VERSION CONTROL
Version: 1.0
Author: Gerard Gray
Date: 12/10/22

POLICY OWNER - Gerard Gray
ACCOUNTABLE EXECUTIVE - Martin Ridgeway

DATE APPROVED
20th February 2023
APPROVED REQUIRED BY
Martin Ridgeway

DATE APPROVED
27th February 2023
APPROVED REQUIRED BY
Policy and Governance Board

OUR CONTACT DETAILS

Name: Gerard Gray, SCL Group Data Protection Officer
Email: dataprotection@wearescl.co.uk
Address: SCL Group, Unit 7, Lakeside Business Park, Sandhurst, Berkshire, GU47 9DN
Telephone: SCL Support Centre, 0345 644 5747
These contact details are correct as of October 2022.

INTRODUCTION

We are dedicated to respecting your right to data privacy and will always do what we must to follow Data Protection rules, such as those in the Data Protection Act (DPA 2018) and the UK General Data Protection Regulation (UK GDPR).

Your personal data is any information that can identify who you are, such as your name or a photograph of your face. It can also mean information that might not reveal who you are by itself, but it could identify who you are if someone has extra information to go with it. For example, your home address by itself is not your personal data, but your address AND your age together might be enough for someone to identify you.

SCL Group’s companies which process personal data are registered with The ICO. You can search for our registrations on The ICO’s website https://ico.org.uk/ESDWebPages/Search

Company name
SCL Education and Training Limited
ICO Registration number - ZA063549

Company name
Soccer Coaching Limited
ICO Registration number - Z525313X

Company name
Youth Development League Ltd
ICO Registration number - ZB389383

We will make sure that personal data we hold about you is:

- Processed lawfully, fairly, and transparently
- Collected and used only for the lawful purposes we have identified
- Limited only to the personal data we need
- Accurate and kept up to date when we need to do so
- Held only for as long as we need; and
- Kept secure

Some personal data is especially sensitive, such as information about your health, or your race. This is called ‘special category data’ and if we have this information about you then we must take extra care to ensure your data is held securely and we only use it for lawful purposes.

We will also make sure we handle your personal data in line with other legislation that sets rules about how we handle your personal data. This legislation includes:

• the Regulation of Investigatory Powers Act 2000
• The Privacy and Economic Communications Regulations 2003
• the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000
• the Communications Act 2003
• the Human Rights Act 1998
• the Defamation Act 1996
• the Equality Act 2010
• the Safeguarding Vulnerable Groups Act 2006

THE TYPE OF PERSONAL INFORMATION WE COLLECT

The personal information we collect about you depends on which SCL service you are using.

If you are studying with SCL Education and Training Limited, we may collect your;

- Name
- Proof of identity (e.g. passport)
- Address, email Address and Contact Phone Numbers, including emergency contact details
- Details relating to your qualifications, such as your Unique Learner Number and your previous qualifications
- Personal information in accident or incident forms when required. Crisis Management Plan guidelines may also require witness statements
- Special Educational Needs (SEN) or Special Behavioural Needs (SBN) details
- Disability information (if relevant)
- Medical information (if relevant)
- Details related to any Safeguarding matters (if relevant)
- Details of any criminal convictions (if relevant)

If you or your child goes to our SCL Active Clubs or Soccer Schools, or part of our Youth Development League, we may collect your;

- Name
- Address, email Address and Contact Phone Numbers including emergency contact details
- Payment details
- Personal information in accident or incident forms when required. Crisis Management Plan guidelines may also require witness statements
- Disability information (if relevant)
- Medical information (if relevant), such as details you provide us on medication forms
- Details related to any Safeguarding matters (if relevant)
- Details of any criminal convictions (if relevant)

This is not a complete list, and there may be times where we will need more details from you to help you achieve your best with SCL, or because we must by law. If we need more information from you, we will always explain why we need it.

HOW WE GET THE PERSONAL 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:

• To verify your eligibility for our programmes
• To run your studies with us through SCL Education or SCL Professional, and help keep you and others safe while doing so
• To take payments and register you/your child on our SCL Active clubs or football holiday clubs, and help keep you/your child and others safe while running the club
• To run the Youth Development League, and keep you and others safe while doing so
• To ensure our compliance with regulatory bodies
• If you have given us consent to do so, to let you know about some of SCL’s products and services we think you might be interested in

If you are studying with SCL Education and Training Limited, we may also receive some personal information indirectly:

Any Safeguarding information or Special Education Needs details that relate to you, so we can support you in your studies and help to protect you from harm. If we are sent this, it will usually come from your previous place of learning.

Sometimes, we also need to process some personal data we hold so we can;

• Meet our contract responsibilities
• Pay salary and benefits to our staff
• Manage holiday and sickness for our staff
• Manage our claims for funding from The ESFA and others
• Manage our staff’s performance and achievement
• Safeguard you, other learners, other customers, our staff and any others
• Meet our responsibilities with regards to equality, diversity and inclusion
• Protect the health & safety of all, and meet our legal requirements with regards to health & safety
• Complete and process accident reports
• Handle disciplinary issues
• Provide education, support and advice to our learners and clients
• Promote our products and services;
• Include information in publications (where we are allowed to use personal data in this way);
• Manage our financial and staffing records; and
• Meet our other legal requirements

We also record CCTV in order to monitor and maintain the security of our head office and for the prevention or detection of crime.

