GPDR

1. Introduction

This Privacy Notice explains how Francesca Biltaji, trading as Holistic Nurture Solutions, collects, uses, stores, and protects personal data when delivering services within educational settings. This notice is written in accordance with UK data protection law.

2. Data Controller

Francesca Biltaji, trading as Holistic Nurture Solutions, is the Data Controller for the purposes of UK GDPR when providing independent services. This means responsibility for deciding how personal data is processed and ensuring it is handled lawfully.

3. Purpose of Processing

Personal data is collected and used to: -Deliver services safely and effectively within schools -Maintain accurate and appropriate records -Support children, young people, and staff -Fulfil safeguarding responsibilities

4. Categories of Personal Data

The following types of data may be collected: -Case notes relating to children, young people, or staff -Consent forms -Contact details (e.g. names, telephone numbers, email addresses) -Notes from supervision sessions or consultations -This may include special category data, such as information relating to health, wellbeing, or safeguarding.

5. Lawful Basis for Processing

5.1 Article 6 (UK GDPR)

Processing is carried out under one or more of the following:

  • Consent -Legitimate interests (delivery of services) -Legal obligation (including safeguarding duties) -Vital interests (protecting individuals from harm)

5.2 Article 9 (Special Category Data)

Where special category data is processed, the lawful basis includes:

  • Explicit consent -Safeguarding of children and individuals at risk (Substantial Public Interest)

6. Safeguarding and Information Sharing

  • Safeguarding is a fundamental aspect of service delivery.
  • Information may be shared without consent where there are concerns about safety or wellbeing.
  • Sharing will be limited to appropriate professionals (e.g. Designated Safeguarding Leads, relevant authorities).
  • Practice aligns with statutory guidance, including Keeping Children Safe in Education, and local safeguarding procedures.

7. Data Storage and Security

Appropriate technical and organisational measures are in place to protect personal data:

  • Electronic records are stored on secure, password-protected systems
  • Paper records are stored in locked, secure locations
  • Trusted third-party service providers (e.g. secure email or cloud systems) may be used.
  • These providers operate under data processing agreements and comply with UK GDPR requirements.

8. Data Retention

Personal data, including case notes and consent forms, is retained for 10 years. This retention period is based on:

  • Safeguarding responsibilities
  • Professional accountability requirements
  • Good practice for records relating to children (often retained until adulthood)
  • At the end of this period, data is securely destroyed.

9. Data Sharing

  • Information is shared with the relevant school only, where appropriate
  • Data is not shared between different schools
  • Information may be shared where required for safeguarding purposes
  • Contact details are stored centrally for service delivery
  • Personal data is not sold or shared for marketing purposes

10. Roles and Responsibilities

Depending on the context of the work:

  • Francesca Biltaji of Holistic Nurture Solutions acts as a Data Controller for independent services
  • Schools may act as separate Data Controllers
  • In some circumstances, Francesca Biltaji, of Holistic Nurture Solutions may act as a Data
  • Processor on behalf of a school -These roles are defined within service agreements.

11. Data Subject Rights

Under UK GDPR, individuals have the right to:

  • Access their personal data
  • Request rectification of inaccurate data
  • Request erasure (where applicable)
  • Withdraw consent at any time
  • Request restriction of processing
  • Request data portability
  • Object to processing
  • Requests should be made using the contact details below.

12. Complaints

Concerns about data handling should be raised in the first instance using the contact details below.

Individuals also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

https://www.ico.org.uk

13. ICO Registration

Francesca Biltaji of Holistic Nurture Solutions is registered with the Information Commissioner’s Office in accordance with UK legal requirements my unique number is C1926489.

14. Contact Details

Francesca Biltaji

Holistic Nurture Solutions

fb@holisticnurturesolutions.com

07970860921