Privacy Notice
Who we are
Sherborne Qatar was founded in 2009 and is a joint venture between Sherborne School and Sheikh Abdullah bin Ahmed Al Thani. Sherborne Qatar is a founding member of the Ministry of Education Outstanding Schools Initiative and is overseen by the Ministry’s Private Schools Office. The Sherborne Qatar group of schools is self-financed, runs not-for-profit schools and has its own Board of Governors, of which Sherborne School has half of the appointed membership.
The current Schools’ addresses are;
• Sherborne Senior School, Mall of Qatar, Doha
• Sherborne Qatar Preparatory School, Umm Al Maa Street, Al Rayyan, Doha
• Sherborne Qatar School for Girls, Rawdat Al Khazna Street, Al Ebb, Doha
The Schools’ office opening hours are Sunday to Thursday 7.00 am – 3.00 pm.
What this privacy notice is for
This policy is intended to provide information about how the Schools will use (or “process”) personal data about individuals including: its staff; its current, past and prospective pupils; and their parents, carers or guardians (referred to in this policy as “parents”). This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents and pupils are all encouraged to read this Privacy Notice and understand the Schools’ obligations to its entire community. This Privacy Notice applies alongside any other information the Schools may provide about a particular use of personal data, for example when collecting data via an online or paper form. This Privacy Notice also applies in addition to the Schools’ other relevant terms and conditions and policies, including:
• any contract between the Schools and its staff or the parents of pupils;
• the Schools’ policy on taking, storing and using images of children;
• the Schools’ CCTV;
• the Schools’ records’ retention policy;
• the Schools’ safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
• the Schools’ ICT policies.
• Anyone who works for, or acts on behalf of, the Schools (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice which also provides further information about how personal data about those individuals will be used.
Responsibility for Data Protection
The Schools’ Bursar will deal with all your requests and enquiries concerning the Schools’ uses of your personal data and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law. The Schools’ Data Administrator Officer Sajna Ali at the email address sajnaali@sherborneqatar.org and can also be contacted at Sherborne Senior School, Mall of Qatar, Doha.
Why the Schools needs to process personal data
In order to carry out its ordinary duties to staff, pupils and parents, the Schools needs to process a wide range of personal data about individuals (including current, past and prospective staff, pupils or parents) as part of its daily operation. Some of this activity the Schools will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with its staff, or parents of its pupils. Other uses of personal data will be made in accordance with the Schools’ legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
The Schools expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
• For the purposes of pupil selection (and to confirm the identity of prospective pupils and their parents);
• To provide education services, including musical education, physical training or personal development, career services, and co-curricular activities to pupils, and monitoring pupils’ progress and educational needs;
• Maintaining relationships with alumni and the Schools’ communities, including direct marketing or fundraising activity;
• For the purposes of management planning and forecasting, research and statistical analysis
• To enable relevant authorities to monitor the Schools’ performance and to intervene or assist with incidents as appropriate;
• To give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any educational institution that the pupil attended or where it is proposed they attend; and to provide references to potential employers of past pupils;
• To enable pupils to take part in national or other assessments, and to publish the results of public examinations or other achievements of pupils of the schools;
• To safeguard pupils’ welfare and provide appropriate pastoral care;
• To monitor (as appropriate) use of the Schools’ IT and communications systems;
• To make use of photographic images of pupils in schools’ publications, on the Schools’ website and (where appropriate) on the Schools’ social media channels in accordance with the Schools’ policy on taking, storing and using images of children;
• For security purposes, including CCTV;
• To carry out or cooperate with any School or external complaints, disciplinary or investigation process; and
• Where otherwise reasonably necessary for the Schools’ purposes, including to obtain appropriate professional advice and insurance for the Schools.
In addition, the Schools will on occasion need to process special category personal data (concerning health, ethnicity, religion) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards safeguarding and employment, or from time to time by explicit consent where required.
These reasons will include:
• To safeguard pupils’ welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual’s medical condition or other information where it is in the individual’s interests to do so: for example for medical advice, for social protection, safeguarding and cooperation with police or social services, for insurance purposes or to caterers or organisers of School trips who need to be aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a pupil;
• In connection with employment of its staff, for example DBS checks;
• As part of any School or external complaints, disciplinary or investigation process that involves such data, for example if there are SEN, health or safeguarding elements; or
• For legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.
Types of personal data processed by the Schools
This will include by way of example:
• names, addresses, telephone numbers, e-mail addresses and other contact details;
• bank details and other financial information, e.g. about parents and other people who pay fees to the Schools;
• identification records (e.g. QID, Passport)
• past, present and prospective pupils’ academic, disciplinary, admissions and attendance records (including information about any special needs), and examination scripts and marks;
• personnel files, including in connection with academic, employment or safeguarding;
• where appropriate, information about individuals’ health and welfare, and contact details for their next of kin;
• references given or received by the Schools about pupils, and relevant information provided by previous educational establishments and/or other professionals or organisations working with pupils;
• correspondence with and concerning staff, pupils, and parents past and present; and
• images of pupils (and occasionally other individuals) engaging in School activities, and images captured by the Schools’ CCTV system (in accordance with the Parents’ Consent policy and the Schools’ policy on taking, storing and using images of children).
