Our respect for the privacy and security of yours and your children’s data is of great importance to Imperial College London. All personal data is held and processed in accordance with the Data Protection Act 2018 and any subsequent amendment or replacement to it like the General Data Protection Regulation (GDPR, May 2018), as well as with the College’s Data Protection Policy and supporting Codes of Practice.
This notice specifically relates to personal data processed by the Early Years Education Centre. This notice should be read in conjunction with the College’s Data Protection Policy and the relevant Codes of Practice, which are available on our Legal Services Office web pages.
This notice contains the key information about how and why Early Years collects your child’s 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 how well your child is developing whilst at Early Years and any information that we need to take care of your child. Photographs and videos of your child also count as their personal information.
Our primary reason for using your child’s personal information is to provide them with care and education services whilst they are in our care as you are either a member of the Imperial College staff or student community.
We collect this information to help the Early Years Education Centre to run properly and safely. Below are examples of the different ways in which we use your child’s personal information and where that personal information comes from. The requirement to provide you with the details we retain about you and your child applies to information that is collected in relation to:
- Online data processing
- Paper data processing
Early Years Prviacy Policy
What information do we collect about you?
1. When you complete an application form, we collect the following information:
In relation to your child:
- Name, date of birth, gender, nationality, home address
- Parental or guardian contact details and/or other emergency contact information
In relation to the parent:
- Name, date of birth, contact details including postal address, email and phone
- Employment or academic information including Imperial contact details
- Staff or student status
2. When you have been offered a place we collect the following information:
In relation to the child:
- Health and medical needs information
- GP and Health visitor details
- Special Educational Need requirements
In relation to the parent:
- Proof of parental responsibility e.g. birth certificate or adoption, fostering details
In relation to persons authorised to collect the child:
- Name, photographic identification, contact details including postal address
In relation to persons unauthorised to contact child:
- Name and details of lawful prohibition
3. When you have accepted a place and your child is admitted into Early Years
In relation to your child:
- Details and observations about your child’s learning and development within Early Years for record keeping
- Safeguarding and child protection records
- Any records required to support your child, such as shared information from other agencies and professionals
- We may take photographs or videos of your child for inclusion in their development files
- Photos of your child and their work may be used for identification purposes, and for displays within the rooms in the Early Years Centre to showcase the work of the children. Photos may also be used to show prospective parents what we do here, for example in brochures or on our website. Before we us the photos for this purpose, we would be sure to ask for your permission to do so. We may continue to use these photographs and videos after your child has left EYEC. Sometimes we may also use photographs and videos for teaching purposes, for example, to record a drama session.
- 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
- There may be instances where we may need to share information with government authorities or our legal advisers.
- We need to tell all appropriate members of staff if your child is allergic to something or might need extra help with some tasks
- CCTV footage is taken within the public spaces within Early Years, to assist in providing a safe and secure environment for the benefit of the children, parents and staff within EYEC. The CCTV system is owned by the College and more information on how these are processed can be found in the CCTV Code of Practice.
How do we use the information you provide to us?
We have set out below the legal basis for using the personal data you provided to us, and what this means in practice.
Some information you provide to us is required so that we can provide the care and education services we have agreed to provide for your child, and charge you the appropriate fee rate. The processing is necessary to fulfil that contract to which you are a party.
We also need to process the data you provide to us to ensure the safety and wellbeing of your child and others. This type of processing is necessary to protect the vital interests of the data subject or others. In addition to this, we also need to process some of the data you provide to us to help us comply with legal obligations.
Some of the information you provide to us is considered ‘sensitive personal data’ such as information relating to your cultural or ethnic identity or relating to your child’s health data.
Information relating to your child’s health is necessary to protect the vital interests of your child, and the interests of others, as they are too young to consent for themselves.
Your contact details are kept for Safeguarding purposes and to ensure we can keep you up to date with current news or issues at the EYEC. When getting in touch with you we would use the most appropriate means to do so. For example, we would use the text service to get in touch with you for any urgent communications.
Any information you provide to us about your racial, ethnic or religious identity is provided on a voluntary basis. You do not have to supply this information, and you can ask us to delete any such information that we hold about you. For more information please contact firstname.lastname@example.org
Who do we share your information with?
We may have to share information with the local authority or legal authorities in relation to the safeguarding and wellbeing of your child.
We may also share some of the information you provide to us with the College’s HR department to verify your current status at the College.
We share information with other childcare establishments that your child may attend as requested. E.g. schools or other nurseries.
Tracking Children’s development
In order to record and track children’s development we use a we-based application called the EYFS Tracker developed by MIME Consulting. https://www.eyfstracker.com
How long do you keep my information?
We are required to keep the data you provide to us for as long as it is necessary for the purposes set out above in order to provide care and education to your child and, as required for statutory and legal purposes.
In exceptional circumstances, we may keep your child’s 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.
The brief table below shows for how long we keep different types of information about your child. After the time indicated, the information will be destroyed securely. If you would like to see a detailed copy of our retention policy providing further details on how long we keep the data on you and your child, please get in touch .
Type of information
Retention period or the criteria
Application records relating to the application process
Length of time on waiting list + 3 years ; unless child attends EYEC
Admission of children
Date of attendance + 3 years if no concerns
Length of time child attended + 3 years then Review, may wish to keep permanently as may receive enquiries from past children to confirmed dates attended and for historical interest
Is my personal data secure?
We are committed to the security of the information we hold and in ensuring that only people who need to access the information, are able to do so. Your information is held in the College’s secure servers, with access restricted to authorised personnel only.
What decisions can you make about your child’s information?
From May 2018, you will be able to make various decisions about your child’s information. Some of these are new rights whilst others build on your child’s existing rights. Your child’s rights are as follows:
- If information is incorrect, you can ask us to correct it;
- You have a right to request copies of the data that we hold about you or your child. Our sharing of this information may however be restricted in some cases, for example where there may be safeguarding or child protection concerns. If you would like further information on this, please see the College’s subject access request process.
- You can ask us to stop processing, rectify or delete your personal data in certain circumstances.
Data Controller details
The College is currently required to register its notice of being a data controller with the UK’s regulatory body – the Information Commissioner’s Officer. The College’s registration number on the Data Protection Register is Z5940050. Please see the Information Commissioner’s Office website for more information.
For the purposes of any applicable data protection laws in England and Wales, including from 25 May 2018 the EU General Data Protection Regulation 2016/679 (GDPR), the College is the data controller of you and your child’s personal data.
If you have any concerns about the use of your data the College has appointed a Data Protection Officer, who can be contacted via:
Telephone: 020 7594 3502
Data Protection Officer
Level 4, Faculty Building
Imperial College London
London, SW7 2AZ.