This is not a complete list of purposes for which SCL processes personal data, and there may be times where we will need to process personal data for other reasons. We will always make sure we process your personal data within the law.

DATA RETENTION

We will only hold information about you for as long as we reasonably need, which will usually be for one of the following lawful bases;

- Where applicable, you have given us your consent to do so;
- To meet our contract responsibilities;
- We must hold onto it for a specific time period under law;
- We have a legitimate business interest to do so

We may also hold onto personal data to protect your or someone else’s vital interests (i.e. to help protect someone’s life), or if we need to do so to complete a task in the public interest.

If we are holding onto your personal data on the basis of your consent, you can remove your consent at any time and should contact SCL Support Centre on 0345 644 5747 or by emailing our Data Protection Officer at dataprotection@wearescl.co.uk explaining which personal data about yourself you would like us to delete. If you remove your consent for us to retain your personal data, we must delete it unless we reasonably believe we can’t because one of the other lawful bases applies. We will always explain to you if this is the case.

We retain data in line with our SCL Group Data Retention and Destruction Policy. You can ask for a copy of this policy by contacting our Data Protection Officer at dataprotection@wearescl.co.uk

When destroying information, we will make sure that any information is destroyed by secure means, e.g., by shredding, pulping or burning for hard copy, deletion etc. for electronic/digitised copy. When we need to physically destroy information, will use a trusted ISO-Accredited company and receive a certificate of destruction.

DATA SECURITY

We have an Information Security Policy that all our staff must follow which helps us to protect your personal information data from being lost, stolen or used incorrectly. We also have lots of security measures which we use where necessary to protect your personal data. Some of these may include:

• Lockable cupboards which can only be accessed by specific staff
• Password-protection on staff accounts and on particularly sensitive files
• Password changes at regular intervals
• Password-protected attachments for sensitive personal information sent by email
• Setting up computer systems so staff are only able to access areas of our network they need to do their job
• Not allowing personal data to be taken off site (as hard copy, on laptop or on memory stick) without appropriate safeguarding, such as encryption
• Secure and reliable back-up of data
• Strong and trustworthy IT security features
• Secure data flows across SCL
• Careful consideration and setting rules in place when sharing data with other organisations
• Only sharing data with other organisations where we have a lawful basis to do so
• Strong and secure on-site IT storage of our electronic data
• When destroying information, making sure that any information is destroyed by secure means;
• Constant review of the steps we are taking to help your data remain secure

This is not a complete list of everything we do, and we will always take steps to help make sure that personal data is kept secure.

As much as we can, we will try to make sure that information we hold about you is accurate and up-to-date. We will also try to hold the minimum information we need about you so we can meet the purposes we hold your data.

DATA SHARING

There are times where we may need to share your personal data with other organisations or people. When our only lawful basis to do so is your consent, we will always ask you for your consent before we share your information and you will have the choice whether or not we share your data. You have the option to remove consent at any time. To remove your consent, you can contact SCL’s Support Centre on 0345 644 5747 or by emailing our Data Protection Officer at dataprotection@wearescl.co.uk, explaining which consents you would like to remove.

However, there may be times where we need to share your personal data with other organisations or people for other reasons that do not rely on your consent. This is when one of the following applies:

- We have a contractual obligation.
- We have a legal obligation.
- We have a vital interest (this means protecting someone’s life from harm).
- We need it to perform a public task.
- We have a legitimate interest.
- Another exemption from UK GDPR applies. You can find out more about exemptions by clicking here.

Some of the organisations we share personal data with may include:

• Other Educational bodies or institutions
• Education and Skills Funding Agency (ESFA)
• European Social Fund (ESF)
• OFSTED
• Police or other Law enforcement or investigatory institutions
• Professional bodies, such as solicitors, GPs Child protection agencies
• UK Border Control
• Other organisations so we can complete internal or external audits of our own performance
• HM Revenue and Customs so we can manage our staff’s pay and benefits

This is not a complete list of organisations with whom we may need to share your data. If you have questions about our processing of your personal data, you can contact our Data Protection Officer by emailing dataprotection@wearescl.co.uk

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 personal 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 personal information in certain circumstances
- Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances
- Your right to data portability - You have the right to ask that we transfer the personal 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 will usually have one month to respond to you.

Please contact us at SCL Support Centre on 0345 644 5747 or by emailing our Data Protection Officer at dataprotection@wearescl.co.uk if you wish to make a request, providing details about your request so that it helps us understand what you are specifically asking for.

HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us via the following contact details:

Email: enquiries@wearescl.co.uk
Address: SCL Group, Unit 7, Lakeside Business Park, Sandhurst, Berkshire, GU47 9DN
Telephone: SCL Support Centre, 0345 644 5747

We will need you to provide us with the following:

• a clear, detailed description of what your complaint is about
• copies of any letters or emails or relevant documentation related to the complaint
• any details relating to the compliant if you have raised them previously informally or directly to the person/person responsible for the matter you are complaining about
• your email address or postal address (so we can respond to your complaint)
For written complaints, please send details of the above to the postal address or email address, clearly marking the subject matter of your correspondence
as: Complaint; this will then be directed to a member of our complaints handling team who will allocate to the correct department or member of staff:

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
Website: https://www.ico.org.uk

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time. We will provide you with a new privacy notice when we make any major updates about the way we are handling your personal data. From time-to-time, we may also let you know you in other ways about the processing of your personal information.