Privacy Notice 

First Class Tailored Solutions (FCTS) 

 

​First Class Tailored Solutions is responsible for all personal data it processes. As the Data Controller, FCTS ensure that it adheres to all Data Protection Act (DPA) 2018 legal requirements. 

 

 

How we use learner  information 

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The categories of pupil information that we process include: 

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• personal identifiers, contacts and characteristics (such as name, unique pupil 

number, contact details and address) 

• characteristics (such as ethnicity, gender, language, and disability) 

• safeguarding information (such as Child Protection information and Child Protection Plan information court orders and professional involvement) 

• special educational needs (including the needs and ranking) 

• medical and administration (such as doctors information, child health, dental 

health, allergies, medication and dietary requirements) 

• attendance (such as sessions attended, number of absences, absence reasons 

and any previous schools attended) 

• assessment and attainment (such as key stage 1 and phonics results, post 16 

courses enrolled for and any relevant results, learner subject reports) 

• behavioural information (such as exclusions and any relevant alternative provision 

put in place) 

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This list is not exhaustive and will be amended as required to fulfil our remit to the learners. 

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Why we collect and use learner information 

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The personal data collected is essential, in order for FCTS to fulfil their official functions and meet legal requirements. We collect and use pupil information, for the following purposes: 

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a) to support learning 

b) to monitor and report on learner attainment progress 

c) to provide appropriate pastoral care 

d) to assess the quality of our services 

e) to keep children safe (food allergies, or emergency contact details) 

f) to meet the statutory duties placed upon us 

g) to evaluate and improve our policies in an alternative education 

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Under the Data Protection Act (DPA) 2018, the lawful bases we rely on for processing learner information are: 

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• for the purposes of (a), (b), (c) & (d) in accordance with the legal basis of Public 

task: collecting the data is necessary to perform tasks that educational organisations are required to perform as part of their statutory function 

• for the purposes of (e) in accordance with the legal basis of Vital interests: to keep children safe (food allergies, or medical conditions) 

• for the purposes of (f) in accordance with the legal basis of Legal obligation: data collected for DfE census information 

o Section 537A of the Education Act 1996 

o the Education Act 1996 s29(3) 

o the Education (School Performance Information)(England) Regulations 2007 

o regulations 5 and 8 School Information (England) Regulations 2008 

o the Education (Pupil Registration) (England) (Amendment) Regulations 2013 

In addition, concerning any special category data: 

• conditions a, b, c and d of GDPR - Article 9 

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Collecting learner information 

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We obtain learner information via registration forms at the start of each referral. In addition, when a child joins us from a referrer we are sent a secure file containing relevant information. 

Learner data is essential for FCTS’ operational use. Whilst the majority of learner information provided to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with DPA we will inform you at the point of collection, whether you are required to provide certain learner information to us or if you have a choice in this. 

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Storing learner data 

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We hold learner data securely for the set amount of time shown in our data retention schedule. 

Who we share learner information with 

We routinely share pupil information with: 

•         educational organisations that the pupil attends after leaving us 

•         learner referrer; Local Authority linked with a particular learner 

•         youth support services (learners aged 13+) 

•         the Department for Education (DfE) 

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Why we routinely share learner information 

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We do not share information about our learners with anyone without consent unless the law and our policies allow us to do so. 

 

Learners aged 13+ 

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Once our learners reach the age of 13, we also pass learner information to our local authority and/or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996. 

  

This enables them to provide services as follows: 

 

• youth support services 

• careers advisers 

 

The information shared is limited to the child’s name, address and date of birth. However, where a parent or guardian provides their consent, other information relevant to the provision of youth support services will be shared. This right is transferred to the child/learner once he/she reaches the age 16. 

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Learners aged 16+ 

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We will also share certain information about learners aged 16+ with our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996. 

This enables them to provide services as follows: 

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• post-16 education and training providers 

• youth support services 

• careers advisers 

Data is securely transferred to the youth support service via a secure file transferring system and is stored within local authority software. 

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Department for Education 

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We are required to share information about our learners with the Department for Education (DfE) either directly or via our local authority and referrers for the purpose of data collections, under: 

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• Section 537A of the Education Act 

• the Education (School Performance Information)(England) Regulations 2007 

• regulations 5 and 8 School Information (England) Regulations 2008 

• the Education (Pupil Registration) (England) (Amendment) Regulations 2013 

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All data is transferred securely and held by DfE under a combination of software and hardware controls, which meet the current government security policy framework. 

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For more information, please see ‘How Government uses your data’ section. 

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Requesting access to your personal data 

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Under DPA, parents and learners have the right to request access to information about them that we hold. To make a request for personal information or to be given access to educational records, contact the Data Protection Officer, see Contact details below. 

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If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/ 

  

Contact 

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If you would like to discuss anything in this privacy notice, please contact: 

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• Mr M Quinton on 0123 626171 or email data.protection@first-class 

• Our local authority 

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How Government uses your data 

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The learner data that we lawfully share with the DfE and referrers through data collections: 

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• underpins school funding, which is calculated based upon the numbers of children and their characteristics in each school. 

• informs ‘short term’ education policy monitoring (for example, school GCSE results or Pupil Progress measures). 

• supports ‘longer term’ research and monitoring of educational policy. (for example how certain subject choices go on to affect education or earnings beyond school) 

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Data collection requirements 

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To find out more about the data collection requirements placed on us by the Department for Education (for example; via the school census) go to https://www.gov.uk/education/data-collection-and-censuses-for-schools 

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The National Pupil Database (NPD) 

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Much of the data about pupils in England goes on to be held in the National Pupil Database (NPD). 

The NPD is owned and managed by the Department for Education and contains information about pupils in schools in England. It provides invaluable evidence on educational performance to inform independent research, as well as studies commissioned by the Department. 

It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including schools, local authorities and awarding bodies. 

To find out more about the NPD, go to 

https://www.gov.uk/government/collections/national-pupil-database 

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Sharing 

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The law allows the Department to share learners’ personal data with certain third parties, including: 

• schools 

• local authorities 

• researchers 

• organisations connected with promoting the education or wellbeing of children in England 

• other government departments and agencies 

• organisations fighting or identifying crime 

 

For more information about the Department’s NPD data sharing process, please visit: 

https://www.gov.uk/data-protection-how-we-collect-and-share-research-data 

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Organisations fighting or identifying crime may use their legal powers to contact DfE to request access to individual level information relevant to detecting that crime. Whilst numbers fluctuate slightly over time, DfE typically supplies data on around 600 pupils per year to the Home Office and roughly 1 per year to the Police. 

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For information about which organisations the Department has provided pupil information, (and for which project) or to access a monthly breakdown of data share volumes with Home Office and the Police please visit the following website: 

https://www.gov.uk/government/publications/dfe-external-data-shares 

  

To contact DfE: 

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https://www.gov.uk/contact-dfe