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Privacy Policy

Teacher and staff privacy notice

Updated September 2026 | Version 2.0 | England

This notice explains how we use personal information about current and former teachers and other staff, and applicants where relevant, why we need it, who we share it with and the rights you have. You do not need to sign or consent to this privacy notice. Optional publicity choices are provided separately at the end.

Personalised for St Willibrord’s RC Primary School | 29 September 2026

Who is responsible for your information

School: St Willibrord’s RC Primary School. The data controller, which decides how and why personal information is used, is the Governing Body of St Willibrord’s RC Primary School (Voluntary Aided).

Controller contact: St Willibrord’s RC Primary School, Vale Street, Clayton, Manchester, M11 4WR; admin@st-willibrords.manchester.sch.uk; 0161 223 9345. Where another organisation controls particular records, we explain its role when relevant.

Our Data Protection Officer service is provided by Global Policing Limited.

Email: data@globalpolicing.co.uk.

Telephone: 0161 510 2999 (answerphone).

Website: www.globalpolicing.co.uk/data.

You may contact the school or the DPO about this notice or your rights.

We follow the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended, including by the Data (Use and Access) Act 2025.

Information we collect and where it comes from

We collect information from you, recruitment and supply agencies, referees, previous employers, qualification and vetting bodies, occupational health services, pension providers and relevant public authorities. We also create records while managing recruitment and employment. Information may include:

  • Identity, contact and emergency-contact details; date of birth, National Insurance and teacher reference numbers; right-to-work and suitability checks.

  • Applications, references, qualifications, experience, recruitment assessments and relevant publicly available professional information where lawfully checked.

  • Contracts, role, pay, bank and pension details, tax, working hours, attendance, leave, performance, training, grievances and disciplinary records.

  • Health and disability information, adjustments, ethnicity, religion and trade union information where needed and lawful; criminal record and safeguarding information subject to specific safeguards.

  • Photographs, communications and workplace system records where relevant. Age and sex are not, by themselves, special category data under UK GDPR.

Why we use information and our lawful bases

We use information to recruit suitable staff, administer employment and pay, provide support and adjustments, manage performance and workplace issues, protect pupils and staff, meet statutory duties and maintain a reliable workforce record.

Recruitment employment and statutory duties

Contract under Article 6(1)(b) applies where processing is necessary to take steps you request before entering into a contract or to perform our employment contract, such as administering contractual pay and benefits.

Legal obligation under Article 6(1)(c) applies to relevant employment, tax, pension, right-to-work, equality, health and safety, safeguarding and statutory reporting duties. Where applicable, workforce returns are made under the Education (Supply of Information about the School Workforce) (No. 2) (England) Regulations 2007, as amended.

Public task under Article 6(1)(e) may apply to necessary workforce administration supporting a maintained school’s or academy’s public education functions. St Willibrord’s is a maintained voluntary-aided school. The Governing Body is the employer and data controller for school workforce records. Public task under Article 6(1)(e) applies where necessary workforce administration supports the school’s public education, safeguarding and governance functions; Article 6(1)(c) applies where processing is necessary to meet a specific legal duty, and Article 6(1)(b) applies where processing is necessary for the employment contract. The school does not rely on Article 6(1)(f) legitimate interests to perform its public tasks. Any use outside those public functions would be separately assessed and documented before reliance on legitimate interests.

Sensitive and criminal record information

For special category information we also need an Article 9 condition. Necessary employment, social security and social protection processing, including relevant health and adjustment records, normally uses Article 9(2)(b) and Schedule 1 paragraph 1 of the Data Protection Act 2018. We keep an appropriate policy document where required.

Occupational health processing may use Article 9(2)(h) and Schedule 1 paragraph 2 where the required professional confidentiality safeguards apply. Necessary legal claims may use Article 9(2)(f). Safeguarding or equality monitoring may use Article 9(2)(g) with the appropriate Schedule 1 condition. Employment-related health, disability and adjustment processing normally uses Article 9(2)(b) with Schedule 1 Part 1 paragraph 1 where necessary to meet legal employment, social security or social protection obligations. Occupational health may use Article 9(2)(h) with Schedule 1 paragraph 2 where the required professional-confidentiality safeguards apply. Safeguarding uses Article 9(2)(g) with Schedule 1 Part 2 paragraph 18 where its requirements are met. Equality monitoring may use Article 9(2)(g) with Schedule 1 paragraph 8, or paragraph 6 for statutory functions, where applicable. The school maintains an Appropriate Policy Document where the relevant Schedule 1 condition requires one.

