Clowns needs to use your information in order to comply with a legal obligation, for example to report a concern to Children’s Services. We may also have to disclose your information to third parties such as the courts, the local authority or the police where legally obliged to do so.

Public interest
Clowns considers that it is acting in the public interest when providing education.
Clowns must also comply with an additional condition where it processes special categories of personal information. These special categories are as follows: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information and information about sex life or orientation. In these cases we may rely on the following legal bases for handling your child’s information.

Substantial public interest
The processing is necessary for reasons of substantial public interest.

Vital interests:
To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.

Legal claims
The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.

Medical purposes
This includes medical treatment and management of healthcare services.

We may ask for your consent to use your child’s information in certain other ways. If we ask for your consent to use your child’s personal information you can take back this consent at any time. Any use of your child’s information before you withdraw your consent remains valid. Please speak to the Operations Manager if you would like to withdraw any consent given.

Sending information to other countries
We may send your child’s information to other countries where we communicate with you when you are overseas (for example, during the summer holidays).
The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here:
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

If the country that we are sending your information to is not on the list or is not a country within the EEA then it might not have the same level of protection for personal information as there is in the UK.

For how long do we keep your information?

We keep your child’s information for as long as we need to in order to educate and look after your child. We will keep some information after your child has left Clowns, for example, so we can find out what happened if you make a complaint.

In exceptional circumstances we may keep your information for a longer time than usual but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.

What decisions can you make about your information?

From May 2018 data protection legislation gives you a number of rights regarding your child’s information. Some of these are new rights whilst others build on your child’s existing rights. Your child’s rights include the following:
• If information is incorrect you can ask us to correct it.
• You can also ask what information we hold about your child and be provided with a copy.
• You can ask us to delete the information that we hold about your child in certain circumstances. For example, where we no longer need the information.
• Our use of information about your child may be restricted in some cases. For example, if you tell us that the information is inaccurate we can only use if for limited purposes while we check its accuracy.

Further information and guidance

The Operations Manager is the person responsible at Clowns for managing how we look after personal information and deciding how it is shared.

Please contact the Operations Manager if:
• You would like us to update the information we hold about your child; or
• You have any questions.

Clowns Nursery also has an independent Data Protection Officer whom you can contact with queries or concerns at DPO@clownsnursery.co.uk.

If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner’s Office: ico.org.uk

Cookie Information

Our website uses cookies which allow us to monitor the use of our website. This is for general purposes only and the information we gather cannot be used to identify you as an individual.

We only use Google Analytics cookies on our website. We do not use any other third party cookies. By using this website you consent to the processing of data by Google Analytics cookies.

If you do not consent to the use of Google Analytics cookies, contact us at info@clownsnursery.co.uk – We will provide you with advice on how to reject the Google Analytics cookies via your browser. Please note that if you do this you may not be able to use the full functionality of this website.

For more information about cookies and the type of cookies our website uses, see the frequently asked questions we have prepared below.

FREQUENTLY ASKED QUESTIONS

What is a cookie?

A cookie is a small text file which is generated by a website and stored in a folder on your computer. The cookie stored is unique to your computer.

Why are cookies needed?

Cookies are needed to make websites work better. For example when you add an item to your shopping cart on the Amazon website the contents of the shopping cart are stored in the cookie. Another example would be when you log into a webmail service such as Hotmail or Gmail a cookie is generated that confirms you are logged in. When you log off the cookie is deleted. This means if someone goes back to your webmail address they will not be able to read your emails.

What cookies does Clowns Nursery use?

Clowns Nursery uses Google Analytics cookies to record visits to the website. This helps us to identify which parts of the website are popular and which are less so.

Why do Google need to know about my computer?

The information generated by Google Analytics cookies will be used to evaluate the use of this website. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

Google Analytics cookies DO

Identify a computer to a website
Store information generated by a website

Google Analytics Cookies DO NOT

Identify a computer’s owner to a website
Gather information from a computer

I still don’t want cookies on my PC – what can I do?

All major browsers have options that will restrict the use of cookies. However, in many cases this will limit the features you can use on a website. For details on how to block all cookies click here