Privacy Notice
Purpose
New Codes On The Block (or NCOTB from here on) is committed to protecting your personal information and being transparent about what information we hold about you.
The lawful basis for obtaining and using personal data
NCOTB needs small amounts of personal data in order to fulfil its obligations to parents and guardians. Parents or guardians with children under the age of 16 will act on behalf of their children. Children over 16 years of age are deemed competent to understand this privacy statement.
We will only process personal data where we have one of six ‘lawful bases’ to do so under Article 6 of the EU General Data Protection Regulations.
Most commonly:
• To fulfil a contract with the individual, or when the individual has asked NCOTB to take specific steps before entering into a contract;
• For the legitimate interests of NCOTB (provided the individual’s rights and freedoms are not overridden);
• Where the individual (or their parent or guardian if under the age of 16) has freely given consent.
And exceptionally:
• To comply with a legal obligation;
• To ensure the vital interests of the individual e.g. to protect someone’s life;
• To perform a task in the public interest.
The personal data we hold
NCOTB will use the information you provided in your initial application and may supplement this with additional information which you provide following this.
Personal data that we may collect, use, store and share (see Data Sharing below) about individuals includes, but is not restricted to:
• Your full name, title;
• Email address and phone number;
• Attendance information and session history
Why we use this data
We use this data to:
• Administer, organise and deliver tutorials;
• Manage students’ participation in, and progression through NCOTB programmes including;
• Support student learning;
• Monitor and report on student progress;
• Assess the quality of our services;
• Administer applicants waiting lists;
• Share with partners for joint activities;
• Keep you updated with NCOTB activities that are relevant to you;
• Offer you opportunities to engage further with our activities;
• Generate publicity and advertise NCOTB’s services;
• Celebrate the success of our students and raise awareness of their achievements;
Photographs and Video Recording
There may be occasion to request permission to include work undertaken by students on social media or as part of this website. Should this occur parents or guardians will be asked for permission to include such material. When using photographs and videos for publicity, display or website purposes, we will not accompany them with any other personal information about the child unless permission from the parent or guardian has been given. Although we will carefully use images on the basis of our ‘legitimate interests’ (see above), we understand there may be occasions where individuals give good reason why we should withdraw certain images.
If you ask us to withdraw an image or video with good cause, we will delete the photograph or video and not distribute it further. Images that might cause embarrassment or distress will not be used.
Data sharing
Where it is legally required, or necessary for the reasonable undertaking of our business activities (and it complies with data protection law) we may share personal information with:
• Schools
• Central government
• Police forces, courts, tribunals.
Security of your personal data
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information confidential and as secure as possible. Your data will only be accessible to authorised staff. We will ensure that any third parties we use for processing your personal information do the same.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
We undertake to report any data breaches in accordance with Data Protection Act and General Data Protection Regulations guidelines.
Your rights to your personal information
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.
Contact details and further information
Please get in touch with us if you have any questions about any aspect of this privacy notice, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.
Online Education
Online Education & Distance Learning Protocol & Guidance
1.1 Purpose
This guidance sets out the provision of Online Education and Distance Learning for New Codes On The Block (or NCOTB) participants and the circumstances in which this will be delivered.
NCOTB delivers individual or small group online learning tutorials.
This guidance seeks to:
• Ensure a high-quality learning experience for Online Education/Distance Learning students;
• Make clear the responsibilities of all parties involved and the delivery of the lessons; and
• Safeguard all parties involved.
2 Protocol & Guidance
2.1 Safeguarding
Location of online lessons
The location in which both students and teachers take part in the online lesson should be in an appropriate room, and within earshot of a parent or guardian. This will ensure the student can raise any concerns, whether practical or related to safeguarding.
Whilst space in houses may be limited, and may be shared with others, NCOTB will work with the parents to make sure that whatever space is available to use is neutral, safe, conducive to learning, doesn’t reveal any personal information, and doesn’t present a safeguarding risk.
The student’s camera and microphone will be disabled by default and chat activity can only be directed to the NCOTB teacher.
In order to prevent inappropriate content being shown to others via the webcam, the background shown should ideally be neutral, and not create a risk of offensive or age-inappropriate content being displayed. For example, there shouldn’t be a TV or screen switched on, or posters that may cause offence.
NCOTB teachers have received sufficient training tonenable them to lead by example, including being aware of making the background visible in their online teaching professional and neutral.
Teaching space should not reveal any details about the teacher’s personal life. Care should be taken to remove anything that would not be appropriate in a face-to-face lesson either, for example, personal items, or anything that may distract students.
Teachers should check with the student at the start of the lesson if they feel comfortable in the environment and advise that they can stop at any time.
