Data Processing Statement – West Yorkshire Maths Hub
Introduction
This Data Processing Statement (“Statement”) outlines how we, West Yorkshire Maths Hub, as part of Trinity Multi Academy Trust 1, process personal data in compliance with UK General Data Protection Regulation (GDPR) and other applicable data protection laws in the United Kingdom (UK) in accordance with the Grant Funding Agreement for the Department for Education’s Maths Hub Programme.
Parties acknowledge that for the delivery and participation in the Maths Hub Programme the Department for Education is the Controller and West Yorkshire Maths Hub is the Processor.
Data Controller
Department for Education
2 Rivergate
Temple Gate
Bristol
BS1 6EH
Emma Wharram
emma.wharram@education.gov.uk
Data Processor
Trinity Multi Academy Trust
Trinity MAT
c/o Trinity Academy Halifax
Shay Lane
Holmfield
Halifax
HX2 9TZ
Mr Peter Knight
dataprotection@trinitymat.org
Purpose of Data Processing
The Company processes personal data for the following purposes:
Personal data is processed in order to ensure that West Yorkshire Maths Hub can effectively deliver against the aims of the Maths Hub Programme against it’s Public Task. Personal processing personal data have a duty of confidentiality and undertake annual Data Protection training.
Categories of Personal Data Processed
West Yorkshire Maths Hub may process the following categories of personal data in relation to the Maths Hub Programme:
- Name;
- Contact information such as email address;
- Head Teacher Contact information such as email address;
- Maths Lead Contact information such as email address;
- Job title;
- Organisation;
- Qualifications;
- Images;
- Teacher Reference Numbers
West Yorkshire Maths Hub may process the following categories of data in relation to your access and use of our website:
MAC Address, IP Address, Date and Time, Browser, Operating System, Pages visited, Click throughs.
Categories of Data Subjects:
Staff (incl volunteers & associates), customers/clients/sub-contractors, suppliers, schools, students/parents/teachers, members of the public, complainants & enquirers, representatives of other organisations, individuals captured by closed circuit television images, users of the West Yorkshire Maths Hub website.
Legal Basis for Data Processing
West Yorkshire Maths Hub processes personal data based on the following legal bases:
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. Such as the delivery of the Maths Hub Programme.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). To fulfil our legal obligations, ie HMRC.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. Such as freelance staff.
(a) Consent: the individual has given clear consent to process their personal data for a specific purpose or by accessing the West Yorkshire Maths Hub Website. Where consent is the lawful basis, West Yorkshire Maths Hub will be the Data Controller for the purpose of engaging Sub-Processors, such as a Newsletter.
Recipients of Personal Data
West Yorkshire Maths Hub may share personal data (Name, Work Email, Teacher Reference Number, Head Teacher details, Maths Lead details) with the following recipients:
Workgroup Leads – for the purpose of delivering the Workgroup outcomes (Name and Work Email only).
Participants – for the purpose of delivering the Workgroup outcomes (Name and Work Email only).
National Centre for Excellence in the Teaching of Mathematics (NCETM) via TRIBAL & BASECAMP software – for the purpose for managing Workgroups and delivery against the aims of the Maths Hub Programme.
Sub-processors – for the purpose of delivering West Yorkshire Maths Hub Newsletter (via MailChimp) and organising Workgroups (via EventBrite and Basecamp) where the individual has provided consent. Consent is collected via the West Yorkshire Maths Hub website. Personal data shared with sub-processors is Name, Work Email.
Sub-Processors
West Yorkshire Maths Hub uses the following sub-processors:
| Ser | Sub-Processor | Purpose | Personal Data | Legal Basis |
|---|---|---|---|---|
| 01 | MailChimp | For the distribution of West Yorkshire Hub Newsletters to those who specifically opt in to receive them via our website. | Name, Email | (a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. |
| 02 | Eventbrite | For the organisation of Workgroup events to those who specifically opt in to via our website. | Name, Email | (a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. |
Data Security
West Yorkshire Maths Hub, as Data Processor on behalf of the Department for Education does not transfer or store data outside of the UK or European Economic Area (EEA). Data may be processed outside of the UK/EEA via our sub-processors where you have given consent to do so via our website.
Microsoft Data Centres located in the UK and EEA (Ireland).
Sage UK – International Data Transfers under Standard Contractual Clauses. Privacy Policy: Privacy and Cookies | Sage UK
MailChimp – International Data Transfers under Standard Contractual Clauses and/or International Data Transfer Agreement. Data Processing Addendum: Mailchimp Data Processing Addendum Preview _ Mailchimp.pdf
Eventbrite – International Data Transfers under Standard Contractual Clauses and/or International Data Transfer Agreement. Privacy Policy: Eventbrite Privacy Policy | Eventbrite Help Centre
Data Retention
The West Yorkshire Maths Hub retains personal data for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law (for example HMRC payroll). The longest the data will be processed is for the lifetime of the Maths Hub Programme plus 6 months unless there is a statutory/legal requirement, then it will be held for the duration in accordance with that requirement.
At the written direction of the Data Controller, personal data will be deleted or returned to the Data Controller unless it is required by Law to retain the data.
Where an individual has given their consent to share their data for the purposes of receiving the Newsletter or organising Workgroups via the Sub-Processors then West Yorkshire Maths Hub will delete their data for which we are the controller upon written request and within 10 working days. Otherwise it will be deleted after 3 years.
Individual Rights
As a data subject, you have certain rights under applicable data protection laws, including the right to access, rectify, erase, restrict or object to the processing of your personal data.
West Yorkshire Maths Hub as the Data Processor shall promptly notify the Data Controller if it:
Receives a request from a Data Subject under any Protection Law in respect of Personal Data or a complaint; and,
Ensure it does not respond to that request or complaint except on the documented instructions of the Data Controller or as required by Applicable Laws to which West Yorkshire Maths Hub is subject.
Promptly notify the Data Controller if it receives any communication from a Supervisory Authority (UK Information Commissioners Office) or any other regulatory authority in connection with Personal Data processed under the Maths Hub Programme.
Promptly notify the Data Controller if it receives a request from any third party for the disclosure of Personal Data where the compliance with such request is required or purported to be by Law.
Promptly notify the Data Controller if it becomes aware of a Data Loss Event.
Provide full assistance to the Data Controller in respect of the above.
Support the Data Controller with any reasonable, lawful and contractual request.
Contact Information
If you have any questions or concerns about West Yorkshire Maths Hub data processing activities or this Statement, please contact us at:
Trinity Multi Academy Trust
c/o Trinity Academy Halifax,
Shay Lane, Holmfield, Halifax HX2 9TZ
Mr Peter Knight
dataprotection@trinitymat.org
Or alternatively you have the right to raise any concerns with the Information Comissioner’s Office (ICO) via their website at Make a complaint | ICO
Conclusion
This Data Processing Statement reflects our commitment to ensuring that personal data is processed in compliance with applicable data protection laws, including the UK GDPR. If you have any questions or concerns about our data processing activities, please do not hesitate to contact us.
[1] Information Commissioner’s Office – Register of data protection fee payers – Entry details (ico.org.uk) of which Trinity Academy Halifax is part of.