Projection Education Privacy Statement 

Privacy Notice

Last reviewed: September 2026
Next review: September 2027
Policy owner: Director / Data Protection Lead

​

1. Introduction

Projection Education Ltd respects your privacy and is committed to protecting personal information.

We provide education, alternative provision, tuition, mentoring, Special Educational Needs and Disabilities (SEND) support, pastoral support and related services for children and young people. In delivering these services, we process information relating to learners, parents and carers, staff, applicants, contractors, visitors, commissioners and other professionals.

Individuals whose information we hold are known as data subjects. We process personal information lawfully, fairly and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable legislation.

Projection Education Ltd will normally act as the data controller where we decide how and why information is processed. In some circumstances, we may act as a data processor for a school, academy, local authority or other commissioning body. Our respective responsibilities will be determined by the relevant agreement and circumstances.

​

2. Contact Information

Questions or concerns about this notice or our use of personal information should be directed to:

Projection Education Ltd
Address: The Ferry Centre, Ferry Rd, Felixstowe, IP11 9RT
Telephone: 01206 899024
Email: admin@projection-edu.co.uk

Data Protection Lead: Will Harvey - Director 
Data protection email: wharvey@projection-edu.co.uk (subject matter DPO)

You may also raise a concern with the Information Commissioner's Office (ICO):

Website: https://www.ico.org.uk
Telephone: 0303 123 1113

We would appreciate the opportunity to consider your concern before you contact the ICO.

​

3. Your Data Protection Rights

Depending on the circumstances and the lawful basis used, your rights may include:

• the right to be informed about how your information is used;

• the right of access to information held about you;

• the right to correct inaccurate or incomplete information;

• the right to erasure in certain circumstances;

• the right to restrict processing in certain circumstances;

• the right to data portability in certain circumstances;

• the right to object to certain processing;

• the right to withdraw consent where consent is the lawful basis; and

• rights relating to automated decision-making and profiling.

These rights do not apply in every circumstance. We will explain whether a right applies when responding to a request.

Children and young people have their own data protection rights. When responding to a request concerning a learner, we will consider the child's age, maturity, understanding, communication needs, parental responsibility and individual circumstances.

Requests may be made verbally or in writing. We may need to verify the identity and authority of the person making the request before releasing information.

​

4. Whose Information We Process

We may process information relating to:

• children and young people receiving or being considered for our services;

• parents, carers, family members and emergency contacts;

• employees, applicants, agency workers, contractors and volunteers;

• visitors;

• staff from schools, academies and colleges;

• local authority officers, commissioners and Virtual School staff;

• social workers, SEND professionals and health professionals;

• examination and awarding organisations; and

• other people involved in a learner's education, welfare or safeguarding.

​

5. Information We May Collect

The information we process depends on your relationship with Projection Education Ltd.

Learner information

This may include:

• names, dates of birth, addresses and contact details;

• parent, carer and emergency contact information;

• current and previous educational settings and education identifiers;

• referral, placement and commissioning information;

• attendance, punctuality, engagement and absence information;

• assessments, attainment, progress and qualification records;

• learning plans, targets, reports and work samples;

• behaviour, incident, accident and exclusion information;

• reintegration and transition information;

• photographs, video or audio recordings where appropriate;

• transport, work-experience and educational-visit information; and

• correspondence and meeting notes.

​

SEND, health and special category information

Where necessary to provide safe and appropriate education and support, we may process:

• SEND information and Education, Health and Care Plans (EHCPs);

• disabilities, medical conditions, allergies and medication information;

• mental, emotional and physical health information;

• communication, sensory, mobility and accessibility needs;

• behaviour, emotional regulation and risk information;

• racial or ethnic origin, religion or belief where relevant; and

• other sensitive information needed to meet a learner's needs.

Some of this is special category personal data and receives additional legal protection. Criminal-offence information is also subject to additional safeguards.

​

Safeguarding information

We may process safeguarding and child-protection information, including:

• concerns, disclosures and referrals;

• information about abuse, neglect, exploitation or risk of harm;

• incident, injury, accident or restrictive-intervention records;

• risk assessments and safety plans;

• information from social care, police, health services, schools or other agencies; and

• information relating to looked-after or previously looked-after children.

Access is restricted to people with a legitimate professional need to know.

​

Parents, carers and professionals

We may process names, contact details, relationships to learners, parental-responsibility information, correspondence, meeting notes, consent records and professional details.

​

Workforce and recruitment

We may process contact details, employment history, qualifications, references, right-to-work information, payroll details, attendance, training, performance, disciplinary or grievance records, health information, Disclosure and Barring Service information and safer-recruitment records.

​

Website information

When you use our website, we may collect an IP address, browser and device information, pages visited, website interactions, enquiries, communication preferences and information submitted through forms.

​

6. How We Collect Information

We may receive information:

• directly from the individual concerned or their parent or carer;

• through enquiry, referral, consent or registration forms;

• from schools, academies, colleges and other providers;

• from local authorities, Virtual Schools and commissioners;

• from social workers, SEND teams, health professionals and safeguarding agencies;

• from examination and awarding organisations;

• from applicants, referees and recruitment providers;

• through our website, email, telephone, social media or correspondence;

• automatically through cookies, server logs and similar technologies; and

• from public sources where lawful and appropriate.

Where providing information is mandatory, we will explain this and the possible consequences of not providing it where appropriate.

