General Privacy Notice

Created: 9 April 2024
Updated: 4 September 2024

Whole Education is a network for Trusts and Schools. Its mission is to grow networks of confident and capable leaders who build schools that provide a rigorous whole education so that everyone thrives in a transforming world. Whole Education also provides collaborative school improvement services.

Excellent communication and sharing of information are critical to the work of Whole Education in enabling it to facilitate collaboration and improvement across its network. Whole Education wants you to be comfortable with how it stores and uses your personal data in the work it does. This privacy notice explains how Whole Education uses any personal data it collects about you, the choices you have about what marketing you want Whole Education to send you, your privacy rights, and how the law protects you.

Our Privacy Promise

To comply with the law, your personal data must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Whole Education needs to keep information about its employees, contractors, members, participants and suppliers for financial and commercial reasons and to enable Whole Education to monitor performance, to ensure legal compliance and for health and safety purposes. In practice, this means that only those who have a necessary and lawful need to access your data will be able to do so.

Introduction

Whole Education Limited (“Whole Education”, “we”, “our”) is committed to protecting the privacy and security of the personal data it collects in connection with its membership services, events, products, social media and website. 

Please read this privacy notice carefully as it provides important information about how we handle personal information and outlines the rights you have over your data. 

Personal data we process 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The following gives details of the different kinds of personal data that Whole Education may collect, use, store, transfer about you. 

• Identity Data includes first name, maiden name, last name, username or similar identifier, title.

• Image Data where video capture may be used.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from Whole Education.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Whole Education’s website.

• Profile Data includes your username and password, membership information, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

• Usage Data includes information about how you use Whole Education’s website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, store and use the following “special categories” of more sensitive personal information: 

• information about your health, including any medical condition

How Whole Education collects personal data

• When contacted via its website or emails Whole Education with an enquiry

• When you engage with Whole Education through social media 

• When you engage with Whole Education through online events i.e. zoom 

• When you engage with Whole Education through other digital connections i.e. googlemeet

• Through the sign up process of becoming a member of Whole Education or joining a programme operated by Whole Education

• When a school, trust or Local Authority provides Whole Education with the personal data of its participants during the membership/programme sign up process and in the course of providing services to members

• When you book or attend one of Whole Education conferences

• When Whole Education have direct interactions via post, email, phone or otherwise

• When you join Whole Education’s digital platform

• Automated technologies or interactions. As you interact with Whole Education’s website, it will automatically collect technical data about your equipment, browsing actions and patterns. Whole Education collects this personal data by using cookies, server logs and other similar technologies.

• Third parties or publicly available sources. Whole Education will receive personal data about you from various third parties as set out below:

• Contact, financial and transaction data from providers of technical, payment and delivery services such as Stripe

• Identity and contact data from publicly available sources such as Companies House, Get Information about Schools, Trust and School websites. 

Purposes for which Whole Education use personal data and the legal basis 

Whole Education will only use your personal data when the law allows it to, Most commonly, Whole Education will use your personal data for the following purposes:

• To administer your membership of Whole Education Networks i.e. school, trust 

• To administer your participation in Whole Education programmes such as Words for All, Early Years and SEND Improvement programmes

• To organise and administer in person and online events such as leadership conferences and programme webinars

• To share information on Whole Education’s digital platform

• To respond to enquiries made via Whole Education’s website or email addresses

• To perform the contract/relationship Whole Education are about to enter or have entered into with you/your organisation

• To comply with legal obligation 

The data processing described in this notice is on the basis of legitimate interests of Whole Education or consent to:

• Provide services to its customers 

• Evaluate service delivery

• Market to potential customers

• Maintain network and information security

• Meet its legal obligations

Whole Education will only process special categories of personal data where you have given explicit consent to the processing of those personal data for one or more specified purposes as outlined in Article 9 of the GDPR. 

Marketing

Whole Education may contact you to ask your opinion, offer insight and research into the education sector and tell you about programme and service information, news and updates, events, case studies, impact reports, blogs, articles and other selected items of interest it thinks are relevant to you. For example, in its newsletters Whole Education will curate content for you that includes, but is not limited to, events and opportunities which support school improvement. This is what Whole Education means when it talks about ‘marketing’. 

The personal information Whole Education has for you is made up of what you tell us, and data it collects when you use its services. Whole Education uses this information to decide what may be relevant and of interest to you. 

Whole Education can only use your personal information to send you marketing messages if Whole Education has either your consent or a ‘legitimate interest’. That is when Whole Education has a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask Whole Education to stop sending you marketing messages by contacting it at any time. 

Whatever you choose, you’ll still receive information relating to the programmes and networks of which you are an existing member. Whole Education may ask you to confirm or update your choices if you start any new programmes or use its services in future. Whole Education will also ask you to do this if there are changes in the law or regulation. If you change your mind you can update your choices at any time by contacting Whole Education. 

Third Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Cookies

Cookies may be used in facilitating automated network security to provide one element in protecting Whole Education’s website from high risk patterns of behaviour (further information on this cookie can be found at https://support.cloudflare.com/hc/en-us/articles/200170156). Whole Education may also use cookies (session cookies) if you log into its website for the purpose of providing the services that you logged in to use until your browser is closed. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note some parts of Whole Education’s website may become inaccessible or not function properly. 

Read our cookie policy here.

Google Analytics and Advertising. We may also utilise certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimise, and display ads based on your past visits to our services. 

