- Websites and social media
- Becoming a member
- Getting advice and support
- NAHT marketing and communications
- Participating in NAHT research
- Ballots and industrial action
- Volunteering with NAHT
- Attending an NAHT course or event
- Contacting NAHT
- Exercising your data rights
Complying with requests from law enforcement bodies
- Making a complaint about NAHT
- Applying for a job at NAHT
- Changes to this policy
Websites and social media
Our website, www.naht.org.uk, uses a third-party service to collect standard information from Google analytics. This logs information from visitors to the website regarding their behaviour patterns. NAHT use this information to understand things such as which parts of our site are most popular. Within Google analytics we may create trackable URLs which can be assigned to individuals to understand individual website activity.
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. You can find out more about cookies by visiting www.allaboutcookies.org.
We use a third-party provider, Hootsuite, to manage our social media interactions.
We pass encrypted data to third-parties for the use of social media marketing. Social media sites we use include (but are not limited to) Twitter and Facebook.
We collect data from form-gated articles which include (but are not limited to) Twitter and Facebook. This data may be used for marketing purposes if you have consented. We always provide the option to fill in the form but not consent to receiving marketing communications.
Hootsuite will retain any private or direct messaging you send via social media for a three month period. They do not share your information with any other organisation.
Becoming a member
We collect data from completed online and paper-based membership application forms, and also verbally when someone joins by telephone. We may also receive information about you from the Independent Association of Prep Schools (IAPS), the Institute of School Business Leadership (ISBL) or The Association of Heads of Outdoor Education Centres (AHOEC) if you are joining as part of their member referral scheme.
We collect the data which is needed to fulfil the core functions of being a member of NAHT. This includes your contact and bank account details. We also collect some other information, including your gender, which we are required to collect by the Certification Officer. For more information on the requirements of the Certification Officer, see here.
Sometimes our online joining journey has a hiccup and we lose applicants during the journey. If this happens to you, we will aim to give you a ring back so we can complete the application for you over the telephone, We only retain this information for a short period, so if we aren’t able to contact you, we will stop after making a reasonable number of attempts.
We will always ask you for your consent if we need anything else.
We share your contact and bank details with third-party organisations who process direct debits on our behalf.
If you decide to join IAPS, ISBL or AHOEC as part of our joint membership promotion we will share your details with them in order for you to become a member of their organisation. Similarly, if you join as part of a promotion, we may pass your contact details to a partner so that your ‘reward’ can be processed.
We use a third-party organisation, Bucksnet, to process direct debit data. From time to time, we may also use third-party organisations to collect application data via a web form and validate direct debits. We always make sure that these organisations commit to processing data to the highest security standards.
You can refer friends, colleagues and other contacts for NAHT membership. If the person you refer joins NAHT, we will often give you a reward. Details of rewards are published in NAHT promotional materials. Before referring someone, you must gain their consent for NAHT to contact them about membership. We will ask you to confirm you have done this when submitting the referral. We will then contact the referee, normally by telephone or email, to take them through the joining journey.
We may share statistics with the Trade Union Congress (TUC), who we are affiliated to. This may include information like the gender make-up of NAHT’s membership. This type of data is always shared in a way which ensures individual members can not be identified.
Getting advice and support
We have a number of people trained to help resolve an issue. These include our specialist advisors, regional officers, legal team and a network of NAHT volunteers. As appropriate, your case may be referred to one or more of these individuals. If case notes need to be shared, this will be done via a secure method. When sharing data with volunteers and third parties, the data will be subject to additional security such as encryption or password protection.
All NAHT volunteers are required to sign a volunteer agreement which requires their compliance with data protection regulation.
While working to resolve your issue, we may ask for further information relating to you or your case. Where necessary, we will ask for your consent when we do this. For example, if you require legal support, we may ask for additional consent:
- for your GP to release medical records
- to share information with opposition legal counsels
- to share your case notes with an appointed barrister.
When providing advice and support, we create a ‘case file’ containing the details of your issue. We will keep personal information contained in case files in line with our retention policy. This means that information relating to a case will be retained for seven years from closure. It will be retained in a secure environment and access to it will be restricted.
NAHT marketing and communications
Communications to non-members
From time to time, we communicate information about NAHT membership to non-members via email, SMS, telephone or post. This is to grow membership of NAHT, as the more members we have, the greater our voice and influence becomes. We will only communicate information to individuals who would have a legitimate interest in becoming a member of NAHT (i.e. school leaders). We do this under the legal basis of ‘legitimate interest’, as defined by the General Data Protection Regulations. Details of how to unsubscribe are always contained in our communications.
We only send communications about issues not related to becoming an NAHT member to non-members who have provided consent for us to do so. Communications may include information on a range of issues, including promotional offers and research questions.
