Privacy Policy

Childbase Partnership Limited (“we,” “us” or “our”) respects your privacy and we are committed to protecting your personal data. This privacy notice will inform you about how we look after your personal data and tell you about your privacy rights and how the law protects you, including:

1. Important information and who we are
2. What personal information do we collect?
3. How is your personal information collected?
4. How will we use your personal information?
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention – How long will you use my personal data for?
9. Your legal rights

We will comply with data protection law and ensure that the personal information we hold on you will be:
• Used lawfully, fairly and in a transparent manner
• Collected for the specified purposes outlined in this policy and not used in any way that is considered to be incompatible with the initial purposes
• Relevant and limited to what is necessary in relation to the purposes defined
• Accurate and kept up to date
• Kept for no longer than is necessary for the purposes defined
• Kept securely

1. Important information and who we are
Purpose of this privacy notice
This Privacy Policy describes how we collect and use your personal information and “you/your” may refer to Parent/Carer of a Child, Children attending our nurseries and Employees. It also refers to families enquiring about childcare and prospective employees.

Controller – who we are
The data controller under this privacy notice is Childbase Partnership Ltd of Kingston House, Northampton Rd, Newport Pagnell, MK16 8NJ. Registered Company No: 2418535.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at dataprotection@childbase.com or please write to Data Protection, Childbase Partnership Ltd of Kingston House, Northampton Rd, Newport Pagnell, MK16 8NJ.

You always have the right to make a complaint at any time about how we process your personal data to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Third-party links
This website (www.childbasepartnership.com and www.childbaseacademy.com) may include links to third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. What personal information do we collect?
Parent/Carer of a child
We will collect, store, and/or use the following categories of personal information:

• Name
• Date of Birth
• Home address
• Telephone numbers, and personal email addresses
• National Insurance number
• Bank account and debit/credit card details
• Photographs where consent has been given (family books & nursery events)
• CCTV images

We may also collect, store and use the following “special categories” of more sensitive personal information:
• Information about race or ethnicity, spoken language and nationality

Children
We will collect, store, and use the following categories of personal information:
• Name
• Date of birth
• Gender
• Home address
• Birth certificate/Passport
• Dietary requirements
• Attendance information
• Photographs and CCTV images
• Emergency contact should parents/carers of a child be unavailable and the emergency contact’s contact details
• Records of your child containing the work of your child whilst at nursery, observations about your child’s development whilst at nursery made by our employees, specific examples of your child’s progress, photographs demonstrating your child’s development whilst at nursery, and personal details of your child
• Records relating to your child e.g. special educational needs information, care plans, common assessment frameworks, speech and language referral forms
• Accidents and pre-existing injuries forms
• Records of any reportable death, injury, disease or dangerous occurrence
• Observation, planning and assessment records

We may also collect, store and use the following “special categories” of more sensitive personal information:
• Information about race or ethnicity, spoken language and nationality.
• Information about health, including any medical condition, health and sickness records.
• Information about incident forms / child protection referral forms / child protection case details / reports.

We may also hold data about children that we have received from other organisations, including other nurseries, local authorities and the Department for Education.

Employees, including Childbase apprentices
We will collect, store, and use the following categories of personal information throughout your employment and for as long as is necessary after the termination of your employment:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Nationality
• 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 and, if different, the date of an Employee’s continuous employment
• Location of employment or workplace
• Copy of driving licence (where applicable)
• Copy of Brith Certificate\Passport (where applicable)
• 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, work history, working hours, holidays, training records and professional memberships)
• Personnel files and training records including performance information, disciplinary and grievance information, and working time records
• Information about your use of our information and communications systems
• Records of any reportable death, injury, disease or dangerous occurrence
• Current Study Status (where applicable)
• Employment Details (where applicable)

We may also collect, store and use the following “special categories” of more sensitive personal information:
• Information about race or ethnicity
• Information about health, including any medical condition, accident, health and sickness records, including:
o where you leave our employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
o details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
o where you leave our employment and the reason for leaving is related to their health, information about that condition needed for pensions and permanent health insurance purposes.
• We will hold information about criminal convictions and other information to allow us to assess whether you meet the disqualification criteria under the Disqualification under the Childcare Act 2006. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so, which includes but is not limited to Disclosure and Barring Service (“DBS”) checks. Where appropriate, 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. We will use information about criminal convictions and offences in the following ways:
o To conduct a DBS check on you, to record the date of the DBS check, the number of the DBS check and the name of the body conducting the DBS check.
o To assess your ongoing suitability for your role