Criminal record and DBS information is subject to Article 10 and relevant domestic-law conditions. We limit access, record only what is necessary and apply specific retention rules. For recruitment, safer recruitment and employment checks, the school relies on Article 10 together with applicable Data Protection Act 2018 authorisation, including Schedule 1 Part 1 paragraph 1 where criminal offence data is necessary to meet legal employment obligations. Schedule 1 Part 2 paragraph 6 or paragraph 18 may also apply to statutory or safeguarding processing where their requirements are met. The school records only the necessary check outcome and applies the retention rules in its safer recruitment and data protection arrangements.

Choice and essential information

Optional publicity may use consent under Article 6(1)(a), with a genuine choice and no employment disadvantage for refusal. Consent is not the general basis for employment records or required checks. In an emergency vital interests may apply, subject to the additional conditions for sensitive information.

We tell you whether requested information is a legal or contractual requirement, necessary for a particular service or optional. Without essential information we may be unable to assess an application, confirm employment, pay you correctly or arrange a benefit or adjustment. Please keep your details up to date.

Sharing protecting and retaining information

We share relevant information where necessary and lawful with payroll and pension administrators, HMRC, our local authority where applicable, the DfE, vetting and professional regulation bodies, occupational health providers, insurers, auditors, legal advisers and safeguarding or law-enforcement agencies. References are provided where appropriate and lawful. The Governing Body is the employer. Manchester City Council is the school’s local authority and is a separate controller for functions it carries out, including relevant education, payroll, pension or statutory-return activity where applicable. Manchester City Council’s Education Services privacy information is available at Service Specific Privacy Statements.

Suppliers supporting HR, payroll, IT, training and school management systems may process information for us under written instructions and contractual safeguards. Other recipients act as independent controllers. Our DPO may access information needed to advise us or help manage a request or complaint. Details of service providers: the School Office at admin@st-willibrords.manchester.sch.uk or the Data Protection Officer.

Where required, we supply workforce information for statutory returns to the DfE, directly or through the relevant local authority. The DfE uses workforce information for education workforce statistics, analysis and policy. Its privacy information explains its own use and sharing: Work Force. Workforce categories supplied where required include personal identifiers, characteristics, role and contract information, pay and working hours, qualifications, teacher status, absence information and other fields required by the School Workforce Census or related statutory returns.

Security and monitoring

We restrict access to those who need information for their role and apply appropriate security, confidentiality and staff training measures. Health, employment casework, vetting and safeguarding information have access controls appropriate to their sensitivity.

School email, internet access and school-managed devices may be logged, filtered and monitored for safeguarding, cyber security, acceptable use, technical support and the protection of school systems. Records may include account sign-ins, device or user identifiers, internet and filtering events, security alerts and system activity. CCTV is used on selected areas of the school site for security and safeguarding. Access to monitoring records and CCTV is limited to authorised staff and approved ICT/support providers, and information is retained only for the operational, security or safeguarding period required, with relevant evidence preserved longer where an incident, investigation or legal requirement justifies it. The school does not use biometric identification systems. No AI-supported recruitment or HR tool, and no AI workspace, is currently approved to process personal data. Any future AI use involving personal data must be separately approved, risk assessed and covered by the school’s data protection controls. The school relies on legal obligation and/or public task where monitoring supports its statutory safeguarding, employment, security and public education functions.

International transfers: some approved cloud or service providers may store or access staff information outside the UK. Where a restricted international transfer occurs, the school uses a lawful transfer mechanism, such as UK adequacy regulations or approved contractual safeguards including the UK International Data Transfer Agreement or UK Addendum where appropriate, and carries out the required transfer assessment. Current provider and transfer details can be obtained from the School Office or the Data Protection Officer.

How long we keep information

We retain information only as long as needed for its purpose, taking account of legal duties, pension administration, safeguarding and legal claims. We apply separate periods to recruitment, employment, payroll, tax, pension, health, safeguarding, monitoring and consent records. Our retention schedule is available at the School Office at admin@st-willibrords.manchester.sch.uk or the Data Protection Officer.

We do not apply a single two-year or five-year limit to all staff records. Some records need shorter retention and others substantially longer. Relevant safeguarding allegation records are generally retained until normal pension age or for ten years from the allegation, whichever is later, subject to applicable guidance and exceptions. Pension and statutory financial records have their own requirements.

