Who we are
This work is being carried out by the Behaviour Hubs Programme Team, which is a part of the Department for Education (DfE), and the Education Development Trust (EDT), contracted to be the DfE’s delivery partner for the programme. For the purpose of data protection legislation, DfE is the data controller for the personal data processed as part of the Behaviour Hubs programme and EDT is the data processor.
How we will use your information
We receive your personal data via your online application form, asking you for your data at various points of the programme and by accessing internal and published data from DfE and Ofsted.
We may seek advice and information from your local Regional Schools Commissioner and/or DfE-funded educational experts where this is relevant to processing your application and delivering support. We may also contact any cited parties to confirm information given in the application, and any other party we consider to be relevant to your application for ongoing information should the application be successful.
We are processing this information in order to select the most suitable schools and multi-academy trusts (MATs) to be part of the Behaviour Hubs programme and to correspond with successful schools and manage their data in order to deliver and monitor the programme.
Data will be used to deliver the Behaviour Hubs Programme. The purpose of processing this data includes:
- Managing attendance at training, open days, networking and other events.
- Giving access to the digital platform (Behaviour Hubs Portal).
- Sending communications, resources and surveys about the programme.
- Enabling schools to provide support to other schools on the programme both individually and through events, online forums etc.
- Enabling schools to receive support from other schools on the programme both individually and through events, online forums etc.
- Enabling schools to receive support from the programme team.
- Participating in monitoring and evaluation of the programme.
- Communicating with schools interested in joining the programme (where this has been agreed beforehand with the individual).
- Sharing information about the programme to pass onto other schools that they think may be interested.
- Delivering other aspects of the programme (not detailed above)
The nature of your personal data we will be using
The categories of your personal data that we will be using for this project are: Names, job roles, work histories, email addresses, details of associated schools/organisations, place of employment, address of place of employment, telephone numbers, dietary requirements and accessibility requirements. This will be used for school leaders and employees of the school or MAT.
Why our use of your personal data is lawful
In order for our use of your personal data to be lawful, we need to meet one (or more) conditions in the Data Protection legislation. For the purpose of this project, the relevant condition is that the processing is necessary for the exercise of a function of the Secretary of State or the Department as stated under GDPR Article 6 (1)(e). This lawful basis is appropriate under Sections 14 and 15 of the Education Act 2002 and Section 10 of the Education Act 1996.
Whom we will make your personal data available to
We sometimes need to make personal data available to other organisations. These might include contracted partners and/or other organisations with whom we need to share your personal data for specific purposes. Where we need to share your personal data with others, we ensure that this data sharing complies with Data Protection legislation. For the purpose of this project, we may need to share your personal data with:
- The National Schools Commissioner (NSC), Regional Schools Commissioners (RSC) and/or DfE-funded educational experts, their teams and, if appropriate, DfE-contracted external assessors in order to assess the strength of your application and ensure the right support is provided.
- The delivery centre, the Education Development Trust, contracted on behalf of the Department for Education.
- Evaluator contracted on behalf of Department for Education.
- Digital platform provider and hosting company.
- Other schools and MATs
- Other third parties/suppliers/subcontractors for whom data needs to be shared in order to deliver the programme.
For how long we will keep your personal data
Please note that, under Data Protection legislation and in compliance with the relevant data processing conditions, we can lawfully keep personal data gathered from applications for schools to be part of the Behaviour Hubs programme and gathered from schools as part of programme delivery purely for research and statistical purposes, indefinitely.
Should you be successful in your application to be part of the Behaviour Hubs programme, we shall keep your details for the provision of data for complaints and internal reporting processes, indefinitely. Any personal contact information will be retained for five years and then securely destroyed.
Should you withdraw your application to be part of the Behaviour Hubs programme, we shall keep your details for the handling of any future re-applications, complaints and provision of data for internal reporting processes, indefinitely. Any personal contact information will be retained for five years and then securely destroyed.
Should you be unsuccessful in your application to be part of the Behaviour Hubs programme, we shall keep your details for the handling of any future re-applications, complaints and provision of data for internal reporting processes, indefinitely. Any personal contact information will be retained for three years and then securely destroyed. We will only keep your personal data for as long as we need it for the purpose(s) of this piece of work, after which point it will be securely destroyed. Please note that, under Data Protection legislation, and in compliance with the relevant data processing conditions, personal data can be kept for longer periods of time when processed purely for archiving purposes in the public interest, scientific or historical research, and statistical purposes.
Your data protection rights
Under certain circumstances, you have the right:
- to ask us for access to information about you that we hold
- to have your personal data rectified, if it is inaccurate or incomplete
- to request the deletion or removal of personal data where there is no compelling reason for its continued processing
- to restrict our processing of your personal data (i.e. permitting its storage but no further processing)
- to object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics
- not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you
If you need to contact us regarding any of the above, please do so via the DfE site at: https://www.gov.uk/contact-dfe. Further information about your data protection rights appears on the Information Commissioner’s website at: https://ico.org.uk/for-organisations/guide-to-data-protection/principle-6-rights/
We may need to update this privacy notice periodically, so we recommend that you revisit this information from time to time. This version is up to date as of 1 July 2023.
If you have any questions about how your personal information will be used, please contact us at firstname.lastname@example.org. For the Data Protection Officer (DPO) please contact us via gov.uk and mark it for the attention of the ‘DPO’. Alternatively, please write to:
Ministerial and Public Communications Division
Department for Education