Non-Childbase learners, apprentices and employers
In order to provide our services, we obtain details including:
• Contact details of those we deliver apprenticeship or commercial training to and those who work within an organisation as a point of contact for billing, contracts and decision making
• Residential status – for example, where the apprenticeship programme is funded by the government and requires applicants to have a right to work in the UK
• Current study status – for example, where the apprenticeship programme is funded by the government and needs to be verified for eligibility
• National insurance number/date of birth/gender/disability/ethnicity information
• Feedback we receive and your interest in Childbase Partnership Training Academy of Excellence and its services
• Employment details – this is used to contact the employer of an apprentice/learner and for Trainer Assessor / FS tutor visits as well as employer logins to the e-portfolio systems.
• Emergency contact details of your next of kin or trusted contact in case of an emergency

The information will be obtained from our websites, telephone conversations, emails, written and verbal communications and from records of training sessions or meetings.

We may add information you supply with other information that we obtain from our dealings with you (such as where we have worked with you in the past or you have received training with us in the past).
If you provide information to us about any person other than yourself, you must ensure that they understand how their information will be used and that you are authorised to disclose it to us, and to consent to its use on their behalf, before doing so.

We are allowed to use your personal information in this way to carry out our obligations. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

3. How is your personal information collected?
Parent/Carer of a Child and Children
We collect personal information about you and your child from when you initially enquire about our childcare services, through the registration process and until you stop using our services.

Employees
We collect personal information about you through the application and recruitment process, either directly from you 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.

We will collect additional personal information in the course of job-related activities throughout the period of your employment with us.

Non-Childbase learners, apprentices and employers
Information will be obtained from our websites, telephone conversations, emails, written and verbal communications and from records of training sessions or meetings.

4. How will we use your personal information?
We will only use your personal information listed in ‘What Personal Information do we collect’ when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
• Where we need to perform the contract we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To assess and improve our services (via surveys and feedback)

We may also use your personal information in the following situations, which are likely to be rare:
• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.

Parent/Carer of a Child
Information provided primarily allows us to perform our contracts with you and to enable us to comply with legal obligations. The situations include:
• Your personal information will be shared with local authorities without your consent for funding purposes.
• To report on your child’s attendance
• To be able to contact you or your child’s emergency contact about your child
• To ensure nursery fees are paid

Children
Information provided primarily allows us to perform our contracts with you and to enable us to comply with legal obligations. The situations include:
• Upon consent from you, personal data about your child will be shared with schools for progression into the next stage of their education
• Personal information about your child will be shared with local authorities without your consent where there is a situation where child protection is necessary
• The personal information about your child will be shared with local authorities without your consent for funding purposes
• Ofsted will be allowed access to our systems to review child protection records:
o To ensure we meet the needs of your child
o To enable the appropriate funding to be received
o Report on your child’s progress whilst at our nursery
o To check safeguarding records
o To check complaint records
o To check attendance patterns are recorded
o When your child’s Progress Report is given to you in order for you to pass the same Progress Report to a school for application or enrolment purposes

Employees
Information collected allows us to perform our contracts with you and to enable us to comply with legal obligations. The situations in which we will process your personal information are listed below.
• Making a decision about recruitment or an appointment.
• Checking you are legally entitled to work in the UK.
• Paying you and, if you an employee are deemed an employee for tax purposes, deducting tax and National Insurance contributions (NICs).
• Providing any Employee benefits to you.
• Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.
• Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.
• Administering the contract we have entered into with you.
• Conducting performance and/or salary reviews, managing performance and determining performance requirements.
• Assessing qualifications for a particular job or task, including decisions about promotions.
• Gathering evidence for possible grievance or disciplinary hearings.
• Making decisions about your continued employment, engagement.
• Making arrangements for the termination of our working relationship.
• Education, training and development requirements.
• Dealing with legal disputes involving you, including accidents at work.
• Ascertaining your fitness to work.
• Managing sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor your use of our information and communication systems to ensure compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• 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.

