Document History:
First Published 09/2016

Policy Review Date:
August 2017

Live on website ver-1e

Data Protection Policy
This document explains how data is managed in the organisation. It applies to all staff and volunteers.

Any queries about this policy should be sent to the document editor identified in 1.1 via contactus@edlumino.org

This document should be interpreted in line with the standard policy context and definitions. The editor of this document is the COO who can be contacted via contactus@edlumino.org, who is also the data handler for the organisation. This document is implemented from 1st June 2016.

2     General Principles and practices


Data will be collected and held in line with the requirements of Data Protection legislation, and the guidance of the Information Commissioner’s Office (ICO).

Data will be held in the EU, wherever possible. However third party data handers (such as international IT companies) may occasionally process or store data in other domains. The organisation will only work with 3rd party data handlers storing data in other domains, when the levels of overall IT security afforded by the companies significantly outweighs the risks.

Staff will only process data on official accounts and equipment which the organisation can ensure adhere to appropriate legislation and security standards. The use of storage devices (such as ‘memory sticks’ etc) is not allowed. Data should only be stored in secure areas online and accessed and saved back to those areas. Transmission of data to other places should only take place when it is not possible to send a link or other mechanism which would enable the accessing of the data in its secure location.

Data will not be shared or disclosed without the permission of the data subject, except in the matter of authorised disclosures. These include: data requests from statutory bodies, requests to authorised recipients of child welfare, Data given to parents on behalf of children, payroll and administrative matters, and matters relating to the detection and prevention of crime.

3      Freedom of Information (FoI) and Subject Access Requests (SAR)


FoI and SAR requests should be sent to ‘contactus@edlumino.org. Requests will be processed upon receipt of the fee (as recommended by the ICO) and additionally, in the case of SAR requests, once the identity of the requester has been confirmed.

Requests should include full contact details of the person making the request and any relevant information to focus the search. Generalised requests may fall under the legislation exemption for ‘unstructured requests,’ which allows an organisation to decline to provide the requested information. It is therefore important to give as much detail as possible about what is being requested. In the case of SAR requests, this should include details of which staff have had interactions and which sites or aspects of the organisation there has been interaction with.

4     Data retention policy

Information about allegations against staff will be kept (in line with DfE advice) until the member of staff concerned reaches retirement age. General staff files and information will be kept for up to 3 years in order to enable the writing of references, or the dealing with any subsequent employment queries. 

Student information will only be kept for 3 years, (or to the age of 25 for vulnerable students) except for such limited information as may be necessary to defend against subsequent claims against the organisation.

This Policy has been Impact Assessed for Environment and Equality considerations. Policy review follows the Review cycle.

Impact Assessment  : Edlumino Data Protection Policy
Equality Impact Assessment : Race & Ethnicity, Gender, Age, Religion, Disability, Sexuality, Maternity, Gender Reassignment, Marriage & Civil Partnership, Deprivation

Concerns arising after control measures added : NONE

Further Action : NONE
Environmental Impact Assessment : Waste & Recycling, Pollution of water, land, air, noise, light or odour. Flooding, Energy or materials use.

Concerns arising after control measures added : NONE

Further Action : NONE

See Also :  General assessments and general control measures within the Meta Policy

Assessment carried out by : RF March 2016

Appendix  : Definitions of words used in Policies and Procedures
In general, English words are assumed to have the meaning and reference contained within the Oxford English Dictionary. Specialist terminology relating to Education is taken as having the meaning given to it in the appropriate English parliamentary legislation or English Government documents (especially those from the Department for Education).

Within the organisation we give our own additional definitions as follows:

‘associate volunteers’: are individuals who volunteer and work alongside organisational staff, but are not formally enrolled within the organisation. These individuals may belong to other charities (such as Save the Children, etc), in which case they are ‘corporate associate volunteers,’ or they may be self sponsoring and working on their own behalf, in which case they are ‘sole associate volunteers.”’
‘directors’: are the trustees.

‘Editor’: the member of staff who is deemed to ‘own’ a document and is responsible for ensuring that it is published, reviewed, amended and kept accurate and up to date

‘member’:  the individuals in charity law responsible for appointing the trustees. In Edlumino Education Aid the trustees are the members, and they are a self-regulating body.

‘Organisation’:    The organisation is Edlumino Educational Aid

‘school’: refers to any place where learning is delivered by a member of staff to pupils, as a corporate act of the organisation. This could be a school, an academy or some other formal or informal setting.

‘staff’:  refers principally to employed members of the organisation. However the word ‘staff’ is used in organisational documents as a simple way of referring to all who work on behalf of the organisation, so it includes ‘trustees’, ‘members’, ‘volunteers,’ ‘visitors,’ etc.

‘student’: there is a customary distinction between ‘pupils’ who are learners up to the age of 16 and ‘students’ who are post 16 learners. We use the word ‘student’ to refer to all learners, regardless of age.

‘Studium’: is an Edlumino centre where education, or emergency education is provided. This term is used for centres where words such as ‘school’ or
‘education’ could be misconstrued or mistakenly viewed as having political connotations.

‘Supporter’: this is a person who undertakes to fund raise or carry out other activities which support the organisation. Supporters are not formally part of the organisation and have no formal rights or responsibilities within the organisation.

‘teacher’: a member of staff responsible for ensuring that students learn. This could include those who are formally qualified as teachers, those who are experienced as teachers, or it could include individuals who are delivering aspects of a role which could otherwise be done by teachers.

‘trustees’: those appointed by trustee vote to the body of trustees responsible for the organisation

‘volunteer’:  an individual who donates time to work for the organisation. Individuals only become ‘volunteers’ from the point that they complete their induction and are enrolled as a volunteer. Volunteers have no contractual rights as there is no contract between the organisation and a volunteer.

‘visitor’: an individual who is visiting an organisational site or activity, potentially doing so in order to make a decision about whether to ask to become a volunteer.