Grazebrook PSA Privacy Notice
Our contact details
Name: GRAZEBROOK SCHOOL PARENT STAFF ASSOCIATION (REGISTERED CHARITY NUMBER 1084738)
Address: Grazebrook Primary School, Lordship Rd, Stoke Newington, London N16 0QP
Phone Number: +44 (0) 208 802 4051
E-mail: grazebrookpsa@gmail.com
What type of information we have
We currently collect and process the following information:
· Personal identifiers, contacts and characteristics (for example, name and contact details)
How we get the information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
· Signing up to our newsletter
· Purchasing items from the online store
· Providing feedback
· Submitting a request for funds via the online request form
· Submitting a skill search form
· Completed sign up forms at events (e.g. Summer Fair, Teddy bear’s Picnic
We also receive personal information indirectly, from the following sources in the following scenarios:
· PayPal; In the event a donation is processed through Paypal.com (click for PayPal privacy policy)
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Grazebrook via email grazebrookpsa@gmail.com
What we do with the information we have
We use the information that you have given us in order to send out announcements and newsletters periodically and as they occur. Information held may also be used to contact subscribers for assistance during events in the form of general helpers or those who have made themselves available to assist in specific ways (e.g. accepting a sponsored property board outside their home(s).
We shall also use information to contact those who have purchased items or services via the online store. Contact shall relate to the order in terms of confirmation, cancellation, delay or any other information affecting the fulfilment of the order.
Data shared with 3rd parties is limited to service providers such as PayPal & Mail Chimp
How we store your information
Your information is securely stored in Google Drive, a cloud platform used for administrative purposes provided by google.com. contact details stored on the server are used in administrative tasks such as the organising of events and stall sales for those who have opted-in to assist. Contact information may be submitted and held on those who have been assigned tasks so that the person is able to provide contact and be contacted regarding both the planning and execution of tasks in the run up to events. Information from our online polls are also stored on the server to negate the duplication of votes from the same voter.
Information is also stored via the mailchimp.com storage severs. mailchimp.com currently provide Grazebrook PSA the ability to create e-mail campaigns. Campaigns are designed to provide information about upcoming events. It is also used to send documents such as the PSA Newsletter to those who have subscribed to receive it.
(click for mailchimp.com privacy policy)
We keep contact information for five years. We will then dispose your information by digitally removing the records from our contact list(s).
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at grazebrookpsa@gmail.com if you wish to make a request.
Guidance notes on the capturing of images and videos in relation to data protection law
This guidance covers the use of images of people, including photos and videos, for Grazebrook PSA’s own purposes. It applies to images already stored on Grazebrook PSA databases, as well as to images captured in the future.
Personal data means any information relating to an identified or identifiable individual.
If an image can be used to identify a living individual, that image is therefore likely to constitute personal data. This includes where individuals in an image are named, and also covers situations where no names are used but other contextual information would enable individuals to be identified, e.g. a caption specifying the year the subject that is attached to an image of a small group of students.
Determining whether a particular image includes personal data is not always straightforward. This note therefore provides guidance on whether the following types of images are likely to be classed as personal data:
· Images of individuals
· Images of small groups; and
· Images of individuals.
Images of crowds
Where the image is of a crowd and does not focus on one individual or a group of individuals, it is unlikely to be personal data as the individuals will not be identifiable. Data protection law will not therefore apply.
This means that:
· Grazebrook PSA will not need to establish a legal basis for processing personal data. In particular, consent will not be required;
· There is no requirement to provide privacy information to all individuals in the image. However, even in relation to crowds, Grazebrook PSA’s policy is that individuals should still be informed that photographs or videos are being taken. Announcements about photography/videos at events will be made in the form of signs to inform event attendees that images will be captured by Grazebrook PSA.
· As no personal data is being processed by Grazebrook PSA, individuals cannot object to the use of their personal data. However, it is Grazebrook PSA’s policy to respect the preferences of individuals who request not to be recorded in larger events. This means that we will need to consider taking reasonable steps to achieve this e.g. the issuing of coloured lanyards which can then be used in post-production to identify those individuals who did not want to be included in any images.
Images of small groups
Images of small groups are likely to constitute personal data and must therefore be treated in accordance with data protection legislation.
This means that:
· Grazebrook PSA will need to establish a legal basis for processing personal data. Grazebrook PSA should rely on legitimate interests where possible and consent will not be required;
· Grazebrook PSA must provide individuals with privacy information, making sure that they are aware that their images would be taken and the context in which those images would subsequently be used by Grazebrook PSA; and
· Grazebrook PSA must be prepared to receive objections from individuals to the use of their personal data.
Images of individuals
An image of a single individual is likely to be classed as personal data and the same principles applicable to images of small groups will apply. This means that:
· Grazebrook PSA will need to establish a legal basis for processing personal data. Grazebrook PSA will rely on legitimate interests where possible and consent will not be required;
· Grazebrook PSA must provide the individual with privacy information, making sure that they are aware that their image would be taken and the context in which their image would subsequently be used by Grazebrook PSA; and
· Grazebrook PSA must be prepared to receive objections from the individual to the use of their personal data.
How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113