Privacy & GDPR Statement and Data Sharing Protocol


1. Schools Alliance for Excellence (Website) Privacy Statement 

Schools Alliance for Excellence (“We/SAfE”) recognises the importance of protecting your personal and financial information when you visit our “Website”. This Privacy Statement which includes our Cookies Policy, is designed to help you understand the information collection practices on all Websites owned or operated by or on behalf of SAfE companies, including (but not limited to) and and any local variations that may be created from time to time, as required.

This Privacy Statement relates to data collection via our Website and should be read in conjunction with any other applicable policies, terms, and conditions in place between you and SAfE.

SAfE is committed to:
(a)   protecting the personal information you provide to us;
(b)   telling you how we use the information we collect from you; and
(c)   ensuring that you know the circumstances under which we may disclose your personal data.
1.    Relevant Data Protection Laws
Personal Data collected via SAfE websites is processed as set out herein and in accordance with the requirements of “Relevant Data Protection Laws” meaning EU Data Protection Laws including the EU General Data Protection Regulation (2016/679) (“GDPR”) once it becomes effective on 25 May 2018, and, to the extent applicable, the data protection or privacy laws of any other country.

2.    Definitions
“Personal Data” means any information held by SAfE which can identify an individual such as his / her name, address, email address, date of birth etc, from which that Individual can be directly or indirectly personally identified and includes information such as identification and account numbers and online identifiers.  Some of this Personal Data may include “Special Categories of Personal Data” (previously known to as “sensitive Personal Data”), relating to an individual’s race, ethnicity, health, political opinions, trade union membership, as well as Personal Data related to criminal matters.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

3.    Personal information collected
SAfE may typically collect the following information about you through our websites if you submit a complaint in relation to regulatory compliance: name, contact details, email address, postal address, phone numbers etc.  This is not a definitive list and details may change from time to time. 

4.    Purposes
Personal information collected by SAfE may be uses for some or all of the following purposes. 
•    For our internal business administration and record keeping purposes.
•    For the development and delivery on line of the expertise directory.
•    To provide you with information about our products and related services, to facilitate your online purchases and for all other administration as may be necessary in relation to the supply of our products and related services and the conduct of our business.
•    To respond to your complaints, enquiries or comments submitted through this Website.
•    As may otherwise be necessary for responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations.
•    This is not a definitive list and may change from time to time.

5.  Special Categories of Personal Data 
SAfE may, in limited circumstances, collect and process Special Categories of Personal Data as well as Personal Data relate to criminal matters, in connection with its obligations under applicable laws, which will only be used and disclosed, as necessary, for such purpose.

6.    IP Addresses
An IP address is a number which recognises the computer or other device used to access the Internet and under GDPR, an IP address is “Personal Data”. Typically, a web server automatically collects IP addresses and uses them to administer a website. IP addresses are typically used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access this Website. For further details see “Cookies Policy” below.

7. Personal Information received from a Third Party  
Where SAfE is provided with Personal Data relating to an individual by someone other than that individual, such as a beneficial owner, partners, directors, officers, employees, advisors or other related persons, the person providing the information will be asked to warrant that it will only do so in accordance with Relevant Data Protection Laws, and that it will ensure that before doing so, the individuals in question are made aware of the fact that SAfE will hold information relating to them and that it may use it for any of the purposes set out in this Privacy Statement, and where necessary, has obtained the individual’s consent to the SAfE’s use of the information.  SAfE may, where required under applicable laws, notify individuals whose personal information was received indirectly from a third party, and confirm that SAfE holds their Personal Data and provide a copy of this Privacy Statement to them.

8. Updates to Personal Data
SAfE will use reasonable efforts to keep Personal Data up to date.  However, SAfE must be notified, without delay, of any change in an individual’s personal circumstances by the individual or the person that provides such information on behalf of the individual.  

9. Retention of Personal Data
SAfE is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.  

SAfE is obliged by law to retain identification and transaction records for six (6) years from the end of the relevant relationship or the date of the transaction respectively.  

Other information will be retained for no longer than is necessary for the purpose for which it was obtained by SAfE or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, SAfE (or its service providers on its behalf) will hold this information for a period of  seven (7) years, unless it is obliged to hold it for a longer period under law or applicable regulations.

SAfE may also retain records of telephone calls and any electronic communications for any length of time as required by any relevant regulatory entity or as required by relevant local laws including those relating to data privacy and security. 

10.    Individual’s Rights in relation to Personal Data
An individual may at any time request a copy of his / her Personal Data from SAfE.   

An individual also has the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of his / her Personal Data, and to object to certain uses of his / her Personal Data, in each case subject to the restrictions set out in applicable data protection laws.  

[In any case where the Manager \is relying on an Individual’s consent to process his / her Personal Data, the Individual has the right to change his / her mind and withdraw consent by writing to the address specified below.]   

When SAfE is relying on the basis of legitimate business interest to use and/or disclose Personal Data, an individual is entitled to object to such use of his / her Personal Data, and if he /she does so, SAfE  may cease to use and process the Personal Data for that purpose unless it can show there are compelling legitimate reasons for it to continue using the Personal Data in that way or it needs to use the Personal Data for the purposes of legal claims.  

In limited circumstances, an individual may also have the right to data portability in respect of certain of his / her Personal Data, which means he / she can request that SAfE provides a copy of his/her disclosable Personal Data, to him / her or his / her third party nominee. 

An Individual also has the right to lodge a complaint with the relevant Supervisory Authority about the processing of his / her Personal Data by the Manager and the Fund.  

To exercise any of these rights, please send confirmation of your request, by email or post, to the address below, specifying which SAfE products or services your request relates to and providing any other relevant identifying information: 

•    Data Privacy Manager,   

11.  Complaints (applicable to SAfE [UK Affiliates only])
If you would like to contact us in relation to any service or product you may write to the Complaints Officer, or you can email or phone; contact details are provided below. Any complaint will be handled in accordance with our internal complaints handling procedures. 

12. Cookies
This site may use cookies or other information software to retrieve information about a visitor to the site. SAfE does not, however, collect information sufficient to identify any individual nor will it use cookies or other information software to process personal data as defined by relevant data protection laws. Retrieved information will be limited to such information as is sufficient to identify the number of individual visitors to the site.  

13. Changes to this Privacy Statement
The most recent version of this Privacy Statement will be posted on the website .
This version dated: 09 September 2019


2. Schools Alliance for Excellence Data Sharing protocol 


School / Personal information. In providing support and services to you, we will collect data shared by you on behalf of your school; this may be ’school’ data or ‘personal’ data of your staff and in some cases pupils and pupils’ families. We do this only to provide the kind of support and services which we offer, i.e. our lawful purposes. We will not share this data except with our advisers, subcontractors and consultants (where it is necessary to do so) or with third parties, unless required to do so by law.

GDPR. We will;

(a) implement appropriate technical, security and organisational measures to protect school and personal data against accidental loss, destruction, damage, alteration or disclosure;

(b) keep records of data processing;

(c) keep school/personal data connected to each school / member separate from that related to other schools;

(d) ensure that our personnel and sub-contractors are subject to a duty of confidentiality;

(e) not transfer school/personal data out of SAfE;

(f) notify you of any data subject access request;

(g) notify you of any breach of data protection law;

 (h) provide reasonable assistance if you are carrying out a data protection assessment or audit.

This version dated: 17 October 2019



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