HARROW SCHOOL ONLINE PARENT AND PUPIL PRIVACY NOTICE

A. Introduction 

1. This Privacy Notice is provided alongside the Standard Terms and Conditions provided when a child is accepted for a place with Harrow School Online (“The School”). The School is owned and operated by Pearson Education Ltd of 80 Strand, London, WC2R 0RL, United Kingdom (“Pearson”).  

2. Personal Data is any information from which a living individual can be identified. The School will need to process the Personal Data of applicants, pupils, parents, guardians and mentors in order to perform its contractual obligations as set out in the Standard Terms and Conditions or because it has a legitimate interest in doing so. Pearson will be the Data Controller in respect of the Personal Data that is processed by Harrow School Online and is registered with the UK Information Commissioner with number Z8321564.  

3. The Types of Personal Data the School will process include names, dates of birth, contact details, nationality, medical and health information (where appropriate), passports or other national identification documents, curriculum and assessment information, attendance records, level of English proficiency, information relating to special educational needs or disabilities, previous school(s) information (including references and assessment data), information relating to safeguarding (where appropriate), images of pupils and the financial information of parents and guardians.    

4. Special Category Data: Some of this is defined as special category or ‘sensitive’ personal data. That information is only processed with the consent of the individual concerned, where it is needed to comply with a legal obligation or if it must be processed to protect a pupil’s vital interests.  

5. Collection: The School collects Personal Data in a number of ways. For example, parents, guardians and mentors will provide Personal Data about themselves and their children in correspondence, forms (including enquiry and application forms), documents, in discussions with the School and via agents or websites. Information about pupils will be gathered directly as part of their tuition and be created and developed by the School over the course of their education at the School. It may also be provided by third parties such as local or government bodies or medical professionals where appropriate.   

6. Data Transfers: The School is operated from the United Kingdom and, as such, the personal data of students living in other countries will be transferred to and processed in the United Kingdom in order to fulfil its contractual obligations. The School may also transfer personal data outside the United Kingdom in the delivery of its services (including to the United States of America) and, where that is the case, it will ensure that appropriate mechanisms are in place to protect any such transfers.  

B. How and why the School uses Personal Data  

7. Admission: The School will use the Personal Data of parents, guardians, mentors, applicants and pupils to make decisions relating to admissions, bursaries, scholarships and the charging and recovery of fees.  

8. Education: The School’s primary purpose is to provide education and learning for pupils, including enabling participation in classes, assignments, exams, assessments and the monitoring and reporting of pupils’ progress and their educational needs. This may include extra-curricular activities and educational content and the facilitation of educational trips and visits.  

9. Safeguarding and pastoral care is a key feature of the School’s offering, as the School strives to provide a safe and secure environment and provide pastoral care to its pupils in order to promote and protect their welfare.  

10. Promoting the School’s interests and objectives, including quality assurance and the marketing of related educational products and services provided by Pearson.  

11. Legal and administrative purposes in order to facilitate the safe and efficient operation of the School and to ensure that the School complies with its legal obligations.  

C. Sharing Personal Data  

12. Competent Authorities: Where it is appropriate and lawful to do so the School may share information with local and national government bodies, the Independent Schools Inspectorate (ISI), the Office for Standards in Education, Children’s Services and Skills (Ofsted) and other regulators or exam boards.  

13. Third Party Service Providers: the School may engage third parties to provide it with services that it needs for its operation, including but not limited to IT service providers, internet service providers, external examiners and assessors, content providers, professional advisers, our insurers and consultants. Personal Data will only be shared with these parties to the extent that is necessary and will always be subject to appropriate confidentiality provisions.  

14. Parents, guardians and/or mentors will be given information, where permitted by data protection legislation, about their children/ wards such as information about their academic record, behaviour and progress.  

15. Educational Providers and employers may be given Personal Data in response to a reference request or in order to verify information that is provided to the School as part of the admission process or for safeguarding reasons.  

16. HARROW SCHOOL for quality assurance purposes.  

17. Consent may be sought from parents, guardians, mentors or pupils where it is appropriate to do so in advance of sharing information with third parties.  

 
D. Data Retention  

18. Secure: The School will securely store the Personal Data in its possession for as long as it is needed for the purposes for which it was originally collected, unless the law requires or permits it to be kept for longer. For example, data may need to be retained to bring or defend legal claims or for quality assurance purposes.  

19. Research: Some Personal Data may be retained for longer than usual for historical research or statistical purposes and where that is the case the School will only keep the minimum amount of data that it needs for those purposes and will also consider the extent to which that data can be anonymised.  

  

E. Rights  

20. Rights: Under certain circumstances individuals have rights under data protection laws in connection with their personal data. Those rights include the right to access personal data, the right to correction, request erasure, object to processing, request the restriction of the processing of personal data, to transfer personal data and to withdraw consent. Please note that some of these rights are qualified and whether they are available may vary depending on the circumstances.      

21. Fee: The School will not charge a fee to provide access to Personal Data (or to enable the exercise of any other rights), but it may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, the School may refuse to comply with a request in those circumstances.  

22. Identity: The School may need to request specific information from individuals to help it confirm identity and verify the right to access Personal Data or to any of the other rights that have been referred to. This is a security measure to ensure that Personal Data is handled in accordance with the law and is not disclosed to anyone that does not have the right to receive it.  

  

F. Questions and Complaints  

23. Contact: Any questions about this policy or the School’s privacy practices (including any requests to exercise rights such as the right to access) should be addressed to our Data Protection Officer in the following ways: 

Email: dataprivacy@pearson.com  

Postal address: Data Protection Officer, Pearson Education Ltd, 80 Strand, London, WC2R 0RL, United Kingdom.  

24. Complaints: Individuals have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, the School would appreciate the opportunity to address any concerns before the ICO is approached.