Advanced Coaching & Education (ACE)

Privacy Notice

August 2026

Version 8

We are Advanced Coaching & Education, operating as ACE. Our  programmes include ACE Tots (4–7), Further and Higher Education  Academy (16–21), Alternative Provision (11–17) and Holiday Activities  Programme (4–12). We are registered with the Information  Commissioner’s Office (ICO), registration reference ZC26472.

1. Who is responsible for your information

We use personal information to educate and support pupils, safeguard children, run ACE and meet our legal responsibilities. This notice explains what we use, why we use it, who receives it, how long we keep it and how you can exercise your rights. It covers pupils, parents and carers, staff, volunteers, applicants and visitors.

2. Information we use and where it comes from

For pupils we use identity and contact details, date of birth, pupil identifiers, family and emergency contacts, admission and referral information, attendance, attainment, work and assessments, behaviour, suspensions and exclusions, placements and reintegration plans. Where relevant we use information about SEND, EHCPs, health, medication, disability, safeguarding, social care involvement and looked after status.

For parents and carers we use names, contact details, relationship to the pupil, parental responsibility, communication and complaint records and information needed for support or safeguarding. For staff and volunteers we use identity and contact details, recruitment and references, qualifications and vetting checks, employment, pay and benefits, performance, training, absence and relevant health and equality information. For applicants we use applications, interview records and necessary checks.

For visitors and users of our services we may use contact details, entry logs, correspondence. For academy devices and accounts we may use security and filtering or monitoring information such as account activity, access logs and alerts.

Information comes from you, pupils, families, staff, previous or originating further  education providers, commissioning authorities, other education providers, examination bodies, referees and vetting agencies. Relevant information may also come from health services, social care, police and safeguarding partners. We collect only what is needed for the relevant purpose.

Why We Use Information

3. Purpose and lawful bases

This notice gives effect to GDPR policy section 10. Our roles follow section 6, systems section 12, retention section 13, sharing section 14, rights section 15 and Appendix A, and complaints section 21. We use the UK GDPR and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025. The following describes the intended academy processing. Our Operations Manager can explain the basis for a particular use.

Purpose	Information and usual lawful basis
Tots, holiday bookings and activities	Booking, participation, contact and payment details. Contract for services with the individual; assessed legitimate interests for necessary participant administration and safe delivery. Health information needs an additional condition.
Education, attendance and support	Pupil records, assessments, attendance and placement information. Contract under Article 6(1)(b) where necessary for a contract with the individual; legitimate interests under Article 6(1)(f) for proportionate delivery and coordination of commissioned learning, subject to a balancing assessment. Legal obligation for applicable duties; public task only where a relevant legal function is established.
Safeguarding and welfare	Concerns, referrals, risk and welfare records. Legal obligation where an applicable duty exists; recognised legitimate interests under Article 6(1)(ea) only where the statutory safeguarding purpose and conditions apply, or assessed legitimate interests where appropriate. Vital interests for qualifying emergencies.
SEND and health support	Support needs, plans, reviews and necessary health information. Applicable legal obligation or assessed legitimate interests in providing safe and appropriate support; public task only for an established legal function. An additional special category condition is required.
Employment and recruitment	Applications, checks, employment and payroll records. Contract under Article 6(1)(b) for necessary employment or precontractual steps; legal obligation for tax, right to work and applicable safeguarding checks.
Governance, finance and complaints	Records needed to run the academy, account for spending and resolve concerns. Applicable legal obligations, necessary contractual processing, or legitimate interests in sound administration, service quality and resolving concerns, subject to balancing against individual rights.
Security and safeguarding monitoring	Site entry,  authorised monitoring and relevant incidents. Legitimate interests in site safety and information security, subject to necessity and balancing.
Optional publicity	Identifiable promotional photos or videos where we ask permission. Consent under Article 6(1)(a); refusal or withdrawal does not affect education. Educational and safeguarding image uses are assessed separately.

Information That Needs Extra Protection

Special Category Personal Data

ACE recognises that certain personal information, including information about health, disability, SEND, ethnicity and religion, requires additional protection under data protection legislation.

Before processing special category personal data, ACE will identify and document an appropriate Article 6 lawful basis and a valid Article 9 condition. Where required, ACE will also identify the applicable condition under Schedule 1 of the Data Protection Act 2018 and maintain an Appropriate Policy Document.

The legal condition used will depend on the purpose of the processing. ACE will not assume that the same condition applies to all SEND, medical, safeguarding, employment or equality-monitoring information.

Access to special category personal data will be restricted to authorised individuals who need the information for their role. ACE will ensure that information is handled securely, shared only where lawful and necessary, and retained in accordance with its retention arrangements.

Criminal offence information and DBS checks are processed only with the authority or condition required by Article 10 and UK law. We maintain the additional policy documentation where required. We do not keep certificate copies simply because we performed a check.

