PRIVACY POLICY

 

SUPER CAMPS LIMITED PRIVACY NOTICE FOR EMPLOYEES, WORKERS, CONTRACTORS AND INTERNS

1 INTRODUCTION
1.1 Super Camps Limited (together “we”, “us”, “our” or “Cognita”) are committed to protecting the
privacy and security of your personal information.
1.2 For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”), we are the data
controller and our trading address is Unit 15, Eyston Way, Abingdon, Oxfordshire, OX14 1TR. Our
ICO registration number is Z7584774. As data controller we are responsible for deciding how we
hold and use personal information about you.
1.3 We also have a Data Protection Policy and Data Retention Policy which we ask you to read carefully.
The difference between those policies and this notice is that the policies set out your responsibilities
within Cognita to follow good data protection standards and behaviour whereas this policy informs
you about how we collect and use personal information about you during and after your working
relationship with us, in accordance with the General Data Protection Regulation (“GDPR”).
1.4 This notice applies to current and former employees, workers and contractors of Cognita. This notice
does not form part of any contract of employment or other contract to provide services.

2 THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data
2.1 We will collect, store, and use the following categories of personal information about you: personal
contact details such as name, title, addresses, telephone numbers, and personal email addresses;
date of birth; gender; marital status and dependants; next of kin and emergency contact information;
National Insurance number; bank account details, payroll records and tax status information; salary,
annual leave, pension and benefits information; start date; location of employment or workplace;
copy of driving licence and/or passport; recruitment information (including copies of right to work
documentation, references and other information included in a CV or cover letter or as part of the
application process); employment records (including job titles, qualifications, work history, working
hours, training records and professional memberships); compensation history; performance
information; disciplinary and grievance information
2.2.3 information about your health, including any medical condition, health and sickness
records; and
2.2.4 information about criminal convictions and offences.

3 HOW IS YOUR PERSONAL INFORMATION COLLECTED?
3.1 We collect personal information about employees, workers and contactors through the application
and recruitment process, either directly from candidates or sometimes from an employment agency
or background check provider. We may sometimes collect additional information from third parties
including former employers, credit reference agencies or other background check agencies.
3.2 We will collect additional personal information in the course of job-related activities throughout the
period of you working for us.
3.3 We may also use CCTV footage to ensure your workplace is safe.

