Phoenix Early Learners customer privacy notice

Post

Phoenix Early Learners, Cedarwood, 9 Dale Wood Road, Orpington, Kent, BR6 0BY, GB

Telephone

01689505934

Email

hello@phoenixearlylearners.org.uk

Student Education and Welfare

We collect or use the following information for student education and welfare:

• Names and contact details for students/children

• Names and contact details for parents, guardians, carers

• Gender

• Date of birth

• Next of kin and emergency contact information

• Dietary requirements (including vegetarian, vegan, gluten free and religious requirements)

• Payment details and financial information including transactions

• Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)

• Welfare information (includes family and home life circumstances and history)

• Photographs

• Attendance and reason for absence data

• Account access information

• Progress reports

• Exclusion, suspension and behavioural information

We also collect or use the following special category information for student education and welfare. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin

• Health information

Queries, Complaints or Claims

We collect or use the following personal information dealing with queries, complaints or claims:

• Names and contact details

• Addresses

• Witness statements and contact details

• Relevant information from previous investigations

• Financial transaction information

• Information relating to health and safety (including incident investigation details and reports and accident book records)

• Correspondence

Information Updates or Marketing

We collect or use the following information for information updates or marketing purposes:

• Names and contact details

• Addresses

• Marketing preferences

• Photographs

• Records of consent, where appropriate

Recruitment

We collect or use the following information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)

• Date of birth

• National Insurance number

• Copies of passports or other photo ID

• Employment history (eg job application, employment references or secondary employment)

• Education history (eg qualifications)

• Right to work information

• Details of any criminal convictions (eg DBS, Access NI or Disclosure Scotland checks)

• Security clearance details (eg basic checks and higher security clearance)

Legal Requirements

We collect or use the following information to comply with legal requirements:

• Identification documents

• Health and safety information

• Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

• Safeguarding information

• Any other personal information required to comply with legal obligations

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification. 

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure. 

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing. 

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing. 

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability. 

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for student education and welfare are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task - we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

● Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

● Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

● Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for recruitment purposes are:

● Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

● Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

● Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

● Vital interests - collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

● Public task - we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

• Directly from you

• Regulatory authorities (eg HMRC)

• Parents or carers

• Local authorities or local councils

• Social services

• Publicly available sources

• Previous employers

• Suppliers and service providers

We store personal data only for as long as necessary to comply with our legislative and regulatory obligations. In most cases, this means we retain data for a period of seven complete calendar years. Where required by law we will retain data only in so far as is necessary to achieve compliance.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Joint controllers

We have a joint controller relationship with the London Borough of Bromley. We process your personal information with that joint controller for the following reason: In order to carry out the function of the pre-school and ensure your child’s progress through to primary education, including but not limited to the provision of government funding.

Others we share personal information with

• Local authorities

• Organisations we need to share information with for safeguarding reasons

• Relevant regulatory authorities

• External auditors or inspectors

• Organisations we’re legally obliged to share personal information with

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

January 2026