Do you have to provide information

We will tell you when information is required by law, needed for a contract or optional. If essential information is missing, we may be unable to provide particular support, administer employment or complete required reporting. We will explain the consequences for the relevant request. You can withdraw consent at any time; this does not affect processing that was lawful before withdrawal.

Sharing Security and Retention

4. Who receives information

We share relevant information where necessary and lawful, rather than giving all recipients access to all records. Recipients may include:

• Originating, previous and receiving further education providers, alternative providers and commissioners, for placements, attendance, support and transitions.
• Local authorities, SEND teams, local authority education support teams, social care, health professionals, police and safeguarding partners, for relevant education and welfare functions.
• The Department for Education for required pupil and workforce collections, and Ofsted, auditors or regulators where they need information for their functions.
• Examination and awarding bodies for entries, assessments, adjustments and qualifications.
• Contracted IT, management information, safeguarding, communications, payroll, pensions, professional advisory and secure disposal providers who need information to deliver services.

Where applicable, we share relevant pupil characteristics, attendance, attainment and workforce information with DfE through the required collections or lawful commissioning arrangements. DfE is responsible for its own use; its learner and workforce privacy information is available through GOV.UK. You can ask our Operations Manager for details of the recipients relevant to your information.

5. Security

We restrict information to people who need it, use our managed Google Workspace account and approved storage and transfer methods, train staff and require relevant safeguards from service providers. Paper and digital records are protected according to their sensitivity. Our Data Breach Procedure sets out how we investigate incidents and make required notifications.

How Long We Keep Information

6. Retention Periods

Our Records Retention and Disposal Policy sets category specific periods and is available from the Operations Manager. We keep information for the purpose for which it is needed and any applicable legal requirement, then securely delete or genuinely anonymise it. The proposed schedule includes:

 

Information	Period or criterion
Core AP learner education records	AP benchmark: until age 25 where necessary and we remain custodian; transfer arrangements apply.
Safeguarding files	Until age 25; child sexual abuse files until age 75, subject to transfer arrangements.
Admission and attendance registers	Routine attendance: six years from entry as an ACE benchmark. Funded evidence: six years from financial year end following last payment, subject to the applicable funding agreement.
Tots, holiday and further education	Routine Tots and holiday records: programme end plus three years. Essential further education administration: completion or withdrawal plus six years; DfE funded evidence: six years from financial year end following last payment, subject to funding and qualification rules.
Personnel and unsuccessful applications	Personnel: employment end plus six years. Unsuccessful applicants: decision plus six months.
CCTV and visitor records if used	CCTV: thirty days. Visitor logs: one year, unless needed for an incident.
Complaints and breach accountability records	Closure plus six years. Relevant pupil or safeguarding evidence may follow a longer period.

 

These periods must match the academy’s approved schedule. Legal claims, investigations, information requests or inquiries can require relevant records to be held longer; we review and document that need. Other financial, pension or specialist records follow their applicable requirements.

Your Rights and Questions

7. Your Rights

You can ask for access to your personal information and correction of inaccurate information. Depending on the circumstances, you can also request erasure, restriction or portability. These rights have legal limits; for example, we may need to keep records for a legal duty or a necessary safeguarding purpose. We explain any refusal and your options.

Your right to object

You can object to processing based on public task where applicable, or legitimate interests if that basis applies, on grounds relating to your situation. We must consider your objection and explain whether compelling grounds or legal claims justify continuing. You can object to direct marketing at any time. Contact our Operations Manager to exercise this right.

To make a rights request, contact info@advancedcoachingeduation.co.uk. We will usually respond within one month. Where the law permits an extension or a pause for necessary clarification, we will explain it. We may ask for proportionate evidence of identity or authority. A child’s information belongs to the child; parental access depends on the circumstances, the child’s understanding and legal rights.

 

8. Automated decisions and new uses

We explain significant changes to our use of information and update this notice. If we use a new monitoring system, online service or AI tool with personal data, we assess its impact and explain the relevant use and safeguards before introduction where required.

9. Questions and Complaints

Please contact our Operations Manager with questions or a concern about how we use information. Send a complaint to info@advancedcoachingeduation.co.uk. We acknowledge data protection complaints within thirty days and respond without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO). You do not have to obtain our permission to contact it.

ICO contact and complaints: https://ico.org.uk/make-a-complaint/ • Telephone 0303 123 1113 • Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

A short explanation for pupils

We keep information to help you learn and stay safe, such as your contact details, attendance, progress and support needs. Only people who need the information should use it. Sometimes we share it with people who help you, such as your originating further education provider or social worker. You can ask what we hold, tell us if something is wrong and speak to Paul Davis paul@advancedcoachingeducation.co.uk or our Operations Manager. We can explain this notice in a way that works for you.