4 HOW WE WILL USE INFORMATION ABOUT YOU?
Lawful bases of processing
4.1 We will only use your personal information when the law allows us to. Most commonly, we will use
your personal information where:
4.1.1 we need to perform the contract we have entered into with you;
4.1.2 we need to comply with a legal obligation;
4.1.3 it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests; and
4.1.4 it is necessary for the purposes of carrying out our obligations in the field of employment
law.
4.2 We may also use your personal information in the following situations, which are likely to be rare:
4.2.1 where we need to protect your interests (or someone else’s interests) (for example, we may
need to use your details without telling you to deal with a medical emergency); or
4.2.2 where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
4.3 We need all the categories of information in the list above (see paragraph 2) primarily to allow us to
perform our contract with you and to enable us to comply with legal obligations. In some cases we
may use your personal information to pursue legitimate interests of our own or those of third parties,
provided your interests and fundamental rights do not override those interests. The situations in
which we will process your personal information are listed below.
4.3.1 making a decision about your recruitment or appointment;
4.3.2 determining the terms on which you work for us;
4.3.3 checking you are legally entitled to work in the UK;
4.3.4 conducting checks through the appropriate government department to ensure that you are
able to teach in accordance with the terms of the employment contract and that you hold
either Qualified Teacher Status or Qualified Teacher Learning and Skills Status;
4.3.5 conducting prohibition from teaching or management checks and/or any other checks or
measures that we are required to undertake as a result of any child protection legislation
from time to time in force;
4.3.6 paying you and, if you are an employee, deducting tax and National Insurance
contributions;
4.3.7 providing you with the benefits as set out in the employment contract or elsewhere;
4.3.8 liaising with your pension provider;
4.3.9 administering the contract we have entered into with you;
4.3.10 business management and planning, including accounting and auditing;
4.3.11 conducting performance reviews, managing performance and determining performance
requirements;
4.3.12 making decisions about salary reviews and compensation;
4.3.13 assessing qualifications for a particular job or task, including decisions about promotions;
4.3.14 gathering evidence for possible grievance or disciplinary hearings;
4.3.15 making decisions about your continued employment or engagement;
4.3.16 making arrangements for the termination of our working relationship;
4.3.17 education, training and development requirements;
4.3.18 dealing with legal disputes involving you, or other employees, workers and contractors,
including accidents at work;
4.3.19 ascertaining your fitness to work;
4.3.20 managing sickness absence;
4.3.21 complying with health and safety obligations;
4.3.22 to prevent fraud;
4.3.23 to monitor your use of our information and communication systems to ensure compliance
with our IT policies;
4.3.24 to send out surveys to you by email as part of our Voice of the Employee campaign which
is our employee survey tool.
4.3.25 to ensure network and information security, including preventing unauthorised access to
our computer and electronic communications systems and preventing malicious software
distribution; and
4.3.26 equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which
justify our use of your personal information.
How we use particularly sensitive personal information
4.4 We may process special categories of personal information (i.e. the sensitive personal data identified
in paragraph 2.2) in the following circumstances:
4.4.1 in limited circumstances, with your explicit written consent;
4.4.2 where we need to carry out our legal obligations and in line with our Data Protection Policy
and/or Data Retention Policy;
4.4.3 where it is needed in the public interest, such as for equal opportunities monitoring or in
relation to our occupational pension scheme, and in line with our Data Protection Policy
and/or Data Retention Policy; or
4.4.4 where it is needed to assess your working capacity on health grounds, subject to
appropriate confidentiality safeguards.
4.5 Less commonly, we may process this type of information where it is needed in relation to legal claims
or where it is needed to protect your interests (or someone else’s interests) and you are not capable
of giving your consent, or where you have already made the information public.
4.6 We will use your particularly sensitive personal information in the following ways:
4.6.1 in relation to leaves of absence, which may include sickness absence or family related
leaves, to comply with employment and other laws;
4.6.2 about your physical or mental health, or disability status, to ensure your health and safety
in the workplace and to assess your fitness to work, to provide appropriate workplace
adjustments, to monitor and manage sickness absence and to administer benefits;
4.6.3 about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your
sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and
reporting; and
4.6.4 we will use trade union membership information to pay trade union premiums, register the
status of a protected employee and to comply with employment law obligations.
Do we need your consent?
4.7 We do not need your consent if we use special categories of your personal information in accordance
with our written policy to carry out our legal obligations or exercise specific rights in the field of
employment law. In limited circumstances, we may approach you for your written consent to allow
us to process certain particularly sensitive data. If we do so, we will provide you with full details of
the information that we would like and the reason we need it, so that you can carefully consider
whether you wish to consent. You should be aware that it is not a condition of your contract with us
that you agree to any request for consent from us.
Information about criminal convictions
4.8 We may only use information relating to criminal convictions where the law allows us to do so. This
will usually be where such processing is necessary to carry out our obligations and provided we do
so in line with our Data Protection Policy and Data Retention Policy. In particular, we require
information about criminal convictions as part of our safer recruitment programme. Given that the
vast majority of our employees will be working with children at some point (the frequency in which
you will be working with children depends on your role at Cognita), it is important that we are more
vigorous in carrying out our criminal checks than organisations in other sectors. Our primary focus is
on the welfare of our pupils.
4.9 Less commonly, we may use information relating to criminal convictions where it is necessary in
relation to legal claims, where it is necessary to protect your interests (or someone else’s interests)
and you are not capable of giving your consent, or where you have already made the information
public.
4.10 We will collect information about criminal convictions as part of the recruitment process or we may
be notified of such information directly by you in the course of you working for us or when you tell us
a part of the recruitment process. We will use information about criminal convictions and offences in
the following ways:
4.10.1 as part of our safer recruitment programme and as part of our deciding whether you are
suitable for the role; and
4.10.2 where it is necessary to take the information into consideration when:
4.10.2.1 a complaint is made against you; or
4.10.2.2 taking disciplinary action against you.
4.11 We are allowed to use your personal information in this way to carry out our legal obligations in
connection with employment and social protection law.
4.12 For further information about the kind of information about criminal records we keep, please see our
Data Retention Policy.

5 CHANGE OF PURPOSE
5.1 We will only use your personal information for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If we need to use your personal information for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.
5.2 Please note that we may process your personal information without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

6 IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
6.1 If you fail to provide certain information when requested, we may not be able to perform the contract
we have entered into with you (such as paying you or providing a benefit), or we may be prevented
from complying with our legal obligations (such as to ensure the health and safety of our workers).

