Privacy, Cookies and Information Rights

Ascent Multi Academy Trust

Website: www.ascenttrust.org.uk

Our Commitment to Data Protection

Ascent Multi Academy Trust is committed to protecting the privacy, confidentiality and security of personal information belonging to our pupils, parents, carers, staff, governors, trustees, visitors and members of the wider school community.

We recognise the importance of handling personal information lawfully, fairly, transparently and securely.

As a Multi-Academy Trust providing education for children and young people with special educational needs and disabilities (SEND), we take particular care when processing sensitive information, including information relating to pupils' health, additional needs, safeguarding and educational provision.

We comply with applicable data protection and information rights legislation, including:

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018, as amended
• Data (Use and Access) Act 2025
• Freedom of Information Act 2000
• Environmental Information Regulations 2004
• Privacy and Electronic Communications Regulations 2003, as amended

This section explains how we protect personal information, the rights individuals have and how to access information held by the Trust.

1. Privacy Notices

The Ascent Trust processes personal information for educational, safeguarding, employment, administrative, governance and statutory purposes.

Our privacy notices explain what information we collect, why it is needed, the lawful basis for processing, who it may be shared with, how long it is retained and the rights of individuals.

The Trust should make the following privacy notices accessible through this section:

Pupil Privacy Notice

Explains how pupil information is collected and processed, including educational records, attendance, special educational needs, safeguarding and statutory reporting.

Parent and Carer Privacy Notice

Explains how personal information relating to parents, carers and family contacts is used for communication, pupil welfare, educational administration and statutory obligations.

Staff Privacy Notice

Provides information about the collection, use, storage and retention of employee information, including recruitment, employment, payroll and statutory reporting.

Recruitment Privacy Notice

Explains how information supplied by job applicants is processed throughout recruitment, safeguarding and pre-employment checks.

Governors and Trustees Privacy Notice

Explains how personal information relating to trustees, governors and those undertaking governance responsibilities is processed.

Website Privacy Notice

Explains how information is collected when individuals visit our website, submit online forms or contact the Trust electronically.

Additional Privacy Notices

Where applicable, separate notices may be provided for contractors, volunteers, visitors, CCTV and other specific processing activities.

Privacy notices are reviewed at least annually and whenever significant changes to data processing activities occur.

2. Data Protection Officer (DPO)

The Ascent Trust has responsibilities under UK data protection legislation to protect personal information and support individuals in exercising their information rights.

Our Data Protection Officer provides independent advice and oversight concerning data protection compliance.

For data protection enquiries, individuals can contact:

Data Protection Officer
Ascent Multi Academy Trust
The Brier School
Bromley Lane
Kingswinford
West Midlands
DY6 8QN

General email: info@ascenttrust.org.uk
Telephone: 01384 816000
Direct DPO contact: [Insert verified DPO contact details]

Please clearly mark correspondence for the attention of the Data Protection Officer.

3. Your Data Protection Rights

Under UK data protection legislation, individuals have a number of rights concerning their personal information.

Depending on the circumstances and the lawful basis for processing, these include:

• Right to be informed: To receive clear information about how personal data is collected and used.
• Right of access: To request access to personal information held about them.
• Right to rectification: To request correction of inaccurate or incomplete personal information.
• Right to erasure: To request deletion of personal information where the legal conditions apply.
• Right to restrict processing: To request limitations on certain uses of personal information.
• Right to data portability: To receive certain information in a structured and commonly used electronic format, where applicable.
• Right to object: To object to certain types of personal data processing.
• Rights concerning automated decision-making: To receive applicable protections where decisions are made solely through automated processing.
• Right to withdraw consent: To withdraw consent where consent is the lawful basis for processing.

These rights are not absolute. Some information must be retained or processed to meet legal obligations, public tasks or safeguarding responsibilities.

Further information is available from the Information Commissioner's Office (ICO).

4. Subject Access Requests

Individuals have the right to request copies of personal information that the Trust holds about them. This is known as a Subject Access Request (SAR).

Requests can be made verbally or in writing, including by email.

To help us process a request efficiently, individuals should provide their name, contact details, the information they are requesting and any relevant dates or circumstances.

Requests can be directed to:

Email: info@ascenttrust.org.uk
Subject: Subject Access Request

Postal address: Ascent Multi Academy Trust, The Brier School, Bromley Lane, Kingswinford, DY6 8QN.

We will normally respond without undue delay and within one calendar month, in accordance with applicable legislation.

Additional time may be permitted where a request is complex or multiple requests have been received. Where clarification is reasonably necessary, the statutory response period may be paused in accordance with current legislation.

We may request proportionate evidence of identity or authority before releasing personal information.

Requests are normally processed free of charge, although limited exceptions apply.

Where a request concerns a pupil, we will consider the pupil's own rights, their understanding and any appropriate parental authority before disclosing information.

5. Freedom of Information

Ascent Multi Academy Trust is subject to the Freedom of Information Act 2000.

The Act provides members of the public with a right to request recorded information held by the Trust, subject to relevant exemptions.

A Freedom of Information request must be made in writing and should include:

• The requester's name.
• A postal or email address for correspondence.
• A clear description of the information requested.

