Privacy Notice
This privacy notice tells you what to expect when we use personal information about you. We want you to be fully informed about how we use your data and your rights.
Introduction
This privacy notice tells you what to expect when we use personal information about you. It applies to all individuals who interact with us, including students, parents/carers, staff, volunteers, job applicants, donors/supporters, visitors and contractors.
We want you to be fully informed about how and why we use your personal information, the legal reasons that allow us to do so, and the rights you have under UK data‑protection law.
Legal framework
We use personal data in accordance with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018 (DPA 2018)
- Privacy and Electronic Communications Regulations (PECR)
- Data (Use and Access) Act 2025 (DUAA) – which introduces new obligations for transparency, recognised legitimate interests, automated decision-making safeguards, data subject rights and greater protection for under 18s..
Throughout this notice, “use” means collecting, storing, analysing, sharing or otherwise processing personal data.
What is personal data?
Personal data is any information about a living person that can identify them directly or indirectly – such as name, contact details, date of birth, health information, ID numbers, online identifiers or financial details.
Who is National Star?
National Star is the working name of the registered charity National Star Foundation, charity number 220239.
Our address is:
Ullenwood Manor,
Ullenwood,
Cheltenham,
Gloucestershire,
GL53 9QU.
Telephone: 01242 527631
Email: Contact Us
We are registered with the Information Commissioner’s Office (ICO) under reference number Z6504485.
If you have any questions about our use of your personal information, or wish to exercise your GDPR rights, please contact our Data Protection Officer: [email protected]
Your rights
You have the following rights over your personal data:
- Access – request a copy of the personal information we hold about you.
- Correction – ask us to fix inaccurate or incomplete data.
- Erasure – ask us to delete data where legally permitted.
- Restriction – ask us to limit how we use your data.
- Objection – object to certain types of processing.
- Data Portability – receive your data in a machine‑readable format or ask us to send it to another provider.
- Complaints – raise concerns with us or the ICO.
Sometimes we need certain information to provide a service. If you choose to use one of your rights so that we can no longer use that information, we might not be able to offer that service anymore. If that happens, we’ll explain why.
We will verify your identity before responding to a rights request.
If you wish to exercise your right to make a complaint about how we have handled your personal data please see our Complaints Procedure.
How to contact us about your data
Email: [email protected]
Post: Data Protection Officer, National Star, Ullenwood Manor, Ullenwood, Cheltenham, Gloucestershire, GL53 9QU
How to contact the regulator (ICO)
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: https://ico.org.uk/about-the-ico/
Telephone: 0303 123 1113
How long we keep your data
We keep your personal information only for as long as necessary for its purpose.
Some records — such as care, safeguarding, therapy, education or regulatory records — must be kept for minimum periods under law or sector rules.
After retention periods end, data is securely deleted or anonymised.
Sharing data outside the UK
If we need to transfer your personal data outside the UK, we will only do so where appropriate legal safeguards are in place. These may include UK adequacy regulations or approved transfer mechanisms such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses. These safeguards ensure your data continues to be protected to UK standards.
How we protect your data
We use a combination of technical and organisational measures, including:
- Secure login system and password-protected devices
- Strict access controls
- Mandatory staff data-protection training
- Enterprise-grade cyber-security
- Certification through Cyber Essentials and NHS DSPT
No online transmission is entirely secure; data sent electronically is at your own risk, but we take all reasonable measures to protect it.
Updates to this notice
We may update this notice to reflect legal changes or organisational developments.
Latest update: February 2026
In addition to our general Privacy Notice we may further process personal data for the following specified groups.
Why we use your data
When using our website we use your information to operate and improve it, ensure security, provide services you request, and understand how our site is used.
DUAA recognises network and information‑system security as a recognised legitimate interest, meaning we can rely on it without balancing tests when necessary.
