May 2022
What is the purpose of this document?
Cub (KME NURSERIES LTD) are committed to respecting and protecting the privacy and security of personal information. This privacy policy describes how the business collects and uses personal information about prospective, current, and former consumers of its services, website, and social media. In this instance, the ‘consumer’ may be a parent, guardian, child, visitor, or employee.
Cub (KME NURSERIES LTD) are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.
This policy does not form part of any contract of employment or other contract to provide services.
For simplicity throughout this Notice, ‘we’, ‘us’ and ‘our’ means Cub (KME NURSERIES LTD) and ‘you’ or ‘your’ means Consumer.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
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- Used lawfully, fairly and in a transparent way.
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- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
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- Relevant to the purposes we have told You about and limited only to those purposes.
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- Accurate and kept up to date.
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- Kept only as long as necessary for the purposes we have told you about.
Why do we collect your personal information?
We limit the collection of your personal information to what is necessary. Below we have highlighted the main reasons for collection:
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- Fulfil or meet the reason you provided the personal information to us.
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- Respond adequately to your requests for Services or information.
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- Provide Services to you and/or your dependents.
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- Personalise, enhance, and support your website experience and/or the Services.
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- Create, maintain, customise, and secure your account with us.
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- Facilitate and process purchases, financial transactions, and payments.
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- Provide information regarding our Services and areas of interest to you.
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- Research and analyse existing Services for training and quality purposes and develop new Services.
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- Comply with laws, regulations, and sector standards.
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- Protect the security of our technology and data.
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- Fulfil tax, reporting, and other financial requirements and obligations.
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- Prevent or detect unlawful acts.
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- As described to you when collecting your personal information.
When do we collect your personal information?
There are a variety of contexts under which we will collect your personal information.
When you visit our websites or social media, we collect your personal information from:
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- Monitoring your electronic visit and engagement with us.
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- The information you provide to us (for instance, by completing one of our webforms).
Our website is not intended for use by children under 16 years of age nor do we knowingly collect personal information from children under 16 through our website. If you are under 16, please do not use or provide any information on our website.
When you call our nurseries or one of our directors, we will collect your personal information from:
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- The verbal information you provide to us.
When you receive Services from us, we will collect your personal information from:
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- The information you provide to us.
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- Completion of enrolment forms, assessments, and other documentation as part of the provision of Services.
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- Forms relating to the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, and other background check agencies.
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- We will collect additional personal information throughout the period of which an Employee works for us, during job-related activities.
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- Recorded images at locations with CCTV cameras.
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- Use of key fobs or biometric technology to gain access to the Services.
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- If you receive government funding, we may receive personal information from the government on your eligibility for the funding and other reporting identifiers.
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- Government agencies may provide us with personal information to support their regulatory obligations or investigations.
When you receive services from us, what information will we collect and store?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.
PARENTS:
We will collect, store, and use the following categories of personal information about Parents:
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- Personal and Work Telephone numbers
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- National Insurance Number (if child is accessing funding)
We may also collect, store, and use the following “special categories” of more sensitive personal information:
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- Information about a Parent’s race or ethnicity, spoken language and nationality.
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- Information relating to safeguarding concerns or issues
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- Conversations with Parents where Employees of the Nursery/Family Club deem it relevant to the prevention of radicalisation or other aspects of the government’s Prevent strategy.
CHILDREN:
We will collect, store, and use the following categories of personal information about children:
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- Home address / additional addresses
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- Parent / Guardian Contact details
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- Emergency contact details
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- Photographs of the Child to be used within the nursery e.g., for self-registration, or display purposes.
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- Information relating to planning and assessment, including the Child’s stage of learning and development and progress during the period of attendance.
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- Observations & photographs uploaded onto the Nursery Management software
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- Records relating to individual Children e.g., health care plans, referral forms
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- Accidents & Incident forms, and pre-existing injuries/injury at home forms
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- Medication Authorisation forms
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- Records of any reportable death, injury, disease, or dangerous occurrence
We may also collect, store, and use the following “special categories” of more sensitive personal information:
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- Information about a Child’s race or ethnicity, spoken language and nationality.
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- Information about a Child’s health, including any medical condition, health, and sickness records.
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- Information relating to a Child’s accident or incident, including reports of pre-existing injuries.
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- Information relating to safeguarding, including child protection referral forms / child protection case details / reports.
EMPLOYEES:
We will collect, store, and use the following categories of personal information about Employees:
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- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
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- Marital status and dependants.
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- Next of kin and emergency contact information.
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- National Insurance number.
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- Bank account details, payroll records and tax status information.
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- Salary, annual leave, pension, and benefits information.
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- Start date and, if different, the date of an Employee’s continuous employment.
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- Location of employment or workplace.
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- Copy of passport and/or driving licence (where applicable).
