WHO WE ARE
The Independent Schools' Bursars Association (ISBA) is an
association of member independent schools based in the UK and
abroad. There is a trading subsidiary (ISBA (Enterprises))
which is part of the ISBA and will be assumed to be included in
this privacy notice as the activities of ISBA and ISBA
(Enterprises) are inextricably linked. The two bodies are
treated as one data controlling organisation for the purposes of
the relevant legislation, in this case the General Data Protection
Regulation (EU 2016/679) and the UK Data Protection Act 2018, as
well as potentially other relevant supporting legislation that will
This privacy notice is intended to cover the activities of both
ISBA and ISBA (Enterprises).
The data held by ISBA is primarily that of the member school but
within that, there are a number of school employees for whom data
is held. This gives ISBA two clear strands to its privacy
policy, the business to business relationship with schools and the
data control of the contact data for those employed by the member
WHAT THIS PRIVACY NOTICE IS FOR
This policy is intended to provide information about how ISBA
will use (or "process") personal data about individuals including:
its own staff; and its current, past and prospective contacts
within member schools.
This information is provided because Data Protection Law gives
individuals rights to understand how their data is used. Staff are
all encouraged to read this Privacy Notice and understand the ISBA
obligations to its entire membership.
This Privacy Notice applies alongside
any other information ISBA may provide about a particular use of
personal data, for example when collecting data online or in paper
This Privacy Notice also applies in
addition to the Association's other relevant terms and conditions
and policies, including:
- any contract between ISBA and its staff;
- the Association's policy on taking, storing and using
- the Association's retention of records policy;
- the Association' health and safety policies, including as to
how concerns or incidents are recorded; and
- the Association's IT policies, including its Acceptable Use
policy, eSafety policy, WiFi policy and Remote Working policy.
Anyone who works for, or acts on behalf of, ISBA (including
staff, volunteers, Board Members and service providers) should also
be aware of and comply with this Privacy Notice and the
Association's data protection policy for staff, which also provides
further information about how personal data about those individuals
will be used.
RESPONSIBILITY FOR DATA PROTECTION
ISBA has appointed the Chief Operating Officer as Privacy
Officer who will deal with all requests and enquiries concerning
the Association's use of your personal data (see section on Your
Rights below) and endeavour to ensure that all personal data is
processed in compliance with this policy and Data Protection
Contact details are Mr John Murphie, 01256 373110,
WHY ISBA NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, member
schools and those individuals used as contacts within the schools,
ISBA needs to process a wide range of personal data about
individuals (including current, past and prospective staff) as part
of its daily operation.
Some of this activity ISBA will need to carry out in order to
fulfil its legal rights, duties or obligations - including those
under a contract with its staff, or member schools.
Other uses of personal data will be made in accordance with the
Association's legitimate interests, or the legitimate interests of
another, provided that these are not outweighed by the impact on
individuals and provided it does not involve special or sensitive
types of data.
ISBA expects that the following uses will fall within that
category of its "legitimate interests":
- To provide member services, including professional development,
training, advice and guidance, and monitoring schools' progress and
- Maintaining relationships with former members and the ISBA
community, including direct marketing;
- For the purposes of management planning and forecasting,
research and statistical analysis, including that imposed or
provided for by law (such as tax, diversity or gender pay gap
- To enable relevant authorities to monitor the Association's
performance and to intervene or assist with incidents as
- To give and receive information and references about past,
current and prospective staff.
- To monitor (as appropriate) use of the Association's IT and
communications systems in accordance with the Association's IT
Acceptable Use Policy;
- To make use of photographic images, on ISBA website and (where
appropriate) on the Association's social media channels;
- To carry out or cooperate with any internal or external
complaints, disciplinary or investigation process; and
- Where otherwise reasonably necessary for the Association's
purposes, including to obtain appropriate professional advice and
insurance for the Association.
In addition, ISBA will on occasion need to process special
category personal data (concerning health, ethnicity, religion,
biometrics or sexual life) or criminal records information (such as
when carrying out DBS checks) in accordance with rights or duties
imposed on it by law, including safeguarding and employment, or
from time to time by explicit consent where required. These reasons
- In connection with employment of its staff, for example DBS
checks, welfare, union membership or pension plans;
- To run any of its systems that operate on biometric data, such
as for security and other forms of identification;
- As part of any Association or external complaints, disciplinary
or investigation process that involves such data; or
- For legal and regulatory purposes (for example diversity
monitoring and health and safety) and to comply with its legal
obligations and duties of care.
TYPES OF PERSONAL DATA PROCESSED BY THE
This will include by way of example:
- names, addresses, telephone numbers, e-mail addresses and other
- bank details and other financial information;
- personnel files;
- where appropriate, information about individuals' health and
welfare, and contact details for their next of kin;
- references given or received by ISBA about employees, and
relevant information provided by previous employers;
- correspondence with and concerning staff, past and present;
- images of individuals engaging in Association activities.
HOW ISBA COLLECTS DATA
Generally, ISBA receives personal data from the individual
directly. This may be via a form, or simply in the ordinary course
of interaction or communication.
