GDPR Policy

iBOS GDPR Policy The aims of our school are

• A school where teachers, staff, and students are expected to support and extend the atmosphere of respect, courtesy, the love of learning and the value of friendship that is held dear at iBOS.
• iBOS aims to develop students to become well-rounded individuals. We aim to empower our students with the best tools and resources, making them capable in following and achieving their dreams, to become valued members of our global societies, and to allow them to make a positive difference to the world, wherever they choose to progress to.
• Students leave iBOS prepared for university. They are confident, contributing, and caring members of the global community and they have embraced the challenge of our specialized education. They will have gained the values that equip them to make a positive contribution.

Responsibility of: The Principal

Date Ratified: 03 July 2025

Review Date: 03 July 2027

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Data Protection and Data Security Policy

Statement and Purpose of policy iBOS is committed to ensuring that all personal data handled by us will be processed according to legally compliant standards of data protection and data security. We confirm for the purposes of the data protection laws, that the Employer is a data controller of the personal data in connection with your employment. This means that we determine the purposes for which and how your personal data is processed. The purpose of this policy is to help us achieve our data protection and data security aims by:

1. 1. notifying our staff, customers, suppliers and other third parties of the types of personal information that we may hold about them, and what we do with that information
2. 2. setting out the rules on data protection and the legal conditions that must be satisfied when we collect, receive, handle, process, transfer, and store personal data and ensuring staff understand our rules and the legal standards
3. 3. clarifying the responsibilities and duties of staff in respect to data protection and data security This is a statement of policy only and does not form part of a contract (of employment etc.). We may amend this at any time, at our absolute discretion. These definitions are for the purposes of this policy:
4. 1. Data protection laws: all applicable laws relating to the processing of personal data, including, for the period during which it is in force, the UK general data protection regulation.
5. 2. Data subject: the individual to whom the personal data relates.
6. 3. Personal data: any information that relates to an individual who can be identified from that information.
7. 4. Processing: any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.
8. 5. Special categories of personal data: information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
9. 6. Data Processor: Any person or organisation (other than an employee of the data controller) who processes personal data on behalf of the data controller.

7. UK GDPR: The United Kingdom General Data Protection Regulation, tailored by the Data

Protection Act 2018.

Data Protection Principles

Staff whose work involves using personal data relating to staff or others must comply with this policy and with the following data protection principles which require that personal information is:

1. 1. Processed lawfully, fairly, and transparently. We must always have a lawful basis to process personal data, as set out in the data protection laws. Personal data may be processed as necessary to perform a contract with the data subject, to comply with a 2

legal obligation to which the data controller is the subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. The data subject must be told who controls the information (us), the purpose(s) for which we are processing the information and to whom it may be disclosed.

1. 2. Collected only for specified, explicit and legitimate purposes. Personal data must not be collected for one purpose and then used for another. If we want to change the way we use personal data, we must first tell the data subject.
2. 3. Processed only where it is adequate, relevant, and limited to what is necessary for processing. We will only collect personal data to the extent required for the specific purpose notified to the data subject.
3. 4. Accurate and the employer takes all reasonable steps to ensure that information that is inaccurate is rectified or deleted without delay. Checks to personal data will be made when collected and regular checks must be made afterwards. We will make reasonable efforts to rectify or erase inaccurate information.
4. 5. Kept only for the period necessary for processing. Information will not be kept longer than it is needed, and we will take all reasonable steps to delete information when we no longer need it.
5. 6. Secure, and appropriate measures. These are adopted by the employer to ensure such.
6. 7. Accountability. The school must take responsibility for what it does with personal data and how it complies with the data protection principles, and must have appropriate measures and records in place to demonstrate compliance. Who is responsible for data protection and data security? Maintaining appropriate standards of data protection and data security is a collective task shared between us and you. This policy and the rules contained in it apply to all staff of the employer, irrespective of seniority, tenure and working hours, including all employees, directors and officers, consultants, and contractors, casual or agency staff, trainees, homeworkers and fixed-term staff and any volunteers (staff). Questions about this policy, or requests for further information, should be directed to the Principal. All staff have a personal responsibility to ensure compliance with this policy, to handle all personal data consistently with the principles set out here and to ensure that measures are taken to protect the data security. Managers have special responsibility for leading by example and monitoring and enforcing compliance. The Principal must be notified if this policy has not been followed, or if it is suspected this policy has not been followed, as soon as reasonably practicable. Any breach of this policy will be taken seriously and may result in disciplinary action up to and including dismissal. Significant or deliberate breaches, such as accessing staff or customer 3

personal data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice. What personal data and activities are covered by this policy? This policy covers personal data:

1. 1. Which relates to a natural living individual who can be identified either from that information in isolation or by reading it together with other information we possess;
2. 2. Is stored electronically or on paper in a filing system;
3. 3. In the form of statements of opinion as well as facts;
4. 4. Which relates to staff (present, past or future) or to any other individual whose personal data we handle or control;
5. 5. Which we obtain, is provided to us, which we hold or store, organize, disclose, or transfer, amend, retrieve, use, handle, process, transport or destroy. This personal data is subject to the legal safeguards set out in the data protection laws. What personal data do we process about staff? iBOS collects personal data about you which:
6. 1. you provide or we gather before or during your employment or engagement with us;
7. 2. is provided by third parties, such as references or information from suppliers or another party that we do business with; or
8. 3. is in the public domain. The types of personal data that we may collect, store and use about you include records relating to your:
9. 1. home address, contact details and contact details of your next of kin;
10. 2. recruitment (including application forms, curriculum vitae, references received and details of qualifications);
11. 3. pay records, national insurance number and details of taxes and any employment benefits such as pension and health insurance (including details of any claims made);
12. 4. telephone, email, internet, fax or instant messenger used;
13. 5. performance and any disciplinary matters, grievances, complaints, or concerns in which you are involved.

Sensitive Personal Data

We may from time to time need to process sensitive personal information (sometimes referred to as ‘special categories of personal data’). We will only process sensitive personal information if:

1. 1. we have a lawful basis for doing so, e.g. it is necessary for the performance of the 4

employment contract; and

1. 2. one of the following special conditions for processing personal information applies:
2. a. the data subject has given explicit consent
3. b. the processing is necessary for the purposes of exercising the employment law rights or obligations of the company or the data subject
4. c. the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent
5. d. the processing relates to personal data which are manifestly made public by the data subject
6. e. the processing is necessary for the establishment, exercise, or defense of legal claims; or
7. f. the processing is necessary for the reasons of substantial public interest. Before processing any sensitive personal information, staff must notify the Principal of the proposed processing, for the Principal to assess whether the processing complies with the criteria noted above. Sensitive personal information will not be processed until the assessment above has taken place and the individual has been properly informed of the nature of the processing, the purposes for which it is being carried out and the legal basis for it. Our privacy notice sets out the type of sensitive personal information that we possess, what it is used for and the lawful basis for the processing.

How We Use Your Personal Data

We will tell you the reasons for processing your personal data, how we use such information and the legal basis for processing in our privacy notice. We will not process staff’s personal information for any other reason. In general, we will use the information to carry out our business, administer employment or engagement and deal with any problems or concerns you may have, including, but not limited to:

1. 1. Sickness Records: to maintain a record of sickness absence and copies of any doctor’s notes or other documents supplied to us in connection with your health, to inform colleagues and others of sickness related absences, as reasonably necessary to manage absences, to deal with unacceptably high or suspicious sickness absence, to inform reviewers for appraisal purposes of sickness absence level, to publish internally aggregated, anonymous details of sickness absence levels.
2. 2. Monitoring IT Systems: to monitor use of e-mails, internet, telephone and fax, computer or other communications or IT resources.
3. 3. Disciplinary, Grievance or Legal Matters: in connection with any disciplinary, grievance, legal, regulatory or compliance matters or proceedings that may involve you.
4. 4. Performance reviews; to carry out performance reviews. Accuracy and Relevance We will:
5. 1. Ensure that any personal data processed is up to date, accurate, adequate, relevant and not excessive, given the purpose for which it was collected
6. 2. not process personal data obtained for one purpose for any other purpose, unless you agree to this or reasonably expect this 5

If you consider that any information held about you is inaccurate or out of date, please inform the Principal. If they agree that the information is inaccurate or out of date, then they will correct it promptly. If they do not agree with the correction, then they will note your comments. Storage and Retention Personal data (and sensitive personal information) will be kept securely in accordance with our GDPR policy. The periods for which we hold personal data are contained in our privacy notices.

Individual Rights

You have the following rights concerning your personal data. Subject access requests:

1. 1. You have the right to make a subject access request, if you make a subject access request, we will tell you:
2. a. whether or not your personal data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from you;
3. b. to whom your personal data is or may be disclosed;
4. c. for how long your personal data is stored (or how that period is decided);
5. d. your rights of rectification or erasure of data, or to restrict or object to processing;
6. e. your right to right to complain to the information commissioner if you think we have failed to comply with your data protection right; and
7. f. whether or not we carry out automated decision-making and the logic involved in any such decision making.
8. 2. We will provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made a request electronically unless you agree otherwise.
9. 3. To make a subject access request, contact us at hr@ibos.education
10. 4. We may need to ask for proof of identification before your request can be processed. We will let you know if we need to verify your identity and the documents we require.
11. 5. We will normally respond to your request within 28 school days from the date your request is received. In some cases, e.g. where there is a large amount of personal data being processed, we may respond within 3 months of the date your request is received. We will write to you within 28 days of receiving your original request if this is the case.
12. 6. If your request is manifestly unfounded or excessive, we are not obliged to comply with it. 6

Other rights:

1. 1. You have a number of other rights in relation to your personal data. You can require us to:
2. a. rectify inaccurate data;
3. b. stop processing or erase data that is no longer necessary for processing;
4. c. stop processing or erase data if your interests override our legitimate grounds for processing the data (where we rely on our legitimate interests as a reason for processing data);
5. d. stop processing data for a period if data is inaccurate or if there is a dispute about whether or not your interests override the employer’s legitimate grounds for processing the data. To request that we take any of these steps, please send the request to the Principal. You also have the right to:

• Data Portability (Article 20): request a copy of your data in a commonly used, machine- readable format and transmit it to another controller where processing is based on consent or contract.
• Object to Automated Decision-Making and Profiling (Article 22): request human intervention where decisions are made solely by automated means that significantly affect you.

Data Security

We will use appropriate technical and organizational measures to keep personal data secure, and in particular to protect against unauthorized or unlawful processing and accidental loss, destruction or damage. Maintaining data security means making sure that:

1. 1. Only people who are authorized to use the information can access it;
2. 2. Where possible, personal data is pseudonymized or encrypted;
3. 3. Information is accurate and suitable for the purpose for which it is processed; and
4. 4. Authorized persons can access information if they need it for authorized purposes. By law, we must use procedures and technology to secure personal information throughout the period that we hold or control it, from obtaining to destroying the information. Personal information must not be transferred to any person to process (e.g. while performing services for us on our behalf), unless that person has either agreed to comply with our data security procedures or we are satisfied that other adequate measures exist. Security procedures include:
5. 1. Any desk or cupboard containing confidential information must be kept locked.
6. 2. Computers should be locked with a strong password that is changed regularly or shut down when they are left unattended, and discretion should be used when viewing personal information on a monitor to ensure that it is not visible to others. 7

1. 3. Data stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used.
2. 4. The Principal must approve of any cloud used to store data.
3. 5. Data should never be saved directly to mobile devices such as laptops, tablets or smartphones.
4. 6. All servers containing sensitive personal data must be approved and protected by security software.
5. 7. Servers containing personal data must be kept in a secure location, away from general office space.
6. 8. Data should be regularly backed up in line with the employer’s backup procedure. Telephone precautions. Particular care must be taken by staff who deal with telephone enquiries to avoid inappropriate disclosures. In particular:
7. 1. The identity of any telephone caller must be verified before any personal information is disclosed.
8. 2. If the caller’s identity cannot be verified satisfactorily, then they should be asked to put their query in writing;
9. 3. Do not allow callers to bully you into disclosing information. In case of any problems or uncertainty, contact the Principal.
10. 4. Methods of disposal must be adhered to. Copies of personal information, whether on paper or any physical storage device, must be physically destroyed when they are no longer needed. Paper documents should be shredded and CDs or memory sticks or similar must be rendered permanently unreadable.

Data Impact Assessments

Some of the processing that the employer carries out may result in privacy risks. Where processing would result in a high risk to staff rights and freedoms, the employer will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data Breaches

If we discover that there has been a breach of staff personal data that poses a risk to the rights and freedoms of individuals, we will report it to the information commissioner within 72 hours of discovery. We will assess the potential risk to individuals and, where there is a likely risk to their rights and freedoms, notify the Information Commissioner’s Office (ICO) within 72 hours. If there is a high risk to individuals, we will inform them without undue delay. If the breach is likely to result in a high risk to your rights and freedoms, we will tell affected individuals that there has been a breach and provide them with more information about its likely consequences and the mitigation measures it has taken. 8

International Data Transfers

Personal data must not be transferred outside the UK unless appropriate safeguards are in place. Where data is transferred to a third country, iBOS will use the UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU Standard Contractual Clauses (SCCs), and ensure an appropriate Transfer Risk Assessment (TRA) is completed.

Individual Responsibilities

Staff are responsible for helping the employer keep their personal data up to date. Staff should let the employer know if personal data provided to the employer changes, eg if you move house or change your bank detail. You may have access to the personal data of other staff members and our customers in the course of your employment. Where this is the case, the employer relies on staff members to help meet its data protection obligations to staff and customers. Individuals who have access to personal data are required:

1. 1. to access only personal data that they have authority to access and only for authorized purposes;
2. 2. not to disclose personal data except to individuals (whether inside or outside of the employer) who have appropriate authorization;
3. 3. to keep personal data secure (eg by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
4. 4. not to remove personal data, or devices containing or that can be used to access personal data, from the employer’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
5. 5. not to store personal data on local drives or on personal devices that are used for work purposes.

Training

All staff will receive training as part of their induction and annual GDPR refresher training. Attendance is recorded in the GDPR Training Log. Staff in roles that require regular access to personal data or responsibilities under this policy will receive additional training and guidance.

Policy Review

This policy will be reviewed and updated as necessary to ensure compliance with legislation or organizational practices changes. 9