Privacy Policy

Lyonsdown School

Website Privacy Notice

This document explains how we use your personal data.

We are committed to ensuring the privacy of our students, parents, alumni and other website visitors. In this notice we explain how we hold, process and retain your personal data.

1. How we use your personal data
   • This section provides you with information about:

• what personal data we hold and process;
• in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
• the purposes for which we may process your personal data; and
• the legal grounds on which we process your data.
  • Contact Data. We may process information that you provide to us via a form on our website (“Contact Data“). This Contact Data may include your name, address, telephone number, email address, gender and title.

We may use Contact Data to provide you with information about our education services and events (including open days), to provide you with a copy of the school prospectus, and to contact you about your child’s admissions to the school. The Contact Data may be processed in this way for the purpose of taking steps, at your request, prior to entering into a contract.

When we send you details about open days by post using your Contact Data, we do so on the basis of our legitimate interests in promoting the school.

• Marketing Survey Data. We may process information that you provide to us when responding to questions about the impact of our marketing (“Marketing Survey Data“). These optional questions are asked when you request a prospectus via our website form. Marketing Survey Data may include information about where you heard about the school, whether you had seen any school adverts in various locations, and whether you found the information on our website useful.

The legal basis for processing is your consent.

• Your Child’s Data. During the course of visiting our website, you may provide us with the personal data of a child to whom you are a parent or guardian (“Your Child’s Data”). We may process Your Child’s Data in order to take steps, at your request, prior to entering into a contract. This may include sensitive personal data, such as religion, nationality and SEND of your child, if you complete the waiting list form.

The legal basis for processing is your explicit consent given on behalf of your child.

• Website Data. We may process data about your use of our website and services (“Website Data“). The Website Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the Website Data is our analytics tracking system. This Website Data may be processed for the purposes of analysing the use of the website and services.

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

• Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2. Providing your personal data to others
   • To our partner service providers. We may also disclose your personal data to Innermedia Ltd (a company registered in England and Wales under number 04818830), provider of our website hosting facilities, whose functions include processing of personal data for the purposes of improving our website and services for you.
   • Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
   • Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.
   • To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.
3. Transfers of your personal data outside of the European Economic Area

Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an “adequacy decision” with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.

4. Retaining and deleting personal data
   • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   • Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:

• Contact Data will be retained until your child reaches the age of 5 and, if your child does not attend the school, it will be deleted from our systems at that point. If your child attends the school, the Contact Data will be retained in line with our Retention of Records Policy which is available on our website.
• Marketing Survey Data will be retained for 1 year following the date you submitted the prospectus request form, at the end of which period it will be deleted from our systems.
• Your Child’s Data. If you provide Your Child’s Data in a waiting list form, it will be held throughout the time your child is or could be at the school. The exception is where your child has refused an offer of admission to the school. In this situation we will delete Your Child’s Data at the end of the admissions process for the relevant year group’s cohort.

If you provide Your Child’s Data in a prospectus request form it will be retained in line with the retention period for Contact Data (as above).

• Website Data will be retained for 2 year following the date of our last contact with you, at the end of which period it will be deleted from our systems.
  • We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Amendments
   • We may update this notice from time to time by publishing a new version on our website.
   • You should check this page occasionally to ensure you are happy with any changes to this notice.
6. Your rights
   • You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

• your request not being found to be unfounded or excessive, in which case a charge may apply; and
• the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
  • We may withhold personal information that you request to the extent permitted by law.
  • You may instruct us at any time not to process your personal information for marketing purposes.
  • In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
  • The rights you have under data protection law are:
• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent.
  • Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
  • Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
  • Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
  • Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
  • Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
  • Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
  • Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
  • Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.

7. Cookie Policy

For information about how we use Cookies please see our Cookie Policy at https://www.millhill.org.uk/cookie-policy/

8. Our details
   • This website is owned and operated by The Mill Hill School Foundation.
   • We are a Private Limited Company in England and Wales under registration number 03404450, and our public address is at Walker House Millers Close, Off The Ridgeway, Mill Hill, London, NW7 1AQ.
   • You can contact us:

• by post, using the postal address given above;
• by telephone, on the contact number published on our website from time to time; or
• by email, using the email address published on our website from time to time.

9. Privacy and Compliance Officer: Maxine Zeltser

Our Privacy and Compliance Officer’s contact details are compliance@millhill.org.uk.