However, in some cases personal data will be supplied by third
parties (for example by other professionals or authorities working
with that individual) or collected from publicly available
WHO HAS ACCESS TO PERSONAL DATA AND WHO ISBA SHARES IT
Occasionally, ISBA will need to share personal information
relating to its community with third parties, such as:
- professional advisers (e.g. lawyers, insurers, PR advisers and
- government authorities (e.g. HMRC, DfE, police or the local
- appropriate regulatory bodies, this includes but will not be
limited to, the Independent Schools Inspectorate,
the Charity Commission or the Information Commissioner.
For the most part, personal data collected by ISBA will remain
within the Association and will be processed by appropriate
individuals only in accordance with access protocols (i.e. on a
'need to know' basis).
Finally, in accordance with Data Protection Law, some of the
Association's processing activity is carried out on its behalf by
third parties, such as IT systems, web developers or cloud storage
providers. This is always subject to contractual assurances that
personal data will be kept securely and only in accordance with the
school's specific directions.
HOW LONG WE KEEP PERSONAL DATA
ISBA will retain personal data securely and only in line with
how long it is necessary to keep for a legitimate and lawful
reason. Typically, the legal recommendation for how long to keep
staff personnel files is up to 7 years following departure from the
If you have any specific queries about how our retention policy
is applied or wish to request that personal data that you no longer
believe to be relevant is considered for erasure, please contact Mr
John Murphie, 01256 373110, email email@example.com.
However, please bear in mind that ISBA will often have lawful and
necessary reasons to hold on to some personal data even following
such a request.
A limited and reasonable amount of information will be kept for
archiving purposes even where you have requested we no longer keep
in touch with you, we will need to keep a record of your request to
fulfil your wishes (called a "suppression record").
Individuals have various rights under Data Protection Law to
access and understand personal data about them held by the
Association, and in some cases ask for it to be erased or amended
or have it transferred to others, or for ISBA to stop processing it
- but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data or
wishing it to be transferred to another person or organisation, or
who has some other objection to how their personal data is used,
should put their request in writing to the Privacy Officer.
ISBA will endeavour to respond to any such written requests as
soon as is reasonably practicable and in any event within statutory
time-limits (which is one month in the case of requests for access
ISBA will be better able to respond quickly to smaller, targeted
requests for information. If the request for information is
manifestly excessive or similar to previous requests, ISBA may ask
you to reconsider, or require a proportionate fee (but only where
Data Protection Law allows it).
- Requests that cannot be fulfilled
You should be aware that the right of access is limited to your
own personal data, and certain data is exempt from the right of
access. This will include information which identifies other
individuals or information which is subject to legal privilege (for
example legal advice given to or sought by the Association, or
documents prepared in connection with a legal action).
You may have heard of the "right to be forgotten". However, we
will sometimes have compelling reasons to refuse specific requests
to amend, delete or stop processing your personal data: for
example, a legal requirement, or where it falls within a legitimate
interest identified in this Privacy Notice. All such requests will
be considered on their own merits.
Where ISBA is relying on consent as a means to process personal
data, any person may withdraw this consent at any time (subject to
similar age considerations as above). Examples where we do rely on
consent are for the use of certain types of images. Please be aware
however that ISBA may not be relying on consent but have another
lawful reason to process the personal data in question even without
That reason will usually have been asserted under this Privacy
Notice or may otherwise exist under some form of contract or
agreement with the individual (e.g. an employment contract, or
because a purchase of goods, services or membership of an
organisation has been requested).
The rights under Data Protection Law belong to the individual to
whom the data relates.
DATA ACCURACY AND SECURITY
ISBA will endeavour to ensure that all personal data held in
relation to an individual is as up to date and accurate as
possible. Individuals must please notify the Membership
Manager of any significant changes to important information, such
as contact details, held about them.
An individual has the right to request that any out-of-date,
irrelevant or inaccurate or information about them is erased or
corrected (subject to certain exemptions and limitations under Data
Protection Law): please see above for details of why ISBA may need
to process your data, of who you may contact if you disagree.
ISBA will take appropriate technical and organisational steps to
ensure the security of personal data about individuals, including
policies around use of technology and devices, and access to
Association systems. All staff and Board Members will be made aware
of this policy and their duties under Data Protection Law and
receive relevant training.
ISBA will update this Privacy Notice from time to time. Any
substantial changes that affect your rights will be provided to you
directly as far as is reasonably practicable.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to the
Privacy Officer using the contact details Contact details are Mr
John Murphie, 01256 373110, email firstname.lastname@example.org.
If an individual believes that ISBA has not complied with this
policy or acted otherwise than in accordance with Data Protection
Law, they should utilise ISBA complaints / grievance procedure and
should also notify the Privacy Officer. You can also make a
referral to or lodge a complaint with the Information
Commissioner's Office (ICO), although the ICO recommends that steps
are taken to resolve the matter with ISBA before involving the
Drafted 23 May 2018