7 DATA SHARING
Why might you share my personal information with third parties?
7.1 We will share your personal information with third parties where required by law, where it is necessary
to administer the working relationship with you or where we have another legitimate interest in doing
so.
Which third-party service providers process my personal information?
7.2 “Third parties” includes third-party service providers (including software providers) and other entities
within our group. The following activities are carried out by third-party service providers: pension
administration, benefits provision and administration and IT services. In particular, we use
Cornerstone OnDemand Limited to provide the “Cornerstone” HR solution, Fuse Universal Limited
to provide “Spark” and Graffiti Group Limited to process payslips. We also use Mimecast to archive
emails and Microsoft SharePoint and DropBox for document management.
How secure is my information with third-party service providers and other entities in our
group?
7.3 All our third-party service providers and other entities in the group are required to take appropriate
security measures to protect your personal information in line with our policies. We do not allow our
third-party service providers to use your personal data for their own purposes. We only permit them
to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
7.4 We will share your personal information with other entities in the Cognita group of companies as part
of our regular reporting activities on company performance, in the context of a business
reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
What about other third parties?
7.5 We may share your personal information with other third parties, for example in the context of the
possible sale or restructuring of the business. We may also need to share your personal information
with a regulator or to otherwise comply with the law.
Transferring information outside the EEA
7.6 The information that we process about you may be transferred to, and stored at, a destination outside
the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary
where, for example, one of our suppliers has a data centre outside of the EEA. We will take all steps
reasonably necessary to ensure that your data is treated securely and in accordance with this privacy
notice and that the appropriate legal safeguards are in place prior to the transfer, for example
ensuring that any contracts between us and the recipient of the information have EU-approved
standard data protection clauses or the country we are transferring the data to is deemed by the EU
Commission as an adequate country.

8 DATA SECURITY
8.1 We have put in place measures to protect the security of your information. Details of these measures
are available upon request. Please also refer to our IT policies.
8.2 Third parties will only process your personal information on our instructions and where they have
agreed to treat the information confidentially and to keep it secure.
8.3 We have put in place appropriate security measures to prevent your personal information from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal information on our
instructions and they are subject to a duty of confidentiality.
8.4 We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.

9 DATA RETENTION
How long will you use my information for?
9.1 We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements. Details of retention periods for different aspects of your personal information are
available in our Data Retention Policy. To determine the appropriate retention period for personal
data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means, and the applicable
legal requirements.
9.2 In some circumstances we may anonymise your personal information so that it can no longer be
associated with you, in which case we may use such information without further notice to you. Once
you are no longer an employee, worker or contractor of the company we will retain or securely destroy
your personal information in accordance with our Data Retention Policy.
10 RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
10.1 It is important that the personal information we hold about you is accurate and current. Please keep
us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
10.2 Under certain circumstances, by law you have the right to:
10.2.1 Request access to your personal information (commonly known as a “subject access
request” or “SAR”). This enables you to receive a copy of the personal information we hold
about you and to check that is correct, and that we are lawfully processing it.
10.2.2 Request correction of the personal information that we hold about you. This enables you
to have any incomplete or inaccurate information we hold about you corrected.
10.2.3 Request erasure of your personal information. You have the right to request that we delete
your personal data where: (a) the personal data are no longer necessary in relation to the
purposes for which they were collected or processed; (b) you withdraw your consent to
processing for which we previously obtained your consent; (c) you object to the processing
and, as a result, we agree to cease that processing (please see paragraph 10.2.4 for more
details); (d) the personal data has been unlawfully processed; and (e) we are required to
erase the personal data in order to comply with the law.
10.2.4 Object to processing of your personal information where we are relying on a legitimate
interest (or that of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground. You also have the right to object
where we are processing your personal information for direct marketing purposes.
10.2.5 Request the restriction of processing of your personal information. This enables you to
ask us to suspend the processing of personal information about you, for example if you
want us to establish its accuracy or the reason for processing it.
10.2.6 Request the transfer of your personal information. In certain circumstances, you have the
right to receive personal data from us in a structured, commonly used and machine readable format and the right to transmit it to a third party organisation.
10.2.7 Right to complain to the ICO. Whilst we would always prefer it if you approached us first
about any complaints or queries you may have, you always have the right to lodge a
complaint with the Information Commissioner’s Office.
10.3 If you want to review, verify, correct or request erasure of your personal information, object to the
processing of your personal data, or request that we transfer a copy of your personal information to
another party, please contact the Data Protection Officer in writing (see paragraph 11).
What we may need from you
10.4 We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.
Right to withdraw consent
10.5 In the limited circumstances where you may have provided your consent to the collection, processing
and transfer of your personal information for a specific purpose, you have the right to withdraw your
consent for that specific processing at any time. Once we have received notification that you have
withdrawn your consent, we will no longer process your information for the purpose or purposes you
originally agreed to, unless we have another legitimate basis for doing so in law.

11 DATA PROTECTION OFFICER
11.1 We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice.
If you have any questions about this privacy notice or how we handle your personal information,
please contact the DPO at Jayne Pinchbeck, Group Legal Director, DPO@Cognita.com. You 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.

12 CHANGES TO THIS PRIVACY NOTICE
12.1 We reserve the right to update this privacy notice at any time, and we will provide you with a new
privacy notice when we make any substantial updates. We may also notify you in other ways from
time to time about the processing of your personal information.

 

Dated 25 May 2018

To view the Cognita General Privacy Policy, please visit https://www.cognita.com/general-privacy-notice-and-cookie-policy/