ECT Privacy Policy

Westminster City Council Early Career Teacher Induction Privacy Notice for Early Career Teachers and Newly Qualified Teachers

This privacy notice is both for Early Career Teachers (ECTs), and Newly Qualified Teachers (NQTs) who have part completed induction and are continuing induction under the pre-September 2021 induction arrangements with Westminster City Council as the Appropriate Body for statutory induction. Where ECTs are referred to in this notice, the information will apply equally to NQTs.

Protecting and respecting your privacy This privacy notice sets out when and how we use your personal information that you or others provide to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of that information. This notice describes what information we collect about you, how we use it, and the rights you have in relation to that collection and usage.

Your privacy is of the utmost importance to us. Please read this privacy notice carefully to understand our views and practices regarding your personal data and how we will treat it.

Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.

Who we are Westminster City Council (WCC), City Hall, Victoria, SW1E 6QP For the purposes of the Data Protection Act 2018 the General Data Protection Regulations GDPR and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation“), WCC will be the ‘data controller’.

The Council’s Data Protection Officer can be contacted at: or, by phone at: Mobile 07890380046 or Tel 0207 641 8578

Your information is collected for the purpose of statutory induction as required to fulfil the council’s duties acting as an Appropriate Body under legislation, Sections 135A, 135B and 141C(1)(b), of the Education Act 2002 and associated Education (Induction Arrangements for School Teachers) (England) Regulations 2012.

Information as described below will be shared with and by the headteacher/principal and induction tutor of the school/setting in which you undertake the statutory induction process.

This information will be shared with the council and by the council with staff of the school who have a designated responsibility for statutory Early Career Teacher induction. This information is checked with the Teacher Regulation Agency (TRA) to verify your qualified teacher status, your eligibility to serve induction and your relevant personal and professional details.

This information, together with post and contract details, induction progress reports and induction records will be shared between the council and the school so that respective statutory duties can be fulfilled for managing the induction process for Early Career Teachers in the prescribed setting.
By “Personal Data” we refer to information collected or held by WCC that identifies and relates to you as an individual.

Information we collect To enable us to run our services adequately we will need to collect Personal Data from you in the following circumstances:

We collect the following personal information about you when you engage with our services as an ECT including:

• your name and date of birth; • postal address; • supplementary information you provide about yourself when engaging with us; • Teacher Reference Number (TRN); • professional teaching qualifications; • professional and career information; • ECT assessment information and information relating to the support and monitoring you receive during your induction period • email address; and • telephone numbers (including mobile).

The information will be retained for six years as statutorily required by the Department for Education and will be processed in adherence to your legal rights, including your right to object to such processing. Beyond this time, we will keep the following information for a further four years, in total a maximum of ten years, so that in the event of data loss or any discrepancy of officially held records, an ECT’s induction history can be confirmed. The information kept will include:

• your name and date of birth • TRN number • school or setting name where induction was served • induction start date • induction finish date • induction outcome, whether Pass, Fail, Extended or Incomplete • number of terms served • name of induction tutor and headteacher

Your information will not be shared with any organisation other than the employing school/setting in which you work, or the appropriate body (the council) with which you are registered (or are subsequently registered with) without your permission.

If you are dissatisfied with the processing of your information, you can raise your concern with the council’s data protection officer. You have a right to lodge a complaint with the Information Commissioner’s Office

Headteachers/principals, induction tutors, appropriate bodies and the Teacher Regulation Agency should ensure that arrangements are in place to facilitate the effective protection and secure transfer of data. To this end, the secure online data management system, ECT Manager is used under contract with Evolution Internet Marketing LLP by the council in its role as the Appropriate Body.

Induction data, reports and the assessments generated from the induction process should always be treated with confidentiality and should not be shared with anyone not directly involved in the induction process. It should be made clear to anyone viewing such documents that they are confidential and ECTs must be made aware of who has been granted access to their assessments.

Your school’s governing body can request general reports on the progress of ECTs but are not automatically entitled to have access to an individual’s assessment forms.

The exception to this would be when an ECT has raised concerns about a particular issue/assessment via the institution’s grievance procedures, which would in many cases require the governing body to investigate the situation.

If at any stage the governing body has questions or concerns about the quality of the institution’s induction arrangements and the roles and responsibilities of staff involved in the process they can seek guidance from the Appropriate Body.

What do we do with the information we collect? We will use your personal information for several purposes as listed below. Please note the list is not exhaustive:

• internal record keeping; • to carry out any obligations owed to you through the use of our Website and in respect of any contracts entered into between you and us; • to provide our services to ECTs and the schools they work with; • to give you information that you request from us and to improve our services; • to notify you about changes to our services; • to allow us to operate the Website efficiently; • to ensure that the content from our Website is presented in the most effective manner for you and your computer; • any relevant troubleshooting, testing or statistical analysis as appropriate; and • to keep the Website secure.

Data retention We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As previously explained, certain personal and professional information relevant to the ECT induction process will be kept for a maximum of 10 years to aid in the event of data loss or discrepencies in professional records which could disadvantage a teacher who has served or part served induction with the council as the appropriate body.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Legal basis of processing We collect and process your information as we have a legal obligation to do so. This is usually in order to provide you with the contractual services you or your school have requested from the council. If you have provided us with adequate consent, we may process your information for other purposes, for example organising and allowing your access to training or other development opportunities to which you and your school have agreed.

Protecting your information We are committed to ensuring that your information is kept secure and we have procedures in place to prevent any unauthorised access or disclosures and to safeguard the information that we collect online.

All the Personal Data collected by us and stored electronically is held on a secure server in the UK only (ECT Manager and council systems). Where required, this information is encrypted for additional security.

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees, contractors or unpaid professional school colleagues who require it to fulfil their job or task responsibilities, for example, ECT induction assessment review and moderation.

Data protection officer To ensure we continue to monitor our obligations under Data Protection Legislation, WCC has a data protection officer (DPO). If you wish to contact the DPO regarding any specific elements of Westminster City Council’s data handling, please send your enquiries to

If you have any queries about how your personal data is processed by the council, in the first instance please address these queries to

Sharing your information with others Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so as set out under this privacy notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies.

Access to your Personal Data You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting

The information you request must relate to you, or for another person that you have authority to act on their behalf. WCC will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to verify your identity WCC reserves the right to refuse your request.

The rights you have in relation to the Personal Data we hold regarding you are: • the right to rectify any inaccuracies in the information we hold; • the right to erasure of information in specific circumstances; • the right to request transfer of your information to another controller; and • the right to object to processing in certain circumstances.

Changes to this Privacy Notice We may change this privacy notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information. Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below.

We will endeavour to notify all of our current service users of any updates to this notice via email and we will post the relevant announcement on the ECT Manager website homepage.

We recommend that you print a copy of this page for your reference.

Contacting us Please contact us at: if you have any questions, comments or requests regarding this Privacy Notice.

Last updated 25/05/2022