How the School collects data
Generally, the Schools receives personal data from the individual directly (including, in the case of pupils, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments). However, in some cases personal data will be supplied by third parties (for example another School, or other professionals or authorities working with that individual); or collected from publicly available resources.
Who has access to personal data and who the school shares it with
Occasionally, the Schools will need to share personal information relating to its community with third parties, such as:
• professional advisers (e.g. lawyers, insurers, PR advisers and accountants);
• government authorities (e.g. The Ministry of Education, police); and appropriate regulatory authorities.
For the most part, personal data collected by the Schools will remain within the Schools, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of:
• medical records (held and accessed only by the Schools’ nurses and appropriate medical staff under his/her supervision, or otherwise in accordance with express consent) and
• pastoral or safeguarding files.
However, a certain amount of any SEN pupils’ relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires. Staff, pupils and parents are reminded that the Schools are under duties imposed by the safeguarding rules and policies to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on personnel or safeguarding files, and in some cases referrals to relevant authorities. For further information about this, please view the Schools’ Safeguarding Policy.
Finally, some of the Schools’ processing activity is carried out on its behalf by third parties, such as ICT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the Schools’ specific directions.
How long we keep personal data
The Schools will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. The Schools sets out the arrangements for record retention and if you have any specific queries about how our policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Schools’ Data Administrator Officer. However, please bear in mind that the Schools will have lawful and necessary reasons to hold on to some personal data even following such request. A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes.
Keeping in touch and supporting the Schools
The Schools and/or any relevant other organisation will use the contact details of parents, alumni and other members of the Schools’ communities to keep them updated about the activities of the Schools, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, the Schools will also:
• Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the Schools’ communities;
• Contact parents and/or alumni (including via the organisations above) by post and email in order to promote and raise funds for the Schools;
• Collect information from publicly available sources about parents’ and former pupils’ occupation and activities, in order to maximise the Schools’ fundraising potential;
• Should you wish to limit or object to any such use, or would like further information about them, please contact the Schools’ Data Administrator Officer in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the Schools are nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Your rights
Individuals have various rights to access and understand personal data about them held by the Schools, and in some cases ask for it to be erased or amended or have it transferred to others, or for the Schools to stop processing it – but subject to certain exemptions and limitations. Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to the The Schools’ Data Administrator Officer at the email address office@sherborneqatar.org and can also be contacted at Sherborne Senior School, Mall of Qatar, Doha. The Schools will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, (which is one month in the case of requests for access to information). The Schools will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the Schools may ask you to reconsider or require a proportionate fee.
Requests that cannot be fulfilled
You should be aware the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations – please see further below), or information which is subject to legal privilege (for example legal advice given to or sought by the Schools, or documents prepared in connection with a legal action). The Schools is also not required to disclose any pupil examination scripts (or other information consisting solely of pupil test answers), provide examination or other test marks ahead of any ordinary publication, nor share any confidential reference nor any confidential reference given by the Schools for the purposes of the education, training or employment of any individual. However, we will sometimes have compelling reasons to refuse specific requests to amend or stop processing (or your child’s) personal details; for example a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such request will be considered on their own merits.
Parental requests
It should be clearly understood that the rules on subject access are not the sole basis on which information requests are handled. Parents may not have a statutory right to information, but they and others will often have a legitimate interest or expectation in receiving certain information about pupils without their consent. The Schools may consider there are lawful grounds for sharing with or without reference to that pupil. Parents will in general receive educational and pastoral updates about their children in accordance with the
Parent Contract. Where parents are separated, the Schools will in most cases aim to provide the same information to each person with parental responsibility, but may need to factor in all the circumstances including the express wishes of the child. All information requests from, on behalf of, or concerning pupils – whether made under subject access or simply as an incidental request – will therefore be considered in a case by case basis.
Consent
Where the Schools are relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Please be aware however that the Schools may not be relying on consent but have another lawful reason to process the personal data in question even without your consent. That reason will usually have been asserted under this Privacy Notice or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation has been requested).
Queries and Complaints
Any comments or queries on this policy should be directed to the Schools’ Data Administration Officer at the email address office@sherborneqatar.org and can also be contacted at Sherborne Senior School, Mall of Qatar, Doha. If an individual believes that the Schools have not complied with this policy or acted otherwise, they should utilise the Schools’ complaints / grievance procedure and should also notify the Schools’ Data Administrator Officer.