​

7. Why We Use Information

We may use personal information to:

• assess whether we can safely and appropriately meet a learner's needs;

• manage enquiries, referrals, placements, admissions and transitions;

• provide education, tuition, mentoring, pastoral and SEND support;

• develop individual learning and support programmes;

• monitor attendance, engagement, behaviour, attainment and progress;

• administer assessments, examinations and qualifications;

• safeguard children and promote their welfare;

• manage health, safety, behaviour, incidents and risks;

• make reasonable adjustments;

• communicate with learners, parents, carers and professionals;

• report to schools, local authorities and commissioners;

• support reintegration and future education, training or employment;

• arrange transport, activities, work experience and trips;

• maintain educational, safeguarding and operational records;

• recruit, employ, train and manage our workforce;

• manage complaints, incidents, contracts and legal claims;

• secure our premises, systems and services;

• manage finance, insurance and administration;

• improve and evaluate our services; and

• meet legal, regulatory, safeguarding and contractual duties.

​

8. Lawful Bases for Processing

Depending on the circumstances, we may rely on:

• Contract: processing is necessary to enter into or fulfil a contract;

• Legal obligation: processing is necessary to comply with the law;

• Legitimate interests: processing is necessary for legitimate operational, educational or commercial interests, provided these do not override individual rights;

• Vital interests: processing is necessary to protect someone's life;

• Public task: processing is necessary for a task in the public interest or exercise of official authority, where applicable; or

• Consent: clear, informed consent has been given for a specific purpose.

Consent will not be used where another lawful basis is more appropriate. For special category or criminal-offence information, we will also identify an appropriate additional legal condition.

​

9. Safeguarding and Information Sharing

The safety and welfare of children and young people is our highest priority. We may share information without consent where this is lawful and necessary to protect a child, young person or another person from harm.

Information may be shared with Children's Social Care, local authorities, police, health professionals, schools, safeguarding partnerships and other relevant agencies. We will share only what is relevant and proportionate unless the law requires otherwise.

​

10. Who We May Share Information With

Where necessary, appropriate and lawful, information may be shared with:

• parents and carers;

• commissioning schools, academies and colleges;

• local authorities and Virtual Schools;

• social workers, Children's Services and safeguarding partnerships;

• SEND teams, educational psychologists and education professionals;

• healthcare professionals and emergency services;

• police and other law-enforcement bodies;

• examination and awarding organisations;

• Ofsted, the Department for Education and other regulators where applicable;

• solicitors, accountants, auditors and insurers;

• IT, software, communications, payroll and administrative providers;

• transport, activity and work-experience providers; and

• government bodies or others where disclosure is legally required or permitted.

We do not sell personal information. Where another organisation processes information for us, appropriate contractual and data-protection arrangements will be used.

​

11. Photographs, Video and CCTV

We may take photographs or recordings for legitimate educational, safeguarding, security or record-keeping purposes.

Where an image of a child or young person is intended for public use, such as on our website, social media or promotional materials, we will normally obtain appropriate permission before publication.

Where CCTV is used, it may support safeguarding, site security, crime prevention and the protection of people and property. Signs will be displayed, and footage will only be accessed or disclosed for a lawful reason.

​

12. Data Security

We use appropriate organisational and technical measures to protect information from accidental loss, misuse, unauthorised access, alteration or disclosure. These may include:

• secure systems, passwords and role-based access controls;

• secure physical storage;

• staff confidentiality requirements;

• data-protection, security and safeguarding training;

• secure sharing and disposal procedures;

• breach-management procedures; and

• appropriate arrangements with service providers.

Information is accessible only to people who have a legitimate need to use it.

​

13. Data Retention

We keep personal information only for as long as necessary for its purpose and to meet legal, safeguarding, regulatory, contractual and insurance responsibilities.

Retention periods vary according to the type of record, individual circumstances and applicable guidance. Further details should be set out in our Data Retention Schedule.

When information is no longer required, it will be securely deleted, anonymised or destroyed.

​

14. Electronic Systems and International Transfers

We may use trusted cloud and IT services to store or process information. We take reasonable steps to ensure providers maintain appropriate security and data-protection arrangements.

Where information is transferred outside the United Kingdom, we will ensure that an appropriate lawful transfer mechanism and safeguards are in place.

​

15. Personal Data Breaches

Suspected loss, unauthorised disclosure, inappropriate access or another breach will be investigated promptly. We will act to reduce risk and prevent recurrence.

Where legally required, we will notify the ICO and, where appropriate, affected individuals.

​

16. Website Links, Cookies and Analytics

Our website may link to third-party websites. Projection Education Ltd is not responsible for how those organisations use information after you leave our website. You should read their privacy notices.

Our website may use cookies and similar technologies to operate, remember preferences, understand use and improve performance. Where required, we will ask for consent before setting non-essential cookies.

Cookies can be managed through our website controls or browser settings. Disabling some cookies may affect website functionality. Further information should be provided in our Cookie Notice.

​

17. Marketing

We may send news or promotional information where requested or where another lawful basis permits. You may opt out using an unsubscribe link or by contacting us.

Opting out will not prevent necessary contact about a placement, service, contract, safeguarding matter or operational issue.

​

18. Changes to This Notice

We will review this notice regularly and following significant changes to our services, systems, legal duties or processing activities.

The latest version will be made available through Projection Education Ltd and, where appropriate, on our website.