Where a complaint, investigation, legal claim or preservation requirement justifies continued retention, we keep the relevant records for the necessary period and review that need. When no longer required, information is securely destroyed or anonymised. We explain particular retention arrangements if you ask.

Your rights and how to contact us

You can ask for access to your personal information and correction of inaccurate or incomplete information. Depending on the lawful basis and circumstances, you may also ask for erasure, restriction of use or a portable copy, or object to processing. These rights have conditions and exceptions; for example, we may need to retain records to meet a legal duty.

Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of earlier use. Where we rely on public task or legitimate interests, you may object on grounds relating to your circumstances. You can object to direct marketing at any time.

Contact the school or our DPO to exercise your rights. Requests can be made verbally or in writing and do not have to use a particular form. We may need proportionate evidence of identity or authority to protect your information. We normally respond to a subject access request within one calendar month. Where the law allows clarification, an extension or an exemption, we will explain how this affects your request. School holidays do not automatically extend the deadline.

Automated decisions

The school does not currently use solely automated decision-making that produces legal or similarly significant effects in recruitment, pay, performance, disciplinary, safeguarding or other employment decisions. Significant workforce decisions involve human judgement and review. If this changes, we will update this notice and explain the decision process, likely effects and safeguards, including the right to human intervention where applicable.

Questions and complaints

If you are concerned about our use of personal information, contact the school or Global Policing Limited using the details on the first page. Our data protection complaints procedure is available at the School Office at contact@st-willibrords.manchester.sch.uk or admin@st-willibrords.manchester.sch.uk; it is also set out in the school’s Data Protection Policy. We will acknowledge a data protection complaint within 30 days, investigate appropriately, keep you informed and provide an outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office (ICO). Visit Make a complaint or call 0303 123 1113. The ICO normally expects you to give the organisation an opportunity to address your concern first.

Keeping this notice up to date

We review this notice regularly and when our use of information changes. We will bring material changes to your attention. Current notice: https://www.st-willibrords.manchester.sch.uk/privacy-cookies/. Next scheduled review: September 2027, or sooner if needed. Ask the school for an accessible format or help understanding this notice.

Optional photographs and publicity consent

School: St Willibrord’s RC Primary School. This form records optional choices only. Refusing or withdrawing consent will not affect your employment, opportunities or treatment at work.

Staff member name: ______________________________________________

Select Yes or No for each purpose. Leaving a choice blank means no consent for that purpose. Photographs may include video images. We will seek a separate choice for any materially different use. This form does not authorise facial recognition or biometric identification.

Use images in optional celebration displays inside the school, without a name.    Yes ☐   No ☐

Add my name to those internal celebration displays.    Yes ☐   No ☐

Publish images on the school’s public website, without a name.    Yes ☐   No ☐

Add my name to those website images.    Yes ☐   No ☐

Publish images on the school’s official Facebook page (St Willibrord’s RC Primary School – https://www.facebook.com/StWillibrordsRC), without a name.    Yes ☐   No ☐

Add my name to those Facebook images.    Yes ☐   No ☐

Use images in printed school prospectuses or publicity leaflets, without a name.    Yes ☐   No ☐

Period covered: from the date signed until your employment or other work with St Willibrord’s RC Primary School ends, or consent is withdrawn, whichever is earlier. Website and Facebook images will be reviewed when consent ends; existing printed stock may remain until exhausted. We will ask separately before providing identifiable images or names to newspapers or other external publishers.

Public images can be viewed, copied or shared by others, including outside the UK. We control our own publications but cannot guarantee removal of copies made by others. To withdraw or change a choice, contact admin@st-willibrords.manchester.sch.uk or 0161 223 9345. We will stop future consent-based use and remove images from channels we control where reasonably possible; already distributed printed material may not be recoverable.

These choices are voluntary. Permission to publish my name applies only where permission for the associated image has also been given. Necessary identification and employment records are covered by the privacy notice and do not depend on this form.

Signature: __________________________________   Date: ______________

We retain evidence of your choices and any withdrawal in accordance with our retention schedule, for as long as necessary to manage and demonstrate those choices.

 

Form Submissions

We may collect information about your approximate location when you submit a form on our website.

This may include:

  • Your IP address
  • Geographic location (such as city or region), inferred from your IP address or device data

We collect this information to:

  • Identify and prevent fraudulent or malicious activity
  • Diagnose technical issues

We process this data under our legitimate interests in operating and improving our website and ensuring its security.

We do not use this information to identify your precise location, and we do not share it with third parties for marketing purposes.

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