Purpose
To explain how Evolution Education Limited processes personal data lawfully, fairly and transparently, protecting the rights of students, families and staff under UK GDPR and the Data Protection Act 2018.
Scope
All personal data processed by Evolution Education, including student records, safeguarding records, staff data, commissioner communications, website contact messages, and public communications (including photographs, film and any future anonymised case studies on evolution-education.com).
Definitions
- Personal data: information relating to an identified or identifiable person.
- Special category data: sensitive data such as health, ethnicity or safeguarding information, requiring additional protection.
- Data subject: the person the data is about.
Responsibilities
- Evolution Education Limited is the data controller for school-held data.
- Lloyd, Centre Manager, is the day-to-day Data Protection Lead.
- The Chief Executive Officer retains overall oversight of compliance.
- Contact for data protection questions and UK GDPR requests: admin@evolution-sportsgroup.com.
- All staff complete data protection training and follow need-to-know rules.
- Staff must not publish identifiable student information on websites or social media without Leadership approval and a lawful basis (usually consent).
Procedures
Lawful bases
We process data for legal obligations, public task / legitimate interests in providing education and safeguarding, contract (for example employment), and consent where required (for example certain photography, film and public marketing case studies).
Rights
Data subjects may request access, rectification, erasure (where applicable), restriction, objection and data portability. Requests: admin@evolution-sportsgroup.com. Safeguarding and legal duties can limit erasure or restriction; we explain that when we respond. Complaints may be made to the Information Commissioner's Office (ICO).
Security
Access is role-based. Paper and digital records are secured. Breaches are reported internally immediately and to the ICO within 72 hours where required.
Retention
Records are retained only as long as necessary, with particular care for safeguarding records in line with KCSIE and local guidance.
Sharing
Information is shared with schools, Local Authorities and agencies only where lawful and necessary, especially to safeguard children.
Website, photography, film and case studies
- Public website content must not put a child at risk or reveal special category data (for example diagnoses) in identifiable form.
- We do not currently publish student case studies on the website because we do not hold the required parent or carer consent (and young person agreement where appropriate) for public use.
- When Leadership approves a future story, it must use changed names and reduced detail, with re-identification risk assessed before publication.
- Photography, film and named or recognisable student stories require appropriate consent from a parent or carer, and agreement from the young person where appropriate, plus Leadership approval.
- Parents, carers or young people may ask for a story or image to be edited or removed by emailing admin@evolution-sportsgroup.com.
- A short Privacy notice for families and website visitors is published at /privacy. This policy remains the fuller staff and inspection reference.
Cookies
Essential cookies or similar technologies may be used so the website works securely. The public school site does not use third-party advertising trackers. Browser settings control non-essential cookies where offered by the browser.
Monitoring
The Leadership Team monitors implementation through learning walks, safeguarding reviews, incident analysis, staff feedback, student voice and commissioner feedback. Findings inform training and school improvement planning. Website publications are reviewed when new stories or media are added.
Review Cycle
This policy is reviewed at least annually, or sooner following changes in legislation, statutory guidance, or significant incidents. Next formal review: August 2027, or sooner if law or practice changes. Approved by the Proprietor / Leadership Team.
Related Policies
Child Protection and Safeguarding; Behaviour for Learning; Attendance; SEND; Complaints; Equality, Inclusion and Anti-Discrimination; Prevent; Online Safety; Safer Recruitment; Staff Code of Conduct; Low-Level Concerns; Whistleblowing; Health and Safety; First Aid; Curriculum; Admissions. See also the public Privacy page.
Legislation and guidance
This policy has regard to the Education (Independent School Standards) Regulations 2014, Keeping Children Safe in Education (latest DfE edition), Working Together to Safeguard Children, the Equality Act 2010, the Data Protection Act 2018 and UK GDPR, and other DfE statutory and non-statutory guidance relevant to the subject of this policy. Where Independent School registration is completed, this policy will be reviewed against any updated registration conditions and DfE requirements.