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Initio Learning Trust Vacancy Privacy Statement

As part of the registration process, you should have read our Candidate Account Privacy Notice. We also need you to know how we process your application data for this vacancy.

The following explains how we, Initio Learning Trust (Data Controller) intend to use the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.

Who collects this information

In accordance with the General Data Protection Regulation (GDPR), Initio Learning Trust is the Data Controller and ultimately responsible for ensuring the data you provide is kept secure, processed correctly and that you understand your legal rights in relation to the data you provide.

The recruitment software we use via this website is supplied by Iris Software Group Limited (4th Floor Heathrow Approach, 470 London Road, Slough, SL3 8QY). They are defined as a Data Processor under the GDPR. They will only process your data in accordance with our instructions.

Who collects this information

Initio Learning Trust is the Data Controller. This means that we are responsible for deciding how we hold and use personal information about you and that we are ultimately responsible for ensuring the data you provide is kept secure, processed correctly and that you understand your legal rights in relation to the data you provide. 

The recruitment software we use is supplied by Iris Software Group Limited (4th Floor Heathrow Approach, 470 London Road, Slough, SL3 8QY). They are defined as a Data Processor under the UK GDPR. They will only process your data in accordance with our instructions.

What information do we collect from you?

We collect information that is specifically provided by you as part of the application process. We will collect the following (but not limited to):

• Name, address, email, telephone number
• Answers to application questions
• CV (if applicable)
• Equal opportunities monitoring information (defined as special categories data) - this information is anonymised, and is purely for statistical analysis and monitoring purposes
• Any other information you wish to provide in support of your application.

We also collect further information from applicants who are shortlisted for interview in order to to support robust decision-making, expedite safer recruitment checks and promptly appoint the best candidate. 

This information usually includes:

• Personal identification documents
• Proof of Right to Work in the UK
• Self-declaration of relevant criminal convictions
• Details collected through any pre-employment checks including criminal records; this may include online searches and social media checks. 
• Verification of qualifications
• We may also ask your nominated referees for details of any conduct, grievance, performance issues, appraisals, time and attendance.

Why do we collect your information?

Generally, the purpose of us collecting your data is to support robust decision-making, expedite safer recruitment checks, and promptly appoint the best candidate. 

We also collect data in order to carry out equal opportunities monitoring and to ensure appropriate access arrangements are put in place if required.

If you fail to provide certain information when requested, we may not be able to take the steps to enter into a contract with you, or we may be prevented from complying with our legal obligations.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

How do we collect your information?

We may collect this information from you, your referees, your education provider, by searching online resources, from relevant professional bodies, the Home Office and from the DBS.  We may gather information that is available publicly from online search engines and social media.

How do we use your information?

We will only use your personal information when the law allows us to. Most commonly, we will use your information in the following circumstances:

• Where we need to take steps to enter into a contract with you; 

• Where we need to comply with a legal obligation (such as health and safety legislation, under statutory codes of practice and employment protection legislation); 

• Where it is needed in the public interest or for official purposes; 

• Where it is necessary for our legitimate interests (or those of a third party) and your interests, rights and freedoms do not override those interests. 

• Where it is necessary for the purposes of a "Recognised Legitimate Interest" under the Data (Use and Access) Act 2025 (such as safeguarding vulnerable people or the prevention and detection of crime); 

• Where you have provided your consent for us to process your personal data.

• Where it is relevant to inform the recruiting manager of potential reputational damage and/or safeguarding concerns obtained from online searches.

How we use sensitive information

Sensitive personal information (as defined under the UK GDPR as “special category data”) requires higher levels of protection and further justification for collecting, storing, and using this type of personal information. We may process this data in the following circumstances:

• In limited circumstances, with your explicit written consent;
• Where we need to carry out our legal obligations in line with our data protection policy;
• Where it is needed in the public interest, such as for equal opportunities monitoring (or in relation to our pension scheme);
• Where it is needed in relation to legal claims or where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

Criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where it is necessary to carry out our legal obligations. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.

Who do we share your information with?

We may need to share your data with third parties, including third party service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. These include the following: -

• The DBS;
• Academic or regulatory bodies to validate qualifications/experience (e.g. the TRA);
• Referees;
• Other schools;
• Recruitment and supply agencies.

