School User Privacy Policy

Herts for Learning Privacy Policy for ECT Manager

ECT Manager is an online system that is used by Appropriate Bodies and schools to manage every part of the Early Career Teacher (ECT) induction process in one place. ECT Manager is owned and managed by Evolution Internet Ltd (Registered Company 04385614).

This Privacy Policy demonstrates Herts for Learning’s (HfL’s) firm commitment to data protection. This statement (together with the Service Level agreement) sets out the ways that HfL ('the Company, 'we', 'us' or 'our') gathers and disseminates information from ECT Manager and what you can do if you have questions about Personal Data.

For the purposes of data protection laws, the Company is the controller of personal data collected by us on ECT Manager, in our role of Appropriate Body.

This document sets out the types of Personal Data (meaning information about an individual from which that individual can be personally identified) we handle, the purposes of handling those Personal Data and any recipients of it.

We are committed to ensuring that your privacy is protected at all times. Any information that you provide to HfL on ECT Manager will be handled in accordance with this Privacy Policy.

  1. Our details We are: Herts for Learning Limited Address: Robertson House, Six Hills Way, Stevenage, SG1 2FQ Information Commissioner's Office Registration Number: ZA154308 Our Data Protection Officer is: Lynette Dexter, Company Secretary Email address for the Data Protection Officer:

  2. Why we collect personal data We collect and hold personal information relating to our users and in relation to any individuals included in data sets that are being processed by the Company under contractual agreements.

We may share Personal Data with other agencies, but only as necessary under our legal duties or otherwise in accordance with our duties/obligations as a Company.

The Personal Data we collect is provided to us on a voluntary basis when users register on ECT Manager.

Set out below are the reasons we collect and process Personal Data, as well as the legal basis on which we carry out this processing:

• As the Appropriate Body, to quality assure and monitor the induction period of ECTs • To provide returns to the Teaching Regulation Agency regarding the status of an ECT’s induction

  1. Legal basis for processing personal data The lawful basis for us to collect/process this Personal Data is by reason of necessity for the ‘performance of a contract’ to which the both we and the Data Subject are party. This includes: • Fulfilling our contractual obligations, as the Appropriate Body, to schools that sign up to ECT Manager • Fulfilling our contractual partnership obligations, as the Appropriate Body, with Hertfordshire County Council

We also process Personal Data where processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject. This will include processing where such processing is required in order to fulfil contractual obligations.

We do not process any special categories of Personal Data except where necessary for reasons of substantial public interest in complying with legal obligations including under the Equality Act 2010 or where necessary to protect the vital interests of the Data Subject or of another natural person and where safeguards are in place to ensure that this Personal Data is kept secure. For the avoidance of doubt where special categories of Personal Data are collected it shall not be used for the purposes of automated decision making and/or profiling.

Special categories of data means Personal Data revealing: • racial or ethnic origin; • political opinions; religious or philosophical beliefs or trade union membership; • genetic or biometric data that uniquely identifies you; • data concerning your health, sex life or sexual orientation; or • data relating to criminal convictions or offences or related security measures.

Further Personal Data including special categories of Personal Data may be collected and/or processed where consent has been given. If consent is the only legal basis for processing and has been given then this may be revoked in which case the Personal Data will no longer collected/processed.

  1. Categories of personal data we collect about you As a user of the ECT Manager service, we may collect the following Personal Data about you (please note this list does not include every type of Personal Data and may be updated from time to time): i. Title ii. Name iii. Previous surname iv. Email address v. Date of birth vi. National Insurance Number vii. Postal address viii. Telephone / mobile number ix. Qualifications

This information will be collected from you at the time that you register on ECT Manager. Any Personal Data collected through ECT Manager will be treated as confidential under the principles of the Relevant Data Protection Law.

  1. Who will have access to your personal data Personal Data on ECT Manager will be accessible by members of HfL staff and will also be reviewed by the ECT Review Panel, as required.

We will not share information with third parties without consent unless we are required to do so by law or our policies. We will disclose Personal Data to third parties: • if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation; • in order to enforce any agreements with you; • in order to perform contracts with third parties including: • Hertfordshire County Council • Other Local Authorities • Other Appropriate Bodies • Evolution Internet Ltd • Teaching Regulation Agency • Subscribing schools • Teaching School Hubs • TCI • to protect the rights, property, or safety of the Company.

This may include sharing data with the Police and other organisations where necessary.

  1. How personal data will be processed Personal Data collected on ECT Manager may be processed in a variety of ways; this will include but is not limited to: • maintaining electronic records; • send emails; • adding to spreadsheets, word documents or similar for the purposes of reporting / assessing Personal Data; • invoicing purposes; • identifying and following-up with any individuals requiring additional support.

  2. Cookies The use of Cookies on ECT Manager is managed by Evolution Internet Ltd. Please refer to their Cookie Policy at:

  3. Links to other websites You may encounter links to external website pages whilst using ECT Manager. If the link is to a website that is operated by a third party you should know that we have no control over that website, or its content, and as such cannot be responsible for the protection and privacy of your data or information you provide whilst visiting the site. You are advised to check the Privacy Policy of those other sites for their Terms and Conditions.