When a member leaves NAHT, we may contact them to understand their reasons for leaving. We will use this information to improve our services for members.
Communications to members
There are a range of communications which you may receive as an NAHT member.
Some communications are essential for the maintenance of an NAHT membership, for example an email notification of a failed direct debit payment. Due to the essential nature of these communications, you can not withdraw your consent to receive them. The only way to stop receiving them is by cancelling your membership.
Some communications are for marketing and marketing research purposes. These can be unsubscribed to by clicking unsubscribe in the email or opting out of the text message (please note that this will opt you out of text marketing messages for that specific telephone number, not all telephone numbers we may hold). To process these communications, your data is held on third-party software, including the Dotmailer marketing automation system, and the research tool, Survey Monkey.
We collect data from form-gated articles which include (but are not limited to) email and Google search platforms. This data may be used for marketing purposes if you have provided your consent for us to do so. We always provide the option to not consent to receiving marketing communications.
A number of other communications are essential to ensuring that you are fully equipped to act as a member of a trade union. As such, upon joining, you are automatically signed-up to receive them. We list these communications as benefits of your membership in our membership proposition. They include:
- Leadership Focus, our termly magazine
- our weekly newsletter
- bespoke policy updates
- information about national CPD events and training opportunities.
You can withdraw your consent to receiving these communications by visiting the ‘NAHT email preference centre’. This can be accessed by selecting the link at the bottom of most NAHT emails.
We work with a number of partner organisations who offer a range of products and services, often at discounted rates for NAHT members. We will not share your details with these partner organisations without your consent. Members can provide consent to receive these types of communication by visiting the ‘NAHT email preference centre’. This can be accessed by selecting the link at the bottom of most NAHT emails.
We provide additional products and services to members directly through our NAHT Assured and NAHT Aspire School Improvement provision. These are part of the benefits of being an NAHT member and, as such, members are automatically opted-in to receiving communications about them. You can withdraw your consent to receiving these communications by visiting the ‘NAHT email preference centre’. This can be accessed by selecting the link at the bottom of most NAHT emails.
We work with a number of marketing partners who may be provided your data in order to fulfil marketing promotions (for example, to send you a voucher for referring a friend). Each partner is contracted to a data sharing agreement which does not permit marketing partners to contact you for any reason other than the fulfilment of NAHT promotions.
From time-to-time, you may also be contacted by NAHT regional and branch officials. This may be about a range of issues, including regional events, planned industrial action or welcoming you as a new member.
From time-to-time we may run online prize draws or competitions for members and non-members, sometimes as part of a survey. We also collect data for entry into prize draws and competitions at industry events. The data for these is held securely throughout the event in a secure box.
To enter a competition, we will require information such as your name and email address, so that we can contact you about the result of the competition. This data will be destroyed as soon as possible after the competition has closed.
Prize draws and competitions will always be optional. We may use the data collected for marketing purposes, but will always provide the option to enter a prize draw or competition but not consent to receiving marketing communications.
Participating in NAHT research
It’s important that we know the views of our members. From time-to-time, you may be invited to participate in a survey or focus group. Invitations will usually be communicated in our weekly NAHT newsletter or an issue of Leadership Focus magazine. However, members of NAHT Executive, Committees or task and finish groups may be invited directly.
All of our surveys are conducted using SurveyMonkey, an online tool.
Occasionally, we will publish our research or submit it to another organisation, for example the Department for Education. Unless you have given consent for us to do so, we will only ever present data about our members in a form which doesn’t identify anyone.
Ballots and industrial action
Balloting members on important issues, and undertaking industrial action, are part of our core function as a trade union.
In accordance with legislation, ballots are administered by an independent scrutineer, the Electoral Reform Service (ERS). We provide ERS with member data (including names and addresses ) to enable them to do this. The ERS are responsible for sending ballot papers to members and processing submitted ballot papers. ERS then share the outcome with us. We aim to inform members of the outcome of ballots as soon as possible.
In the event that industrial action is called, legislation requires us to inform employers of the job title and location of all members in their employment who will be induced to take action. We do not share member names or any other member details with employers.
For statutory elections, candidates who put themselves forward for nomination are asked to provide a personal statement and photograph. These will be shared with ERS, who will include them in ballot papers which will be shared with members eligible to vote.
Volunteering with NAHT
A range of official roles are available for members who are able to be more involved in NAHT activities, for example by taking on the role of branch secretary or branch treasurer. Such roles may involve leading or assisting on casework. Volunteers must sign the volunteer agreement and become accredited to undertake these roles. Accreditation requires members to complete training. Once accredited, we provide officials with an ID card, for which we will need a photograph.