We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. 

The recipients of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.

How long do we keep your information for?

Except as otherwise permitted or required by applicable law or regulation, the Trust only retains personal data for as long as necessary to fulfil the purposes they collected it for, as required to satisfy any legal, accounting or reporting obligations, or as necessary to resolve disputes.

If you are not appointed, your information will only be retained by us for 6 months from the date the offer is made to the successful candidate.

If you are successfully appointed, your personal information will be retained whilst you are an employee and used for payroll, pension and employee administration in accordance with the Privacy Notice for Staff (which is available on our website and will be issued on appointment).

Your candidate data will be anonymised after 6 months of inactivity. Candidate activity includes logging in or applying for vacancies. A deactivated candidate will no longer be searchable in the candidate database or sent any e-mails from the system. 

How secure is your information?

We have put in place measures to protect the security of your information (i.e. against it being accidentally lost, used or accessed in an unauthorised way). In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

Your rights: Access, correction, erasure and restriction

As part of the application process, you have set up a candidate account in Networx. 

Networx is dedicated to providing reasonable access to visitors who wish to review the personal information retained when you apply via their website site and correct any inaccuracies it may contain.

Once registered, you may access your profile, correct and update your details, or withdraw your details at any time. To do this, you can access your personal profile by using the secure login. In all cases we will treat requests to access information or change information in accordance with applicable legal requirements.

Under certain circumstances by law you have the right to:

• Access your personal information (commonly known as a ‘subject access request’). This allows you to receive a copy of the personal information we hold about you. Please note that under the Data (Use and Access) Act 2025, the Trust is only legally obligated to provide confirmation and personal data that can be located following a reasonable and proportionate search for the requested information.  Within your Networx candidate account, you can also use the Download Data feature to generate an XML file of the current data we hold on you that you have provided and/or have access to within the account.

• Correction of the personal information we hold about you. This enables you to have any inaccurate information we hold about you corrected. Please note that where records reflect historical events, professional opinions, or safeguarding reports, these represent a factual record of what was reported or understood at that specific time. In these circumstances, the Trust cannot erase or alter the original historical record. Instead, we will fulfil your right to rectification by appending a supplementary statement to the file. 

• Erasure of your personal information. You can ask us to delete or remove personal data if there is no good reason for us continuing to process it. Please note that this is not an absolute right. The Trust cannot erase personal data where we are required by law to retain it (for example, statutory pupil records, attendance registers, or safeguarding files), or where it is necessary for the performance of a task carried out in the public interest.

• Restriction of processing your personal information. You can ask us to suspend processing personal information about you in certain circumstances

• Object to processing in certain circumstances. Please note: You have an absolute right to object to your data being used for direct marketing

• Challenge significant decisions made about you based solely on automated processing, and obtain human intervention. 

• Transfer your personal information to another party.

If you want to exercise any of the above rights, please contact your relevant school’s Headteacher, or the Data Protection Officer. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.  

Your right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please update your preferences within your Networx candidate account.

To withdraw your consent, please notify the school office or update your preferences via the Trust recruitment portal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to raise a concern

We have appointed a Data Protection Officer (DPO) to oversee compliance with data protection and this privacy notice.  If you have any questions about how we handle your personal information which cannot be resolved by the relevant school’s Headteacher or their delegate, then you can contact the DPO, details below: 

Data Protection Officer: Tracy Broadbent

• Address: Allenbourn Middle School, East Borough, Wimborne, BH21 1PL 
• Email: privacy@initiolearning.org
• Telephone: 07761 045361

If your concern amounts to a formal complaint regarding the Trust's handling of your personal data, it will be managed in accordance with our statutory obligations. The Trust will acknowledge your data protection complaint without undue delay and the Data Protection Officer will provide a formal written outcome within one calendar month of receipt, as outlined in our main Data Protection Policy.

You also have the right to make a complaint at any time to the Information Commission, the UK supervisory authority for data protection issues.

• Report a concern online at: https://ico.org.uk/concerns/
• Call: 0303 123 1113
• Write to: Information Commission, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.