Engineering Minds – Data Protection (GDPR) Policy

Purpose
Engineering Minds is committed to protecting the privacy and security of all personal data collected during the delivery of our LEGO Robotics Clubs. This policy outlines how we collect, store, use, and protect personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.


1. Who We Are
Engineering Minds is a provider of STEM-based afterschool and holiday clubs for children aged 5–12. In the course of delivering these services, we collect and process personal data from parents, children, staff, and third-party providers.
Data Controller:
 Engineering Minds
 Email: info@engineeringminds.org.uk


2. What Data We Collect
We may collect the following types of personal data:

From Parents/Guardians:
Child’s full name, date of birth, school, and year group
Parent/carer names and contact information (email, phone number)
Emergency contact details
Medical conditions or allergies
Special educational needs (where disclosed)
Consent for photography or media use
Booking and payment history


From Staff/Tutors:
Full name and contact information
Employment history, qualifications
ID and right-to-work documentation
DBS certificate number and issue date
Safeguarding declarations or training records



3. Why We Collect This Data
We process personal data to:
Ensure the safety and wellbeing of all children in our care
Comply with safeguarding regulations
Maintain emergency contact information
Deliver our services effectively and communicate with families
Fulfil legal and financial obligations (e.g. childcare vouchers, bursaries)
Record and respond to safeguarding, accident, or incident reports
Share updates and club communications (where consent is given)



4. Lawful Basis for Processing
We process data under the following lawful bases, as defined by the UK GDPR:
Lawful Basis                Examples
Contract                      Managing club bookings and payments
Legal obligation         Safeguarding, health & safety, DBS checks
Consent                       Media permissions, marketing emails
Legitimate interest    Improving club delivery, training staff
Vital interests             Emergency medical information



5. How We Store and Protect Data
All personal data is:
Stored securely on password-protected systems or encrypted platforms
Accessed only by authorised Engineering Minds staff and contractors
Never shared with third parties without consent (unless required by law)
Retained only as long as necessary (see retention section below)
Paper records (e.g. attendance or accident forms) are stored securely and destroyed by shredding after the appropriate period.


6. Data Retention Periods
Data Type                                     Retention Period
Child records                               2 years after final session attended
Medical/accident records          3 years minimum (or longer if safeguarding related)
Staff recruitment & DBS data   2 years after leaving role (25 years for safeguarding cases)
Financial records                        6 years (for HMRC compliance)



7. Photography and Media
Photos and videos of children may be taken only with written consent from parents/carers. Images are used solely for:
Sharing progress with parents
Club promotion (e.g. website or flyers, only with opt-in consent)
Internal training or reflection

Staff may use personal mobile phones only with prior consent and only for official purposes. All images must be deleted from personal devices after sharing with the company.


8. Data Sharing
We will never sell or distribute personal data.
We may share data only with:
School safeguarding leads (if a concern arises)
Emergency services (in case of serious injury or risk)
Local Authority or Ofsted (as required for safeguarding compliance)
Our booking platform provider (ClassForKids or equivalent) under a data-sharing agreement



9. Your Rights
Under UK GDPR, parents and staff have the right to:
Request access to their data (“Subject Access Request”)
Correct inaccurate data
Request erasure of personal data (where legally allowed)
Object to processing
Withdraw consent at any time (for media, marketing, etc.)

Requests can be made in writing to: info@engineeringminds.org.uk


10. Data Breach Procedure
In the event of a data breach:
We will investigate immediately
Inform affected individuals (where risk is high)
Notify the Information Commissioner’s Office (ICO) within 72 hours, if required



11. Policy Review
This policy is reviewed annually or when changes in data protection legislation occur.

 Last reviewed: July 2025
 Next review due: July 2026