From time-to-time, NAHT will invite applications from the membership to join NAHT’s National Executive, councils and committees. Vacancies will usually be advertised on the NAHT website and will be communicated via the weekly NAHT newsletter (sent during term-time). We collect data through an application form and only ask for details which are needed to process the application. These may include contact details and information about your current role and experience. We may also occasionally require a photograph for the purpose of the electoral statement. We keep a record of all volunteers, including their role and contact details.
For national executive positions (which require a statutory election), the information provided will be shared with an independent scrutineer, Electoral Reform Services (ERS), who administer NAHT’s elections.
For council/committee positions, the information provided will be shared with the chair of the council/committee to which the application relates. Application data will be retained for no longer than one year and will not be shared with any other organisations.
Attending an NAHT course or event
Most of our courses and events are booked via a website called Eventbrite. Eventbrite allows you to both register and pay for an event. This requires you to submit information including contact and bank details. More information on how Eventbrite manage data is available on their website.
On occasion, we may use alternative methods for booking people onto our events without the use of a booking website.
When booking a course, you’ll need to provide us with some information about you, including your name and contact details. We’ll only use this information to process your booking, and will share it with other organisations only when absolutely necessary. We may share your information with:
- trusted partners who have been contracted to deliver courses on behalf of NAHT (so they can administer the course to you);
- event venues (for example, attendee lists to comply with fire regulations);
- course facilitators (so that they know to expect you).
We’ll always ask for your consent before sharing your details with anyone else, for example including you on an event delegate list.
We run both face-to-face and online courses and events. When hosting an online course or event, we will endeavour to keep personal data such as your name and image private from other delegates. Where this is not possible (eg. due to the technology we are using), we will let you know during the booking process that this is the case. Depending on the course or event, you may be able to choose to share your name, image or other personal data with other delegates; we will consider your proactive enabling of this (eg. by switching video ‘on’ or entering your name) as implicit consent for this personal data to be shared with other delegates. We do not take responsibility for the content of any messages posted by delegates during online courses and events. We may take and retain a record of all comments posted by delegates. You may need to download software to access our online courses and events; please note that you do so at your own risk.
We often take photographs at NAHT events. We will always ask for your consent to take and publish your photograph, usually during the booking process or at the event registration. We will put in place measures to identify people who haven’t consented to being photographed and, wherever possible, will avoid photographing them. Where this hasn’t been possible, we will delete or anonymise any photographs which contain images of those who haven’t consented. If a photograph of you is published in error, you can request for it to be deleted by contacting our Data Protection Officer, by emailing firstname.lastname@example.org.
We often run prize draws and competitions at events. To enter, you will need to provide your contact details. We may share the winners’ contact details with a partner so that their prize can be processed, but we won’t share them with anyone else. When entering, we will give you an opportunity to consent to receiving communications from NAHT.
We monitor all emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
We don’t record telephone conversations. However, we may take a note of any discussions held. We will keep any such personal information in line with our data retention policy. It will be retained in a secure environment and access to it will be restricted.
Exercising your data rights
UK and EU legislation gives you a number of rights relating to the data organisations hold on you. We take this very seriously. To make a data request to NAHT, you can email our data protection officer or telephone us on 01444 472 472.
- Subject access requests (SAR)
A SAR enables individuals to access all personal data an organisation holds on them. We aim to respond to all SARs within 30 days, in line with relevant legislation.
An RE request enables individuals to request that an organisation deletes all or some of the personal data we hold on them.
If you notice that the data we hold on you is incorrect, let us know and we will correct it. Alternatively, you can update much of the information we hold on you by visiting the ‘update details’ page of the member area of the NAHT website.
- Right to restrict processing
If you would like us to stop using your data in a particular way or for a particular purpose, let us know and we will make sure we stop. Remember, we will always tell you what we intend to do with your data when we collect it.
Complying with requests from law enforcement bodies
From time-to-time, we are asked by the police or other law enforcement bodies for personal information relating to persons who they believe may be or may have been NAHT members. It is NAHT policy to co-operate with the police whilst taking reasonable and appropriate measures to safeguard our members’ personal information and privacy. Requests for information will be considered on a case-by-case basis. We may seek members’ consent, but in appropriate cases we may disclose information without consent. The following factors may be taken into account when deciding whether to disclose and what to disclose:
Whether we are satisfied the crime exemption in the DPA applies.
Whether or not the member consents to disclosure.
Whether it is reasonable or practicable to seek the member’s consent.
Whether withholding information or seeking consent for disclosure might endanger a person.
Whether withholding information or seeking consent for disclosure might prejudice an investigation or the prospects of bringing an offender to justice.
Any relevant duty of confidentiality or legal privilege.
