Privacy policies for ISC websites, alerts and newsletters

The Independent Schools Council (ISC) (the Data Controller) is a membership association made up of schools within the membership of one of the five Heads’ associations. The ISC is a not-for-profit company, limited by guarantee, registered with Companies House (registered number 1103760).

The ISC collects, holds and uses personal information in a number of ways, and the purpose of this notice is to explain to you how we do this, and why, and to give you information about your rights.

MEMBERS – individuals from member schools, associations, affiliated organisations or school groups

As you are an individual from an ISC member school, association, affiliated organisation or school group, then ISC may collect, hold and use personal information about you in order to: administer your membership, provide you with sector updates, invite you to participate in research projects or contact you in relation to the annual Census and other surveys run by ISC.

We collect and hold contact details for you, including name, title and email address, phone number, job title and school or organisation name. We may also collect your postal address, depending upon the way you have been in touch and the way that we communicate with you. We may also display your details, including name and contact information on our websites or newsletters when you have provided content to us.

If you are a head or a member of an ISC group or association, then we may publish your name and contact details on the website. This is because it is a legitimate interest of ours to promote our members and our groups and provide information to the public. The information that is published is professional information only.

Please contact [email protected] for more details or if you have any concerns.

In addition, the ISC may collect from you other categories of personal data you submit to us via the Member Zone. This may have originated from your school’s responses to the Annual Census or was provided directly to us by you via the Member Zone. This may include personal data included in school partnerships and case studies, images which identify individuals, details of sponsored schools and school impact statements and statistics. We strongly advise schools not to include personal data in these submissions.

In most instances the lawful basis on which we rely to hold, share and otherwise process your data is ‘legitimate interests’. The purpose of ISC is to support our members and the independent school sector generally, and it is in our interests to communicate relevant information to you. It is a legitimate interest of ours to ensure that the information that we hold about your school is correct. It is also in the legitimate interests of the School Partnerships Alliance (SPA) where your data is shared with them as set out in ‘Sharing your data and third-party processors’ below.

We keep this information for as long as you remain a member or for as long as you remain subscribed to our email newsletters.

You can unsubscribe from any email newsletter at any time, by clicking the unsubscribe link at the bottom of our emails, by emailing [email protected] or by writing to us at The Independent Schools Council, Second Floor, 23 Buckingham, London, SW1E 6LB. ISC Member Zone users can also update their email subscription preferences in the Member Zone. We will keep your name and email on a "do not contact" list to keep a record of your preference.

ISC may use publicly available sources of information to comply with our legal duty to hold accurate and up to date information. The legal basis for this is legitimate interest.

Sharing your data and third-party processors

We regularly share certain personal data with the SPA to support SPA’s website which promotes partnership working between state and independent schools, following the archiving of the ISC Schools Together website. This includes the submissions you make via the Member Zone. Your data will only be transferred within the United Kingdom and we have in place a data sharing agreement with SPA to ensure your data is protected and secure. Please also see the SPA privacy notice on their website for details of how your data will be handled by them here.

If you wish to opt out of your data being shared with SPA, you can do this at any time and we will contact SPA to ensure it deletes the relevant personal data upon notification by ISC. To opt out or raise any concerns, please contact [email protected].

We use Crumpled Dog to administer our website, and they may have access to your data. We have an agreement in place with them to protect your information where this happens.

We also use Mandrill and Campaign Monitor to send out our email newsletters and email alerts.

Mandrill is part of Mailchimp with whom we have an appropriate agreement in place with them to protect your information. Mailchimp's servers are based in the U.S., meaning that your data is transferred outside of the EEA. Mailchimp is covered by Intuit's certification under the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework. More details of the current certification are available here: https://www.dataprivacyframework.gov/participant/7693

Campaign Monitor maintain administrative, physical and technical safeguards for protection of the security, confidentiality and integrity of personal data uploaded to the Campaign Monitor Services, as described on Campaign Monitor’s Security Page: https://www.campaignmonitor.com/trust/security/

We may also need to pass your information to other third parties such as professional organisations who we employ to provide us with advice, or to certain bodies where we might be legally required to do so. For more information on this, please contact [email protected].

Occasionally, we will use a third party who hosts information outside of the EEA. Should this occur, we will ensure that we have an appropriate agreement in place with them, which protects your personal data. For more information on this, please contact [email protected].

