Lettings

Privacy Notice

INTRODUCTION

KES Bookings Limited is the trading subsidiary of King Edward VI School [the ‘School’], managing the trading activities that take place at the School. This includes hires and lettings of Wellington Sports Ground, the School’s Dobson theatre and the School’s sporting, leisure, performance and rehearsal facilities at the Wilton Road site. The registered address of King Edward VI School is Wilton Road, Southampton, SO15 5UQ and Wellington Sports Ground is located at Stoneham Lane, Eastleigh, SO50 9HT.

WHAT THIS PRIVACY NOTICE IS FOR

This policy is intended to provide information about how KES Bookings Limited will use (or “process”) personal data about individuals including customers, suppliers, staff and other interested parties. This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Individuals are all encouraged to read this Privacy Notice and understand KES Bookings Limited’s obligations to its entire community.

This Privacy Notice applies alongside any other information King Edward VI School 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 KES Bookings Limited and King Edward VI School’s other relevant terms, conditions and policies, including:

  • any contract between KES Bookings Limited and its customers or staff;
  • the KES Booking Limited data protection policy
  • the King Edward VI School data protection policy;
  • the King Edward VI School policy on the use of CCTV;
  • the King Edward VI School retention of records policy;
  • the King Edward VI School safeguarding and health and safety policies, including as to how concerns or incidents are recorded; and
  • the King Edward VI School IT policies, including its Acceptable Use policy and e Safety policy.

Anyone who works for, or acts on behalf of, KES Bookings Limited should also be aware of and comply with this Privacy Notice and KES Bookings Limited’s data protection policy for staff, which also provides further information about how personal data about individuals will be used.

RESPONSIBILITY FOR DATA PROTECTION

KES Bookings Limited has appointed the Assistant Head (Digital Strategy) as Data Protection Lead who will deal with all your requests and enquiries concerning the trading subsidiary’s uses of your personal data and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.

Contact: dataprotection@kes.hants.sch.uk

WHAT TYPES OF PERSONAL DATA DOES THE SCHOOL USE?

During our routine activities, we collect, store and process personal data (sometimes sensitive in nature) to effectively manage the various activities occurring at the School.

For example, this could include:

  • names, addresses, telephone numbers, email addresses and other contact information;
  • bank details and other financial information (to allow us to process payments);
  • information about your health and wellbeing (for example, to make reasonable adjustments for individuals with a disability, or if an individual has specific dietary requirements);
  • images of individuals captured by the School’s CCTV system; and
  • information captured by the School’s access control system at Wilton Road.

HOW DOES THE SCHOOL COLLECT MY PERSONAL DATA?

Generally, we receive personal data directly from you, this may be via completion of a form or simply in the ordinary course of interaction with the School (for example letting us know about a change of address or updating your contact information). We may occasionally receive personal data from third parties or intermediaries who are administering your booking.

The School reserves the right to carry out credit and identity checks to ascertain whether any person is a ‘blocked person’ under UK economic sanctions laws, UK anti-money laundering laws, or UK anti-corruption laws.

WHY DOES THE SCHOOL USE PERSONAL DATA?

We need to process a wide range of personal data to facilitate the activities that take place at the School.

For example, we have a legitimate interest to use personal data:

  • to administer your letting and hire of the facilities
  • to arrange bookings, reservations, and classes
  • to process payments and for accounting purposes
  • to identify when you are on King Edward VI School premises or Wellington Sports Ground
  • for security purposes, including CCTV cameras, to make sure the School estate is secure;
  • to maintain the health and safety of all those who live, work and study on the School estate;
  • to safeguard pupils’ welfare whilst customers of the public are using School facilities;
  • for the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law;
  • where otherwise reasonably necessary for the School’s purposes, including to obtain appropriate professional advice and insurance for the School;
  • the commencement of or cooperation with any complaint, disciplinary or investigation process;
  • to enable relevant authorities to monitor the School’s performance and to intervene or assist with incidents as appropriate;
  • for legal and regulatory purposes (for example child protection, diversity monitoring and health & safety) and to comply with its legal obligations and duties of care;

WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SCHOOL SHARES IT WITH

Occasionally, KES Bookings Limited will need to share personal information relating to its community with third parties, such as professional advisers (lawyers and accountants) or relevant authorities (HMRC, police or the local authority).

For the most part, personal data collected by KES Bookings Limited will remain within the School, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).

In accordance with Data Protection Law, some of KES Bookings Limited’s processing activity is carried out on its behalf by approved third parties, such as IT systems, web developers or cloud storage providers, who may store or transfer personal data outside of the UK. This is subject to contractual assurance that personal data will be kept securely and in accordance with the School’s specific directions.

HOW LONG WE KEEP PERSONAL DATA

KES Bookings Limited will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. This is specified in the King Edward VI School’s Data Retention policy. However, incident reports will need to be kept in accordance with specific legal requirements.

If you have any specific queries about how this 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 Data Protection Lead (dataprotection@kes.hants.sch.uk). However, please bear in mind that the school may have lawful and necessary reasons to hold on to some data.

MARKETING

We may wish to make sure our customers know about events, offers, and other products and services we offer that may be of interest. We will always seek your consent before sending you any direct marketing, and you can change your mind about receiving marketing at any time.

If you want to opt out, please email us at dataprotection@kes.hants.sch.uk.

YOUR RIGHTS

Right of access

You have various rights under data protection legislation to access and understand how we store and process your personal data. In some circumstances, you can ask for your personal data to be amended, erased, transferred to another person or organisation, or for us to stop processing your personal data.

The right of access is subject to certain exemptions and limitations, for example when complying with data protection legislation would breach another law. If we are unable to comply with a request for access, we will endeavour to explain the reason why but may not be able to do so in all instances.

When dealing with a request for access, we may be able to respond more quickly to small, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, we may ask you to reconsider, or require a proportionate fee (only as permitted under data protection legislation).

Right of correction or erasure

You have the right to request that any out of date, irrelevant, or inaccurate information is corrected or erased (subject to certain exemptions and limitations).

Right to be forgotten

You may have heard of the ‘right to be forgotten’. However, we can sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your personal data, for example where the processing is to meet a legal requirement. All such requests will be considered on their own merits.

Requests that cannot be fulfilled

The School is unable to comply with requests for:

  • information which identifies, or is about, another person;
  • information which is subject to legal privilege (for example, advice given to the School, or documents prepared in connection with a legal action);
  • erasure of personal data where it would place the School in breach of its statutory and regulatory obligations.

Complaints

If you have any comments or queries about this notice, please send an email to dataprotection@kes.hants.sch.uk or call 023 8070 4561.

If you believe that the School has not complied with this notice or has acted otherwise than in accordance with data protection legislation, you should use the School complaints procedure and should also notify the Data Protection Lead. You can also make a referral to, or lodge a complaint with, the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator.

DATA ACCURACY & SECURITY

The school will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the school of any changes to information held about them.

An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law).

The school will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training.

The School may update this Privacy Notice from time to time. Where there are substantial changes that may affect your rights, the School will use all reasonable endeavours to notify you directly.