Professional Behaviour and Dress
As lessons will happen in an informal home environment, it is important that both teachers and students follow the same behaviour as they would in a school environment. This will help minimise any safeguarding risks, and thus advice to staff, parents and students includes:
• Having a parent or guardian within earshot of the student taking part in the online lesson
• Appropriate dress, both staff and students should wear clothing that would normally be worn in public
• Following the teacher’s instructions as students would ordinarily in the classroom environment
• Asking the teacher before leaving the session (e.g. for comfort breaks).
• Not taking phone calls, messaging others, or using devices that aren’t requested by the teacher for learning
• Not having other browsers or apps open during the online lesson to reduce the risk of inappropriate content being displayed
Record Keeping
We will offer to record the sessions and send the footage to the parent or guardian after the session. This is an opt-in or opt-out option and you will need to indicate your preference on our GDPR contact sheet, and you may change your mind at any time and notify us in writing about your change of preference. Before arranging the session a NCOTB representative will ask permission to share the screen of the student during the lessons. Permission will also be requested to share the screen of the teacher where this is appropriate. Should the parent or guardian not wish to activate their camera during the session, they will have the option of leaving it off. The parent or guardian is primarily responsible for activation of both the camera and microphone throughout each session.
Reporting of concerns by a child
A parent, a guardian or responsible adult should be within earshot of the child during the online lesson. Students will be told that if they have any concerns before, during, or after a lesson they should ask the parent or guardian for help. This could include for example:
• Technical issues with the computer or internet connection
• Practical issues, such as arranging the appropriate space to follow the lesson
• Other issues, such as not being comfortable with what is happening in a lesson
• Allowing additional time to set up the technology
Mechanisms to Identify, Intervene, and Escalate
Any Incident NCOTB Education and Distance Learning safeguarding follows the same reporting process as face-to-face lessons.
2.2 Communication & Data Protection
Our Online Education and Distance Learning programmes will be delivered through the Zoom technology that is free and accessible to all of our students. Zoom lessons will be arranged by the NCOTB teacher.
As part of this offer there are a number of principles in place to support safe learning programmes, these are outlined below.
Screen sharing and file sharing
Zoom allows teachers to show their full screen or a chosen window, including teaching resources or websites – students will not be allowed to do so. Teachers need to make sure they don’t inadvertently display:
• Personal information – e.g., having a social media website open, which may reveal personal information
• Inappropriate content – e.g., photos, text, apps or websites that may display content unsuitable for children
For this reason, teachers should have a “clean” screen and desktop, and turn off any apps that may interrupt the session (such as alarms, alerts, or incoming Skype calls).
File sharing is not available within Zoom so it is the responsibility of the parent or guardian to access any information required to participate in the session prior to the session starting: any links or email data should be accessed prior to the Zoom session to avoid any chance of sharing personal data. Should access to personal site be required by the student during the session, the NCOTB teacher will end the session and send a link back to the session once this data has been accessed. NCOTB teachers, students, parents or guardians will agree never to try and access their personal information, emails, photo albums, video files or any other type of personal information during the session.
Data and access to data using Zoom
Zoom is a secure online platform. As with other online learning platforms used by schools, nobody external to NCOTB will have access to video streams, passwords, or any data related to online lessons.
Students are instructed not to take screenshots or make video recordings of online sessions. Any training materials used for lessons will be shared by the teacher in advance.
GDPR – Children’s personal information
NCOTB will not collect any information about students’ personal IDs or logons. Unlike other systems (such as Skype, Facetime, or Messenger) Zoom works by sending a password protected invitation link to the parent or guardian’s email address. All invitations will be password protected.
Students are asked not to share any personal contact information with teachers or other students (such as social media names or phone numbers). If there are any issues with students doing this, the teacher will remove the student from the online session and contact the parent or guardian to discuss how to stay safe online.
2.3 Quality Assurance
NCOTB is committed to ensuring that our online lessons are a high-quality experience for our learners.
At the heart of our provision we
• Ensure our GDPR policy conforms to national guidelines.
• Ensure our teachers have undergone the relevant safeguarding training.
• Ensure teachers plan for structured, progressive lessons that challenge and encourage learners
2.4 Parental involvement and Expectations
Having the support of a parent or guardian in setting up the lesson is often needed as the invitations will be sent to a parent or guardian’s email address. We ask that parents or guardians are within earshot as this is important for safety as well as for practical help. Parents or guardians are expected to be present at the start and finish of lessons wherever possible.
The level of involvement of the adult during the lesson will depend on the age of the student. Younger children may need a person in the room to help keep them focused and safe, particularly if it is a new activity. But too much parental involvement can also be distracting or cause shyness with older students. In general, it is recommended that after the first few lessons, a parent or guardian is within earshot but not “in the lesson” wherever possible.
Parental Consent for online tuition
Prior to any ‘live’ communication, a permission form will be emailed to the parent or guardian with understanding that no correspondence or communication can be entered into without the completion of this form. This form will be a brief checklist of the most important aspects of this policy, and will include a check that parents or guardians have read and understood the whole of this document.
NEW CODES FOR NEW KIDS 