Your rights

Under the General Data Protection Regulation (EU 2016/679) and the UK Data Protection Act 2018, you have certain rights associated with the use of your data. These include the right of access, the right to object to certain types of use of your information, the right to request rectification or erasure of information, and the right to request your information in a portable format. Not all of these rights are absolute. More information can be found on the Information Commissioner's website at: https://ico.org.uk/.

If you believe that ISC has not complied with this privacy notice or has acted otherwise than in accordance with Data Protection Law, you have the right to make a data protection complaint directly to the ISC by contacting [email protected] or writing to the Independent Schools Council, Second Floor, 23 Buckingham Gate, London SW1E 6LB. The ISC will acknowledge your complaint within 30 days of receipt and will investigate and inform you of the outcome of your complaint without undue delay.

If you are not satisfied with how we are processing your personal data, or how we deal with your complaint, you can make a complaint to the Information Commissioner’s Office at www.ico.org.uk. The ICO does recommend that you seek to resolve any issues with the data controller initially prior to any referral.

Should you want more information, or you would like to exercise any of these rights, please contact: [email protected]

NON-MEMBERS - website users, email subscribers and website content contributors

We collect and use your contact details, including name and email address, in order to: answer your questions, securely pass your information to the relevant schools as you have requested, or send you email alerts to which you have subscribed. We may also display your details, including name and contact information on our websites or newsletters when you have provided content to us.

The lawful basis on which we rely to do this is legitimate interest. You have requested information from us, or one of our member schools, and we are using the information to facilitate this. Or you have provided us with content for our websites.

We keep enquiry information for two months, after which it is deleted. The information is stored on a secure area of our website which only the schools you have selected can access. For content contributors we will keep your details for as long as the content is displayed.

For email sign-ups, we keep the information as long as you remain subscribed to the relevant newsletter. You can unsubscribe from any newsletter at any time, by clicking the unsubscribe link at the bottom of the email, by emailing [email protected] or by writing to us at The Independent Schools Council, Second Floor, 23 Buckingham Gate, London, SW1E 6LB. We will keep your name and email on a "do not contact" list to keep a record of your preference. (and/or [email protected] for sign-ups to the ISC APPG site on independent education.)

Sign-ups made through the ISC APPG website on independent education may also be shared with officers within the APPG.

ISC may use publicly available sources of information to comply with our legal duty to hold accurate and up to date information. The legal basis for this is legitimate interest.

Sharing your data and third-party processors

We use Crumpled Dog to administer our website, and they may have access to your data. We have an agreement in place with them to protect your information where this happens.

We also use Mandrill and Campaign Monitor to send out our email newsletters and email alerts.

Mandrill is part of Mailchimp with whom we have an appropriate agreement in place with them to protect your information. Mailchimp's servers are based in the U.S., meaning that your data is transferred outside of the EEA. Mailchimp is covered by Intuit's certification under the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework. More details of the current certification are available here: Mailchimp/Intuit Data Privacy Framework certification Campaign Monitor maintain administrative, physical and technical safeguards for protection of the security, confidentiality and integrity of personal data uploaded to the Campaign Monitor Services, as described on Campaign Monitor’s Security Page:

https://www.campaignmonitor.com/trust/security/

We may also need to pass your information to other third parties such as professional organisations who we employ to provide us with advice, or to certain bodies where we might be legally required to do so. For more information on this, please contact [email protected].

Occasionally, we will use a third party who hosts information outside of the EEA. Should this occur, we will ensure that we have an appropriate agreement in place with them, which protects your personal data. For more information on this, please contact [email protected].

Your rights

Under the General Data Protection Regulation (EU 2016/679) and the UK Data Protection Act 2018, you have certain rights associated with the use of your data. These include the right of access, the right to object to certain types of use of your information, the right to request rectification or erasure of information, and the right to request your information in a portable format. Not all of these rights are absolute. More information can be found on the Information Commissioner's website at: https://ico.org.uk

If you believe that ISC has not complied with this privacy notice or has acted otherwise than in accordance with Data Protection Law, you have the right to make a data protection complaint directly to the ISC by contacting [email protected] or writing to the Independent Schools Council, Second Floor, 23 Buckingham Gate, London SW1E 6LB. The ISC will acknowledge your complaint within 30 days of receipt and will investigate and inform you of the outcome of your complaint without undue delay.

If you are not satisfied with how we are processing your personal data, or how we deal with your complaint, you can make a complaint to the Information Commissioner’s Office at www.ico.org.uk. The ICO does recommend that you seek to resolve any issues with the data controller initially prior to any referral.

Should you want more information, or you would like to exercise any of these rights, please contact: [email protected].