In considering these factors we will inevitably be dependent on information given to us by the police oror other law enforcement bodies. We will normally assume that such information is accurate and provided in good faith.
Making a complaint about NAHT
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our data retention policy. This means that information relating to a complaint will be retained for seven years from closure. It will be retained in a secure environment and access to it will be restricted.
Applying for a job at NAHT
Job applicants, current and former NAHT employees
NAHT is the data controller for the information you provide during the recruitment process, unless we tell you otherwise. If you have any queries about the process or how we handle your information, please contact us by emailing email@example.com.
What will we do with the information you provide to us?
All of the information you provide during the recruitment process will only be used for the purpose of processing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third-parties for marketing purposes, or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors, regardless of whether the information is in electronic or paper format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
If you use our online application system, this will be collected by a data processor on our behalf (please see ‘Ikrut’, below).
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our HR team will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our HR team, including hiring managers. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Our hiring managers shortlist applications for interview. They will be able to see your application which will include your covering letter and CV only.
As part of our interview process we might ask you to prepare a presentation in advance of the interview day or complete a written exercise/test which will be given to you on the interview day. You will be invited to a two-stage interview process. Information will be generated by you and by us. For example, you might complete a written exercise and we will take interview notes. This information is held by the NAHT, in accordance with our retention policy.
If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
proof of your identity – you will be asked to bring original documents on your first day of employment, of which we will take copies
- details of any convicted criminal offences
- contact details for two referees who we will contact to obtain references
- a completed questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see ‘The Healthy Company’, below).
If we make a final offer, we will also ask you for the following types of personal information:
| Types of personal information |
| Examples |
Information about you:
|Personal contact details such as name, title, addresses, telephone numbers including mobile and personal email addresses, date of birth, gender, marital status and dependents, details of any known disability. |
|Information to contact you at work or home: |
| Name, address, telephone, email addresses. |
| || |
|Information about who to contact in case of emergency: |
|Next of kin and emergency contact information and their relationship to you. |
Information that we need to pay you:
Bank account details, national insurance number, tax status information.
Your data will be shared with colleagues within NAHT where it is necessary for them to undertake their duties to ensure a smooth onboarding process. This includes, for example, the IT department who will require your home address details to enable setup of broadband.
Use of data processors
We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we determine.
If you use our online application system, you will provide the requested information to Ikrut who provide this online service for us. Once you click ‘apply now’ you will be taken to Ikrut’s website and they will hold the information you submit but NAHT will have access to it.
For more information on how Ikrut process personal data, visit https://www.ikrut.com/privacypolicy.
Advertising on job boards (online)
We advertise roles with various job boards, including the Guardian and Totaljobs. All applicants are channelled into our online application system (Ikrut).
The Healthy Company
The Healthy Company provide our occupational health service. If we make you a conditional offer, we will ask that you complete an online questionnaire which will help to determine if you are fit to undertake the work that you have been offered, or advise us if any adjustments are needed to the work environment or systems so that you can work effectively.
We will send you a link to the questionnaire which will take you to The Healthy Company’s website. The information you provide will be held by The Healthy Company who will provide us with a fit to work certificate or a report with recommendations. You are able to request to see the report before it is sent to us. If you decline for us to see it, this could affect your job offer. If an occupational health assessment is required, this is likely to be carried out by The Healthy Company for staff based at headquarters. A local provider will be sourced for staff based elsewhere.
For more information on how The Healthy Company process personal data, visit http://www.thehealthycompany.com/main/privacy
For interim roles and senior vacancies, we will advertise with our preferred recruitment agencies and may receive information about you from them. We may provide feedback on your application or interview to for your agency to pass on to you.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus six years following the end of your employment. This includes your criminal records declaration, fitness to work, records of references and interview notes.
If you are unsuccessful at any stage of the process, the information you have provided until that point is retained by us for six months from the closure of the recruitment campaign.
Information generated throughout the assessment process, for example interview notes, is retained by us for six months from the closure of the recruitment campaign.
Equal opportunities information is retained by us for six months from the closure of the recruitment campaign, whether you are successful or not.
Ikrut will provide us with management information about our recruitment campaigns. This is anonymised information which tells us about the effectiveness of campaigns, for example, from which source did we get the most candidates or equal opportunities information for monitoring purposes. This anonymised information is retained by us for one year from the closure of the recruitment campaign.
How we make decisions about recruitment?
Final recruitment decisions are made by hiring managers and members of our HR team. For senior roles, members of our finance and personnel committee may be involved. All of the information gathered during the application and selection process is taken into account when making a decision.
You are able to ask for feedback in relation to your application by emailing firstname.lastname@example.org.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated in May 2020.