Requests should be submitted to:

Email: info@ascenttrust.org.uk
Subject: Freedom of Information Request

The Trust will respond promptly and within the applicable statutory timescale.

The normal period is 20 working days, although specific rules can apply to requests received by individual schools, including provisions relating to school days and holidays.

Information may be withheld where an exemption applies, including where disclosure would compromise personal privacy, safeguarding or other legally protected interests.

Where information cannot be disclosed, we will explain the decision as required by law.

Freedom of Information Publication Scheme

The Trust is required to adopt and maintain the Information Commissioner's Office model publication scheme.

Our publication scheme and accompanying guide to information should explain how members of the public can access routinely published information across seven categories:

1. Who we are and what we do – organisational information, leadership, governance and contact details.
2. What we spend and how we spend it – financial information, accounts, funding and relevant expenditure.
3. What our priorities are and how we are doing – strategic priorities, development plans and performance information.
4. How we make decisions – governance arrangements, decision-making processes and relevant meeting records.
5. Our policies and procedures – published policies relating to governance, education, safeguarding, finance and administration.
6. Lists and registers – registers and other information required to be available publicly.
7. The services we offer – information about the Trust, its schools and educational services.

Publication scheme: [Insert link to the Trust's adopted ICO model publication scheme]

Guide to information and charges: [Insert link to approved Trust-specific publication guide and schedule of fees]

Information available electronically will normally be provided free of charge. Any permitted charges will be clearly explained.

6. Cookies and Website Privacy

Our website uses cookies and may use similar technologies to support website functionality, improve accessibility, protect website security and understand how visitors use our services.

Cookies are small files stored on a device when someone visits a website.

Depending on the technologies installed, cookies may support:

Essential website functions

These allow core website features, security and accessibility preferences to operate correctly.

Website preferences

These may remember choices such as language or display settings.

Website analytics

Where used, these help us understand how visitors interact with website content so that we can improve the service.

Third-party services

Some embedded services, such as videos, maps or externally provided forms, may use their own cookies or related technologies.

Managing Cookie Preferences

We aim to provide visitors with clear information about the cookies and similar technologies used by our website.

Where consent is legally required, visitors must be able to make an informed choice before the relevant technology is activated.

Certain strictly necessary or otherwise legally exempt technologies may be used without consent, subject to the applicable legal conditions.

Visitors should be able to manage their preferences using the website's cookie controls, where applicable, or their browser settings.

Cookie preferences: [Insert link to cookie settings control]

Detailed cookie list: [Insert verified cookie name, provider, purpose and duration table]

For further information, please visit the ICO's guidance on cookies and similar technologies.

7. Information Storage, Security and Retention

The Ascent Trust is committed to ensuring that personal information is stored securely and retained only for as long as necessary.

We maintain appropriate organisational and technical safeguards to protect information against unauthorised access, accidental loss, damage, alteration and unlawful disclosure.

Personal information is retained according to its purpose, statutory obligations, relevant retention guidance and the Trust's approved retention schedule.

Different retention periods may apply to pupil records, safeguarding information, personnel files, financial records, governance records and website enquiries.

Where personal information is no longer required, it will be securely deleted, destroyed or anonymised, unless continued retention is legally necessary.

Records Retention Schedule: [Insert link to approved retention schedule or public retention summary]

Individuals who would like information about the retention period for particular records can contact the Data Protection Officer.

8. Sharing Personal Information

The Trust may need to share personal information with appropriate organisations where there is a lawful basis to do so.

Depending on the circumstances, these may include:

• The Department for Education and other public bodies.
• Local authorities and educational support services.
• Health and safeguarding professionals.
• Statutory regulators and authorities.
• Approved technology providers and organisations supporting Trust operations.

We only share information where there is an appropriate lawful basis and necessary safeguards.

Where information is processed by external service providers, appropriate contractual arrangements and security requirements will be applied.

Any international transfers of personal information must comply with applicable UK data protection requirements.

The Trust does not sell personal information.

9. Data Protection Complaints

Anyone who has concerns about the way the Trust collects, uses, stores or shares their personal information can raise a complaint.

Complaints can be directed to the Trust's Data Protection Officer using the contact information above.

We will acknowledge data protection complaints within 30 days and take appropriate steps to investigate and respond without undue delay.

Where an individual remains dissatisfied, they may raise their concern with the Information Commissioner's Office.

Information Commissioner's Office
Website: https://ico.org.uk
Telephone: 0303 123 1113

Further information: How to make a data protection complaint.

10. Further Guidance

For independent information about data protection, privacy rights and access to information, please refer to:

• ICO – Guide to lawful basis for processing
• ICO – Subject Access Requests
• ICO – Publication Schemes
• Department for Education – Privacy Notices for Schools

The Trust is committed to reviewing its information management arrangements regularly and making relevant privacy and information-rights guidance readily accessible to the school community.

Form Submissions

We may collect information about your approximate location when you submit a form on our website.

This may include:

• Your IP address
• Geographic location (such as city or region), inferred from your IP address or device data

We collect this information to:

• Identify and prevent fraudulent or malicious activity
• Diagnose technical issues

We process this data under our legitimate interests in operating and improving our website and ensuring its security.

We do not use this information to identify your precise location, and we do not share it with third parties for marketing purposes.

Cookies Used

Necessary

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.