Non-Childbase learners, apprentices and employers
• For processing, vetting and screening applications for apprenticeship roles
• To provide services you request from us
• To track and analyse activity on our website(s)
• To create a contact profile for you so we can provide an enhanced user experience, respect Your preferences and subscription requests
• To maintain opt-in lists for newsletters, offers and other marketing emails
• For dealing with enquiries
• To carry out market research in order to improve our services and offer
• For use in statistics reports, such as Qualification Achievement Rates (QAR)
• To relay dietary information to catering services ahead of events you have registered to attend
• For adequate and non-excessive processing
• Processing necessary for us to support apprentices, employers and other enquiries
• To send you marketing information from time to time after you have completed your apprenticeship or had an employee who has achieved
• For access to our e-portfolio system, Bud and storage on our management information systems
• To contact you in order to re-engage and ensure our services are delivered successfully
• To share with emergency services, safeguarding officers or related agencies with your permission to ensure learner welfare and wellbeing is maintained
• If you are under 18 and your safety or welfare is at risk, then we have a duty of care to pass on confidential information to external agencies
Your personal information may be used by the Department of Education (DFE) to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (PLR). Your information will be securely destroyed after it is no longer required for these purposes.
Prospective Families and Employees
Personal data collected when enquiring about our childcare service or future employment is provided by you and is used to provide the information you have requested or consider your application. We may also use this data to communicate with you, for example, informing you of upcoming events, updates and special offers. See more information in the ‘Marketing’ section of this policy. This data is not shared with any other organisation outside the Childbase Nurseries group.

Marketing
Personal information that has been collected may be used for marketing purposes where consent has been provided.

About our website
On visiting our website, it does not store or capture personal information but merely logs the user’s IP address (Internet Protocol: standard allowing data to be transmitted between two devices) which is automatically recognised by the web server.

When someone visits our site, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identifies of those visiting our website.

Other websites
Our website contains links to other websites. This privacy policy only applies to this website. When you link to other websites you should read their privacy policy.

5. Disclosures of your personal data
We may have to share your personal information with third parties. 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. We require third-parties to respect the security of your data and to treat it in accordance with the law.

Parent/Carer of a Child and Children: Which third-party service providers process your personal information?
”Third-parties” includes third-party service providers (including contractors and designated agents), local authorities, regulatory bodies, schools and other entities within our group. The following third-party service providers process personal information about you for the following purposes:
• Local Authorities – for funding and monitoring reasons (e.g. equal opportunities and uptake of funded hours)
• Regulatory bodies – for ensuring compliance and the safety and welfare of the children
• Schools – to provide a successful transition by ensuring information about the child’s progress and current level of development and interests are shared

Employees: Which third-party service providers process your personal information?
The following third-party service providers process personal information about you for the following purposes:
• Banks and Building Societies for payment of salaries and company expense payments.
• HMRC for tax purposes and National Insurance contributions.
• Pension arrangement operated by a group company with the trustees or scheme managers of the arrangement in connection with the administration of the arrangements.
• Medical Brokers for medical insurance
• Life Assurance
• Car Insurance for company car drivers
• Our Employment Law representatives
• Any training providers and any government administration of the apprenticeship levy

Prospective Families and Employees and non-Childbase learners, apprentices and employers
Marketing data is not shared with any other organisation outside Childbase Partnership Limited.

How secure is my information with third-party service providers and other entities in our group?
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.

6. International transfers
Childbase does not routinely transfer personal data outside of the United Kingdom (“UK”). The most common scenario for this is where you have asked us to do so in the course of us providing services to you or where we have engaged a third party data processor.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK GDPR. For further details, see United Kingdom: UK Adequacy;

(b) where we use certain service providers, we may use specific contracts and agreements approved by the United Kingdom which give personal data the same protection it has in the UK. For further details, see United Kingdom: International Data Transfer Agreement (“IDTA”)

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention – How long will you use my personal data for?
We will only retain your personal data 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.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us.

Changes to our privacy policy
We keep our Privacy Policy under regular review, and we will place any updates here. We may also notify you in other ways from time to time about the processing of your data.

Statutory information about Childbase Partnership Limited
Registered in England and Wales
Registered Company No: 2418535
Registered Office: Childbase Partnership Ltd, Kingston House, Northampton Rd, Newport Pagnell, MK16 8NJ