The Confederation of School Trusts (CST) is committed to protecting and respecting your privacy. For the purposes of the General Data Protection Regulations (GDPR) and any subsequent UK legislation covering data protection, the Data Controller is CST.
This Policy sets out why we collect personal information about individuals and how we use that information. It explains the legal basis for this and the rights you have over the way your information is used.
This Policy covers CST in relation to the collection and use of the information you give us. We may change this Policy from time to time. If we make any significant changes we will advertise this on the website or contact you directly with the information. Please check this page occasionally to make sure you are happy with any changes.
If you have any questions about this Policy or concerning your personal information please contact the CST office on 0115 917 0142 or by email at firstname.lastname@example.org or by post to CST, George Spencer Academy, Arthur Mee Road, Stapleford, Nottingham NG9 7EW
What type of personal information we collect
The type and amount of information we collect depends on why you are providing it.
The information we collect when you make an enquiry to CST includes your name, trust name/school, telephone number and email address.
If you are applying to be a member of CST, we will ask for details of your trust/school which will include the name of your MAT/group/school and the name of your Accountable Officer. We will also ask for details about your Trust/school and which type of membership you wish to apply for. We then ask for details of the leadership person, the Governance Leader and the Chief Financial Officer or equivalent applying to be part of the membership – this includes job title, title, name and email address and whether they are Leaders of Education or Governance.
If you sign up for an event, in addition to asking for the name, telephone number, email address and role/position of the person making the booking, we also ask for the school name and group or trust name if applicable. We then ask for the title, name, position and email address of each of the attendees being booked onto the event.
For any payment, we will keep copies of your bank details if we need to make regular payments to you – for example refunding travel expenses, doing consultancy work.
If you are a job applicant the information you are asked to provide is as set out in the application and necessary for the purposes of our considering the application.
How we collect information
We may collect information from you whenever you contact us or have any involvement with us for example when you:
- enquire about our activities or services
- ask for advice or support
- book on to an event
- join CST as a member trust/school
- post content onto our website/social media sites
- attend a meeting with us and provide us with information
- take part in our events
- provide consultancy work
- contact us in any way including online, email, phone, SMS, social media or post
Where we collect information from
We collect information:
- From you when you give it to us directly: You may provide your details when you ask us for information, join or register with us, attend our events or contact us for any other reason. Your information may be collected by an organisation we are working in partnership with but we are still responsible for your information.
- When you have given other organisations or individuals permission to share it: Your information may be provided to us by other organisations if you have given them your permission. This might for example be a charity working with us or might be when you buy a product or service from a third party organisation. The information we receive from other organisations depends on your settings or the option responses you have given them.
- When it is available on social media: Depending on your settings or the privacy policies applying for social media and messaging services you use, like Facebook, Instagram or Twitter, you might give us permission to access information from those accounts or services.
How we use your information
We will use your personal information in a number of ways which reflect the legal basis applying to processing of your data. These may include:
- providing you with the information or services you have asked for
- providing you with the benefits of membership
- sending you communications with your consent that may be of interest including marketing information about our services and activities, events and publications and other situations for which we seek support
- when necessary for carrying out your obligations under any contract between us
- seeking your views on the services or activities we carry out so that we can make improvements
- maintaining our organisational records and ensuring we know how you prefer to be contacted
- analysing the operation of our website and analysing your website behaviour to improve the website and its usefulness
- processing grant or job applications
Our legal basis for processing your information
The use of your information for the purposes set out above is lawful because one or more of the following applies:
- Where you have provided information to us for the purposes of requesting information or requesting that we carry out a service for you, we will proceed on the basis that you have given consent to us using the information for that purpose, based on the way that you provided the information to us. You may withdraw consent at any time by emailing us at email@example.com. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.
- It is necessary for us to hold and use your information so that we can carry out our obligations under a contract entered into with you or to take steps you ask us to prior to entering into a contract.
- It is necessary to comply with our legal obligations.
- Where the purpose of our processing is the provision of information or services to you, we may also rely on the fact that it is necessary for your legitimate interests that we provide the information or service requested, and given that you have made the request, would presume that there is no prejudice to you in our fulfilling your request.
How we keep your information safe
We understand the importance of security of your personal information and take appropriate steps to safeguard it.
All electronic data is password protected and therefore stored securely. Our ICT Policy can be read here
We always ensure only authorised persons have access to your information, which means only our staff, trustees and contractors, and that everyone who has access is appropriately trained to manage your information.
No data transmission over the internet can however be guaranteed to be 100% secure. So while we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.
Who has access to your information?
- CST Professional Development are the commercial trading company for CST. They arrange all seminars, training and conferences and liaise with our commercial partners.
- Third parties who provide services for us, for example, our accountants who process all payments to and from ourselves and our subsidiaries (Howard Wilson); the company who provide our website (ZEST) and CRM services (Rubiqa) and the company who provide our IT services (Advanced IT). We select our third party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do.
- Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event.
- Analytics and search engine providers that help us to improve our website and its use.
- Third parties in connection with restructuring or reorganisation of our operations, for example if we merge with another charity. In such event we will take steps to ensure your privacy rights will be protected by the third party.
We may also disclose your personal information if we are required to do so under any legal obligation and may use external data for the purposes of fraud prevention and credit risk reduction, or where doing so would not infringe your rights, but is necessary and in the public interest.
Other than this, we will not share your information with other organisations without your consent.
Keeping your information up to date
We really appreciate it if you let us know if your contact details change. You can do so by contacting us at firstname.lastname@example.org.
Our use of “cookies”
“Cookies” are small pieces of information sent by a web server to a web browser, which enable the server to collect information from the browser. They are stored on your hard drive to allow our website to recognise you when you visit. Our website uses one cookie (called “PHPSESSID”), which is a necessary part of the functionality behind the Members section.
We also use Google Analytics for tracking aggregated website metrics and Google use a number of their own cookies too. Please read our cookies policy here.
How long we keep your information for
We will hold your personal information for as long as it is necessary for the relevant activity. Please see our Records Retention Policy here.
Where we rely on your consent to contact you for direct marketing purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. This will usually be for three years. We may periodically ask you to renew your consent.
If you ask us to stop contacting you with marketing or fundraising materials, we will keep a record of your contact details and limited information needed to ensure we comply with your request.
You have the right to request details of the processing activities that we carry out with your personal information through making a Subject Access Request. Such requests have to be made in writing. More details about how to make a request, and the procedure to be followed, can be found in our Data Protection Policy. To make a request contact us at email@example.com.
You also have the following rights:
- the right to request rectification of information that is inaccurate or out of date;
- the right to erasure of your information (known as the “right to be forgotten”);
- the right to restrict the way in which we are dealing with and using your information; and
- the right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”);
- rights in relation to automated decision making and profiling including profiling for marketing purposes.
All of these rights are subject to certain safeguards and limits or exemptions, further details of which can be found in our Data Protection Policy. To exercise any of these rights, you should contact the Executive Officer at the above address.
If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner’s Office. Further details about how to complain can be found here.
This Policy may be changed from time to time and we will advertise this on our website. If we make any significant changes we will contact you directly with the information.
Do please check this Policy each time you consider giving your personal information to us.