What we collect
- IP address, browser/device info, pages visited
- Cookies and analytics (see Cookie Policy)
- Information you enter when using forms (e.g. student admissions, newsletters, bookings, donations, job alerts)
Lawful bases
- Contract (when delivering services you request)
- Legitimate interests (security, functionality, analytics)
- Consent (marketing emails, optional cookies)
Who we share with
Internal teams and third‑party service providers who support website hosting, security, analytics, booking or payment systems — always under strict conditions.
Retention
We keep subscription information until you unsubscribe.
Social media
National Star operates on a number of social media platforms. We are not responsible for how platforms process your data; please check the platform’s own privacy settings and policies.
Why we use your data
To support your education, care, wellbeing, and safety, and to deliver our statutory functions.
Categories we collect include:
- Contact information
- Attendance/personal administration
- Educational records
- Health/care information
- Funding/admin records
- Digital accounts and IT monitoring
- Images, CCTV, biometrics (only with consent)
- Equality and safeguarding information
- Clinical supervision: Some therapy sessions (for example Music Therapy) may occasionally be audio or video‑recorded for clinical supervision. Recordings are kept securely, accessed only by clinical staff, and deleted once supervision is complete.
Lawful bases
- Legal Obligation (care records, safeguarding)
- Public Task (education and training duties)
- Legitimate Interests (IT security, service management)
- Recognised Legitimate Interests (DUAA) – safeguarding, crime prevention, emergency response
- Consent – biometrics, publicity photos
- Special Category Conditions – health/social care; substantial public interest
Children’s Higher Protection Matters (DUAA)
Where services may be accessed by under-18s, we apply:
- Age-appropriate information
- High-privacy defaults
- Limits on profiling
- No “nudging” to share unnecessary data
- Data protection by design/default
Sharing
Internal teams (education/care/IT/funding teams). NHS; ESFA, Local Authorities, safeguarding agencies, regulators, auditors, approved third‑party processors.
Why we use your data
To contact, employ, support, manage and develop you, pay you, meet legal and regulatory duties, maintain safety, ensure legitimate access, provide references, allow students and residents to communicate with you, promote equality, and run the organisation effectively.
Categories of information collected include:
- Identity, bank details, employment, benefits and pension information.
- Working schedule, attendance and leave information.
- Personal contact details/marital status/next of kin/dependants/emergency contacts.
- Occupational‑health data
- Performance, development, conduct, any criminal record and safeguarding information
- Qualifications/skills/training/registration/driving qualifications/behaviour
- Telephone, IT and network logs
- CCTV, telematics, dashcam footage, vehicle location, sign in information
- Equality monitoring
- Teams/Emails/online documents to support data subject rights requests
- Trade‑union membership (consent)
- Photos/video recordings taken as part of your role supporting service users.
- Recordings of online meetings where you are identified.
- Photographs or video recordings for our marketing and publicity purposes, if you have given us your consent.
- Clinical supervision (clinical roles only): Some practice‑based sessions may be recorded for clinical supervision and professional standards. These recordings are used only for supervision, stored securely, and retained only as necessary.
Lawful bases
- Contract (employment)
- Public task (for example providing information to exam boards.
- Legal Obligation (tax, safeguarding, H&S)
- Legitimate Interests (IT/security, workforce management)
- Recognised legitimate interests (DUAA): safeguarding, crime prevention, emergencies, admin sharing, IT security
- Consent (publicity photos, union deductions)
- Criminal offence data: DBS checks under Schedule 1
- Special Category personal data: We use your health data to fulfil our obligations to health and safety and occupational health requirements. This is on the basis that it is necessary (i) for the purpose of carrying out our obligations in the field of employment, and (ii) for the assessment of the working capacity of employees. • We use racial or ethnic origin, religious or philosophical beliefs, and data concerning sexual orientation to monitor equality of opportunity. This is on the basis that it is necessary for reasons of substantial public interest. • We use your trade union membership to pay your subscriptions by payroll deduction. This is on the basis of your explicit consent.
