Purpose
This GDPR Requests Procedure establishes the framework through which Welfare Academy manages and responds to requests relating to personal data rights under UK GDPR and the Data Protection Act 2018.
Scope
This procedure applies to students, staff, applicants, apprentices, contractors, website users, and other individuals whose personal data is processed by Welfare Academy.
Legislative Framework
This procedure aligns with:
• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Information Commissioner’s Office (ICO) guidance
• Office for Students (OfS) expectations where applicable
GDPR Rights Covered
Individuals may exercise rights including:
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to object
• Right to data portability
• Rights relating to automated decision-making
Submission of Requests
GDPR requests may be submitted through:
Email: support@welfarehs.co.uk
Telephone: 020 3983 0282
Requests should provide sufficient information to identify the individual and the nature of the request.
Identity Verification
Welfare Academy may request identity verification before disclosing, amending, deleting, or restricting personal data in order to protect confidentiality and prevent unauthorised disclosure.
Subject Access Requests
Individuals may request access to personal data held by Welfare Academy. Subject Access Requests (SARs) shall be managed in accordance with UK GDPR statutory requirements.
Rectification Requests
Individuals may request correction of inaccurate or incomplete personal data. Welfare Academy shall review evidence and update records where appropriate.
Erasure Requests
Individuals may request deletion of personal data where lawful conditions apply. Requests may be refused where legal, safeguarding, regulatory, contractual, or public interest obligations require retention.
Restriction of Processing
Individuals may request restriction of processing under circumstances permitted by UK GDPR.
Objection Requests
Individuals may object to certain types of processing, including processing based on legitimate interests or direct marketing activities where applicable.
Data Portability
Where applicable, individuals may request transfer of personal data in a structured, commonly used, and machine-readable format.
Automated Decision-Making
Individuals may request review of decisions based solely on automated processing where applicable under UK GDPR.
Response Timeframes
Welfare Academy shall aim to respond to GDPR requests within statutory UK GDPR timeframes. Complex requests may require reasonable extensions where legally permitted.
Refusal of Requests
Requests may be refused where:
• Legal exemptions apply
• Requests are manifestly unfounded or excessive
• Safeguarding obligations require restricted disclosure
• Regulatory obligations require retention
Reasons for refusal shall be communicated appropriately.
Safeguarding and Confidentiality
Safeguarding obligations may override certain GDPR rights where disclosure or restriction could create risk to life, welfare, or safety. Confidentiality obligations shall be maintained appropriately.
Data Security
All GDPR requests and associated information shall be managed securely using appropriate technical and organisational safeguards.
Staff Responsibilities
Relevant staff members shall:
• Escalate GDPR requests appropriately
• Maintain confidentiality
• Follow institutional procedures
• Protect personal data
• Cooperate with investigations and reviews
Training and Awareness
Relevant staff may receive training relating to UK GDPR compliance, confidentiality obligations, cybersecurity awareness, safeguarding-related data sharing, and data protection procedures.
- Complaints and ICO Rights
Individuals dissatisfied with data handling practices may raise concerns through institutional procedures or contact the Information Commissioner’s Office (ICO).
Record Keeping
Welfare Academy shall maintain appropriate records relating to GDPR requests, decisions, correspondence, disclosures, and compliance activities.
Equality and Accessibility
This procedure operates in accordance with the Equality Act 2010 and accessibility obligations. Welfare Academy shall seek to ensure that GDPR rights can be exercised in an inclusive and accessible manner.
Governance and Review
This GDPR Requests Procedure shall be reviewed annually and aligned with UK GDPR, Data Protection Act 2018 requirements, ICO guidance, safeguarding obligations, and OfS expectations where applicable.
Contact Information
Welfare Academy
Email: support@welfarehs.co.uk
Telephone: 020 3983 0282
Policy Approval
This GDPR Requests Procedure is approved and maintained by Welfare Academy management and remains subject to periodic review and legislative updates.
