Manamgement and Business Academy Privacy Policy

Our Commitment:

Management & Business Academy is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with the data protection principles and the Data Protection Act (DPA).  Click here to visit the website

Changes to data protection legislation shall be monitored and implemented in order to remain compliant with all requirements.

The member(s) of staff responsible for data protection are: Alireza Nazarian (Director) and Javad Mahmoudi (Director)

The Academy is also committed to ensuring that its staff are aware of data protection policies, legal requirements and adequate training is provided to them.

The requirements of this policy are mandatory for all staff employed by the school and any third party contracted to provide services within the school.

Notification:

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO  so please contact us in the first instance.
You can contact our data controllers Alireza Nazarian and Javad Mahmoudi at 44 Dryden Road, Harrow Weald, HA3 7JZ for any questions or complaint you may have.

Personal and Sensitive Data:

All data within the Academy’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.

The definitions of personal and sensitive data shall be as those published by the ICO for guidance: Please here to visit the website.
 
The principles of the Data Protection Act shall be applied to all data processed:

1. Processed fairly and lawfully

2. Obtained only for lawful purposes, and is not further used in any manner incompatible with those original purposes

3. Accurate and, where necessary, kept up to date,

4. Adequate, relevant and not excessive in relation to the purposes for which it is processed

5. Not kept for longer than is necessary for those purposes

6. Processed in accordance with the rights of data subjects under the DPA

7. Protected by appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage

8. Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection of the personal information

Fair Processing / Privacy Notice:

We shall be transparent about the intended processing of data and communicate these intentions via notification to staff, parents and pupils prior to the processing of individual’s data.

Notifications shall be in accordance with ICO.  
https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/

The intention to share data relating to individuals to an organisation outside of our school shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information.

Any proposed change to the processing of individual’s data shall first be notified to them.

Data Security:

In order to assure the protection of all data being processed and inform decisions on processing activities, we shall undertake an assessment of the associated risks of proposed processing and equally the impact on an individual’s privacy in holding data related to them.

Risk and impact assessments shall be conducted in accordance with guidance given by the ICO. Please click here to visit the website

Security of data shall be achieved through the implementation of proportionate physical and technical measures. Nominated staff shall be responsible for the effectiveness of the controls implemented and reporting of their performance.

The security arrangements of any organisation with which data is shared shall also be considered and these organisations shall provide evidence of the competence in the security of shared data.

Data Access Requests (Subject Access Requests):

All individuals whose data is held by us has a legal right to request access to such data or information about what is held. We shall respond to such requests within 40 days and they should be made in writing to Alireza Nazarian or Javad Mahmoudi

A charge may be applied to process the request.

Photographs and Video:

Images of staff and conference attendees may be captured at appropriate times and as part of educational activities for use in academy only.

Unless prior consent from attendees has been given, the academy shall not utilise such images for publication or communication to external sources.

It is the academy’s policy that external parties (including participants’ spouses) may not capture images of staff or attendees during such activities without prior consent.

Data Disposal:  

The academy recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk.

All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at the completion of the disposal process.  

Disposal of IT assets holding data shall be in compliance with ICO guidance. Please click here to view/download the pdf file.

The academy has identified a qualified source for disposal of IT assets and collections.