Automated decision-making
We do not use solely automated decisions with significant effects without safeguards (human involvement, challenge rights).
Sharing
Internal
HR, safeguarding, managers, IT, shift fulfilment, payroll, benefit providers, students/residents (e.g. adding name/photo to AAC devices)
External
Other employers (e.g. references), project partners, DBS, approved third party IT providers, approved third party services (e.g. driving licence checking), Local Authorities, NHS organisations/ UK Health Security Agency, regulators (e.g. Care Quality Commission, Ofsted and Estyn), HMRC, HSE, auditors, insurers, law enforcement where required, training providers and qualification awarding bodies, providers of goods and services such as travel/insurance
Why we use your data
To run a fair, safe and lawful recruitment process.
Includes:
- Communication during recruitment
- Shortlisting, interviews and decision‑making, monitoring recruitment processes
- Checking right‑to‑work, criminal record checks, qualifications, registrations, DBS and to issue contract
- Equality monitoring
- Occupational‑health checks where needed
- Security and site safety (visitor sign‑in, CCTV)
- Handling complaints or legal claims
DUAA‑recognised legitimate interests may apply for: safeguarding, crime prevention, emergency response, internal admin sharing, IT/system security.
Personal data we collect
Identity and contact details, employment history, pensions, benefits, qualifications, skills, conduct, references, training, registrations, health/adjustment needs, National Insurance number (if offered post), bank details, DBS info (where required), equality data (optional), CCTV if you visit site.
Lawful bases
- Legal Obligation (right‑to‑work, DBS)
- Legitimate Interests (fair recruitment, admin, IT security)
- Recognised LI (DUAA) where applicable
- Consent (mailing lists, certain optional uses)
- Special category (employment, health, substantial public interest)
Sharing
Internal
HR, recruiting managers.
External
DBS, referees, approved third party reference checking service, training providers/awarding bodies, Local Authorities (e.g. safeguarding/welfare), regulators (e.g. Care Quality Commission, Ofsted and Estyn), occupational‑health providers, safeguarding bodies, auditors, insurers, legal professionals/law enforcement where required.
Retention
Unsuccessful applicants: 13 months
Successful applicants: data added to staff record.
Why we use your data
To manage donations, fundraising, events, volunteering, supporter communications and charity operations.
Includes:
- Sending newsletters, updates, fundraising materials
- Processing donations and Gift Aid
- Managing lotteries, raffles and administer participation at events
- Stewardship and supporter engagement
- Using stories/photos where you’ve agreed
- Profiling to send relevant content
- CCTV and visitor sign‑in safety measures
- DUAA‑recognised legitimate interests: charity marketing, admin sharing, IT security, safeguarding, crime prevention
What we collect
Contact details, network of contacts (if shared), donation history, payment information, interests/occupation (if shared), event participation info, health data for event safety (consent), publicly available supporter info, visitor/CCTV data, reasons for supporting us.
Lawful bases
- Legitimate Interests (postal marketing, stewardship, profiling, security)
- Recognised LI (DUAA) (direct marketing, crime prevention, admin sharing)
- Legal Obligation (Gift Aid, financial compliance)
- Consent (email/SMS marketing, health/event data, stories/photos)
- Special category — explicit consent or substantial public interest where applicable
Sharing
Internal
Fundraising, Finance, Communications, Events teams;
External
Mailing houses; event partners; payment processors; data‑cleansing providers; regulators (e.g. Fundraising Regulator and Charity Commission); HMRC; auditors.
guidance.submit-learner-data.service.gov.uk/24-25/ilr/ilrprivacynotice
To comply with data protection legislation, schools, colleges, local authorities, and training sector organisations are responsible for issuing a copy of this privacy notice
to learners and/or parents/guardians. This notice summarises the information held on record about them, why it is held and the third parties with whom the data may be shared.
Last reviewed on 16/03/2026