  4. Where we store personal data and how we keep personal data secure We are committed to ensuring that the data you provide is handled securely and have put in place suitable physical, electronic and managerial processes to safeguard your information.

Electronic copies of Personal Data are kept securely and information will only be processed where we are satisfied that it is reasonably secure.

All information you provide to us is stored on secure servers. You are responsible for keeping your ECT Manager password confidential and you must not share your password with anyone.

This site has security measures in place to protect the loss, misuse and alteration of the information under our control. All instances of unauthorised attempted access to ECT Manager are logged and investigated. Where necessary, HfL will inform law enforcement agencies or other relevant organisations regarding misconduct.

At the Company we respect the privacy of email accounts and we store your email addresses securely. Your details will not be passed to ANY organisation beyond us without your explicit permission.

  1. Retention Periods We will only retain Personal Data for as long as is necessary to achieve the purposes for which it was originally collected. In line with DfE guidance, ECT records will be kept by the Company for six years.

Once the retention period concludes, personal data will be securely and safely destroyed/ deleted.

  1. Your data rights The UK General Data Protection Regulations and associated data protection law gives you rights in relation to Personal Data held about you. These are:

• Right to be informed: you have the right to be informed about the collection and use of your data. This policy contains information in relation to the collection of your Personal Data, however, if we collect additional data for other purposes, we will inform you about this.

• Right of Access: if your Personal Data is held by us, you are entitled to access your Personal Data (unless an exception applies) by submitting a written request. We will aim to respond to that request within one month. If responding to your request will take longer than a month, or we consider that an exception applies, then we will let you know. You are entitled to access the Personal Data described in Section 4.

• Right of Rectification: you have the right to require us to rectify any inaccurate Personal Data we hold about you. You also have the right to have incomplete Personal Data we hold about you completed. If you have any concerns about the accuracy of Personal Data that we hold then please contact us.

• Right to Restriction: you have the right to restrict the manner in which we can process Personal Data where: o the accuracy of the Personal Data is being contested by you; o the processing of your Personal Data is unlawful, but you do not want the relevant Personal Data to be erased; or o we no longer need to process your Personal Data for the agreed purposes, but you want to preserve your Personal Data for the establishment, exercise or defence of legal claims.

• Where any exercise by you of your right to restriction determines that our processing of particular Personal Data are to be restricted, we will then only process the relevant Personal Data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

• Right to Erasure: you have the right to require we erase your Personal Data which we are processing where one of the following grounds applies: o the processing is no longer necessary in relation to the purposes for which your Personal Data were collected or otherwise processed; o our processing of your Personal Data is based on your consent, you have subsequently withdrawn that consent and there is no other legal ground we can use to process your Personal Data; o the Personal Data have been unlawfully processed; and o the erasure is required for compliance with a law to which we are subject.

• Right to Data Portability: you have the right to receive your Personal Data in a format that can be transferred. We will normally supply Personal Data in the form of e-mails or other mainstream software files. If you want to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, please contact us via the details in this Notice.

• Right to Object: you have the right to object to the processing of your Personal Data where one of the following grounds apply: o the processing is based on legitimate interests or the performance of a task in the public interest; o the processing is for direct marketing; or o the processing is for the purposes of scientific/ historical research and statistics.

You can find out more about the way these rights work from the Information Commissioner's Office (ICO) website.

  1. Opting out If you no longer wish to receive communications from us you can email:

To change or modify information previously provided, you can email:

  1. Subject Access Request (requesting your personal data) You are entitled to request details of Personal Data that we hold about you and you can access that Personal Data by making a Subject Access Request (SAR).

A SAR is a written or verbal request for personal information (known as personal data) held about you by an organisation. Data protection legislation gives individuals the right to know what information is held about them. However, this right is subject to certain exemptions as set out in the Data Protection Act 2018.

To submit a SAR to HfL we recommend that you email a written request to our Data Protection Officer at To help us respond quickly and effectively to your request, please include information regarding your relationship with us, along with a comprehensive list of what personal data you want to access and any details, relevant dates, or search criteria that will help us identify the information that you want. 13. Making a complaint If you are unhappy with the way we have dealt with any of your data protection concerns, you can make a complaint to the Information Commissioners Officer (ICO), the supervisory authority for data protection issues in England and Wales. We would recommend that you complain to us in the first instance, but if you wish to contact the ICO you can do so using the details below. The ICO is a wholly independent regulator established in order to enforce data protection law.

ICO Concerns website:

ICO Helpline: 0303 123 1113

ICO Postal Address: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

  1. Changes to this Privacy Policy Any changes we make to this Privacy Policy in the future will be posted on ECT Manager and, where appropriate, notified to you by e-mail. Please check back to see any updates or changes.

This Privacy Policy was last updated on 20th October 2021.