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- Recruitment information (including copies of right-to-work documentation, references and other information included in a CV or cover letter or as part of the application process).
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- Qualification certificates where applicable
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- Continued professional development certificates where applicable
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- Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
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- DBS number for the purposes of checking the DBS update service
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- Personnel files and training records including performance information, disciplinary and grievance information, and working time records.
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- Information about your use of our information and communications systems.
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- Records of any reportable death, injury, disease, or dangerous occurrence.
We may also collect, store, and use the following “special categories” of more sensitive personal information:
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- Information about an Employee’s race or ethnicity.
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- Information about an Employee’s health, including any medical condition, accident, health, and sickness records, including:
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- where an Employee leaves employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
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- details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
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- where an Employee leaves employment and the reason for leaving is related to their health, information about that condition needed for pensions and permanent health insurance purposes.
If you are a visitor, we will collect:
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- Contact information such as name, telephone number, email address, car registration and mailing address
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- Where applicable, your DBS reference number.
Where will we store your personally identifiable information?
Electronic Information:
The electronic personal information we collect about you will be stored and processed on electronic information systems operated by Cub (KME Nurseries Ltd).
Hardcopy Information:
Any hardcopy personal information we collect from you will be stored securely in a locked filing cabinet at the Nursery of which your child is enrolled.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
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- Where we need to perform the contract we have entered into with you.
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- Where we need to comply with a legal obligation.
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- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
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- Where we need to protect your interests (or someone else’s interests).
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- Where it is needed in the public interest or for official purposes.
How we use particularly sensitive personal information
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
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- In limited circumstances, with Employee or Parent explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with Employee employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect an Employee, a Child, or a Parents’ interests (or someone else’s interests) and the Employee, Child, or Parent as is appropriate is not capable of giving consent, or where the Employee or Parent has already made the information public.
The Nursery’s obligations as an employer:
We will use particularly sensitive personal information of Employees in the following ways…
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- We will use information relating to leaves of absence, which may include sickness absence or family-related leaves, to comply with employment and other laws.
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- We will use information about the physical or mental health of an Employee, or their disability status, to ensure Employee health and safety in the workplace and to assess the fitness of Employees to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions, and permanent health insurance.
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- We will use information about an Employee’s race or national or ethnic origin, religious, philosophical, or moral beliefs, or an Employee’s sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Do we need Employee consent?
We do not need the consent of Employees if we use special categories of personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach Employees for their written consent to allow us to process certain particularly sensitive data. If we do so, we will provide Employees with full details of the information that we would like and the reason we need it, so that Employees can carefully consider whether they wish to consent. Employees should be aware that it is not a condition of their contract with the nursery that they agree to any request for consent from us.
Who will we share your personally identifiable information with?
Cub (KME Nurseries Ltd) considers your personal information confidential and does not sell it to other parties. However, there are limited circumstances that may require us to share personal information.
Agents and Service Providers:
We sometimes employ or contract with other companies and individuals to perform functions on our behalf, such as supporting our systems infrastructure, providing recruiting services, and supporting our call centres. These parties are under a legal obligation to use your personal information as solely provided in the contractual services to Cub (KME NURSERIES LTD).
Business Transfers:
As we continue to develop our business, we might sell or buy assets. If any Cub (KME NURSERIES LTD) business unit is sold or substantially all of Cub (KME NURSERIES LTD) is acquired, personal information relevant to the operation sold could be one of the transferred assets.
Legal Requirements:
We may share personally identifiable information with law enforcement or other entities as required by law or as we reasonably determine to be necessary to protect our rights or the rights of others, to prevent harm to persons or property, to fight fraud, or to enforce our web site terms of use.
Local Authorities:
For funding and monitoring reasons (e.g., equal opportunities and uptake of funded hours)
Regulatory Bodies:
To ensure compliance and the safety and welfare of the children
Schools:
To provide a successful transition by ensuring information about the child’s progress and current level of development and interests are shared
How can individuals access their personally identifiable information?
To exercise your rights to access and make appropriate changes or deletions to personally identifiable information we have gathered about you:
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- You may directly contact the entity (i.e., the nursery where your child is enrolled) that stores or process your personally identifiable information to access and update it. Cub (KME NURSERIES LTD) may require you to make your access and update requests in writing and to verify your identity.
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- Individuals have a right of access to personal data held by Cub (KME NURSERIES LTD) relating to themselves. Any individual wishing to access their personal data should put their request in writing to the Manager. Cub (KME NURSERIES LTD) will endeavour to respond to any such written request as soon as is reasonably practicable and, in any event, usually within 40 days.
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- No administrative fee would apply.
Links to Other Sites:
This site may contain links or references to other websites. Please be aware that we do not control other websites and that this privacy policy does not apply to those websites. We encourage you to read the privacy policy of every website you visit.