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. 

Website logging of data 

Requests to sites operated by Whole Education are logged including the IP address and browser version. This information is used in the identification of security threats to its site, diagnosing reported issues and providing general usage information about its site. Whole Education do not correlate this information to identify individuals other than for resolving issues which the individual has requested it to address. This information is only accessible by those responsible for the technical operation and support of its services, but may also be shared with other parties where they have the legal power to request such data.

Change of Purpose

Whole Education will only use your personal data for the purposes for which Whole Education collected it, unless it reasonably considers that Whole Education needs to use it for another reason and that reason is compatible with the original purpose. 

Sharing your data 

The personal data of members and delegates is accessed by Whole Education employees and consultants.

Network and Programme Members

Whole Education shares contact details of network members within school and special interest networks to facilitate the sharing of good practice amongst the members, and to support school-to-school introductions.

Whole Education uses its digital platform to share information about events.

Recordings of webinars and online training that is available to all members may be shared in whole or part with all members via email and Whole Education’s learning platform. 

Event Delegates

If you attend a Whole Education event Whole Education will share your name, school and job role via a delegate list given to all attendees to facilitate networking. In the case of online events, webinars and online training sessions, Whole Education makes recordings available to all members.

Delivery Partners

Whole Education delivers some services using external partners and consultants. If you are attending an event or training delivered by a partner, Whole Education will provide them with attendee lists. 

Some services delivered by Whole Education involve third-party venus or other services such as transportation and accommodation. Where Whole Education is contractually required to supply delegate lists to these partners then we will do so. 

Third Party Services

Whole Education uses the following third-party services that may contain your personal data:

Whole Education requires all third parties to respect the security of your personal data and to treat it in accordance with the law. Whole Education does not allow third-party providers to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and in accordance with its instructions. 

Other data sharing

Some programmes may require Whole Education  to share participant data, for example with funding bodies such as the Department for Education.  In such cases participants will be informed of this further sharing at or before the point of sign-up. 

For 2024 2025 Whole Education is working in partnership with the following organisations to share membership and events. To enable these partnerships data will be shared between the providers.   This will be made clear at the point of sign up to these partner memberships/events.

How long Whole Education keeps your data 

Whole Education will retain your personal data for as long as is necessary to provide you with its services and for a reasonable period thereafter to enable it to meet its contractual and legal obligations and to deal with complaints and claims. 

You can ask to have your data removed by contacting them. 

How Whole Education protects your data 

Whole Education has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, Whole Education allows access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Whole Education’s instructions and they are subject to a duty of confidentiality.

Whole Education has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.

Your rights and options 

You have the following rights in respect of your personal data: 

• You have the right of access to your personal data and can request copies of it and information about Whole Education’s processing of it

• If the personal data Whole Education holds about you is incorrect or incomplete, you can ask them to rectify or add to it

• Where Whole Education are using your personal data with your consent, you can withdraw your consent at any time

• Where Whole Education are using your personal data because it is in its legitimate interests to do so, you can object to Whole Education using it this way

• Where Whole Education are using your personal data for direct marketing, including profiling for direct marketing purposes, you can object to it doing so

• You can ask Whole Education to restrict the use of your personal data if: 

• It is not accurate

• It has been used unlawfully but you do not want Whole Education to delete it

• Whole Education do not need it any-more, but you want it to keep it for use in legal claims; or 

• if you have already asked Whole Education to stop using your data but you are waiting to receive confirmation from it as to whether Whole Education can comply with your request

• In some circumstances you can compel Whole Education to erase your personal data and request a machine-readable copy of your personal data to transfer to another service provider

• You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Whole Education may charge a reasonable fee if your request for access is clearly unfounded, repetitive or excessive. Alternatively, Whole Education may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, please contact Whole Education at info@wholeeducation.org. 

You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at: https://ico.org.uk/concerns/. Whole Education would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact it in the first instance. 

Whole Education may need to request specific information from you to help it confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless Whole Education has a lawful basis for doing so and it has notified you. 

Whole Education do not envisage that any decisions will be taken about you using automated means, however Whole Education will notify you in writing if this position changes. 

Photography, Filming and Audio Recording

Whole Education may record photographs / videos / audio recordings at events. In the case of online events, webinars and training courses Whole Education may record the event in audio, video and digital form. These may be used for the following purposes:

• reporting the event via social media

• reporting the event via the Whole Education website and publications, or in Whole Education press releases

• promoting similar events in future, via any medium, including publication in third-party journals or other media

• general marketing and promotion of Whole Education’s business, via any medium, including publication in third-party journals or other media

• transferred to your employer for their own promotional purposes

• shared with other delegates as part of the event record

• in the case of whole-network events, shared with all members of the network

You have the legal right to object to any or all of the above uses of your image. To do so please speak to any member of Whole Education staff at the event (who will ask you to record your objection in writing), or contact Whole Education via info@wholeeducation.org.

Contact us 

If you have any questions, or wish to exercise any of your rights, then you can contact: 

Shonogh Pilgrim, CEO
Whole Education Limited
Canopi Foundation
7 - 14 Great Dover Street
London
SE1 4YR

Alternatively, you can email us at info@wholeeducation.org. 

Changes to this privacy notice 

Whole Education may update this notice (and any supplemental privacy notice), from time to time as shown below. Whole Education will notify the changes where required by applicable law to do so.

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