Privacy Notice – EA’s Corporate Complaints Service

EA’s Corporate Complaints Service has responsibility for the central management of complaints, comments and concerns raised by members of the public as per EA's Complaints Handling Policy and Procedure.

This Privacy Notice explains how the Corporate Complaints Service (“we”, “our”, “the Service”) collects, uses, stores, and shares personal data when managing complaints, comments, and concerns submitted to the Education Authority (EA).

We are committed to protecting your privacy and handling your personal information lawfully, fairly, and transparently.

EA is the Data Controller for the personal data processed in relation to corporate complaints, comments and concerns.

If you have any questions about this notice or how we use your data, please contact the EA’s Data Protection Officer (DPO):
Email: dpo@eani.org.uk

Address: 40 Academy Street, Belfast, BT1 2NQ

Telephone: 028 9047 5011

The EA collects and uses your personal information to enable us to fulfil our duties as an education services provider.  In order for the EA’s Corporate Complaints Service to fully consider any matter raised with us, we will normally need to process your personal data.  When considering complaints or concerns, we must ensure that all appropriate actions are taken.  These actions may include:

• assessing the appropriate policy to manage your complaint or concern under
• undertaking preliminary enquiries or full investigations
• identifying systemic issues highlighted by cases
• dissemination of information to appropriate business areas within EA
• liaison with external bodies, including, for example, the Police Service of Northern Ireland (PSNI), NIPSO, NICCY.

Depending on the nature of your complaint / comment / concern, we may collect the following information:

• Your name and contact details (address, email, telephone number).
• Details of the complaint, comment or concern.
• Information about interactions you have had with individuals or services within the Authority.
• Supporting documents or evidence you choose to provide.  This may include special category data such as information about you or your child’s physical or mental health.
• Personal data relating to third parties involved in or affected by the complaint.

We encourage you not to provide more personal information than needed for us to handle your complaint.

We collect personal data:

• Directly from you when you contact us to submit a complaint, comment or concern.  This may be through telephone calls, emails, online forms and letters.
• From staff members involved in responding to or investigating your complaint or concern.
• From third parties, where necessary and lawful.

EA’s Corporate Governance Service is responsible for the management of concerns which fall to be considered under EA's Raising Concerns - Whistleblowing Policy. Whistleblowing is when a member of staff or the public raises concerns for the greater good about misconduct, safety violations, misuse of funds or unethical behaviour that they have seen or become aware of in relation to EA’s conduct, practice or staff.  Where EA’s Corporate Complaints Service receives a complaint which may meet the definition of a whistleblowing concern, we will share your personal information with the Corporate Governance Service in order that concerns can be managed appropriately and addressed accordingly.

In order for us to fully investigate a complaint, we may need to share your personal information within other services within EA where specific advice is required.  This may be the case, for example, where the complaint relates to matters relating to child protection or data protection and specialist advice is required.

We may have to share your personal information with third parties, including other Bodies such as:

• The Northern Ireland Public Services Ombudsman (NIPSO)

  NIPSO’s role includes investigating unresolved complaints about public bodies in Northern Ireland. Where you have exhausted EA’s complaints process and have complained to NIPSO about EA’s service, we will provide NIPSO with all necessary information to enable them to investigate fully.  We will also share personal information with NIPSO to assist them with investigations, in line with our statutory obligations.

• Department of Education, NI

  DE may request information as part of a formal review, audit, enquiry, complaint or investigation connected to its departmental responsibilities. We will share personal information in line with our statutory obligations.

• PSNI

  EA may share your personal data with the PSNI where it is deemed necessary to prevent or detect crime, or to assist PSNI with an active investigation.

• Legal representatives

  Your personal information may be shared with a legal representative where you have formally instructed a solicitor to act on your behalf, to pursue or defend legal proceedings, or to comply with a court order or a legal / statutory obligation.

Personal data is only shared where it is strictly necessary, proportionate and is limited to what is relevant for the purposes of the data sharing.

The personal information you provide to EA when submitting a complaint, comment or concern is provided on a voluntary basis.

Thereafter, we process your personal data for the following reasons:

Article 6 (1) (e) UK GDPR – public task

Processing is necessary for us to carry out our official functions and ensure that your complaint, comment or concern is handled under the correct EA policy or procedure and managed appropriately.

Article 6 (1) (c) UK GDPR – legal obligation

We may also process personal data to meet duties set out in legislation, regulatory frameworks, or statutory complaint procedures.

Article 6 (1) (f) UK GDPR – legitimate interests

By exception, and only where appropriate, we may rely on legitimate interests to investigate and resolve issues raised.  In such circumstances, a legitimate interest assessment will be completed in advance of the processing.

Special Category Data

If your complaint contains special category information such as data concerning health or the racial or ethnic origin of the complainant, we will rely on:

• Article 9(2)(g) – substantial public interest

We only collect such information where it is strictly necessary.

Some of the personal data we collect about you may be transferred to, and stored or accessed in, countries outside the United Kingdom. Where this occurs, we ensure that appropriate safeguards are in place to protect your information in accordance with UK data protection law.

We will always take steps to ensure that your information remains protected, secure, and processed in line with this privacy notice, regardless of where it is handled.

All data will be stored using the appropriate technical and organisational measures to protect your data and retained in line with the EA’s Interim Retention & Disposal schedule:

• Comments and Complaints information – 2 years
• Whistleblowing – 10 years from the date of conclusion of the investigation

• You have the right to obtain confirmation that your data is being processed, and request access to your personal data
• You are entitled to have personal data rectified if it is inaccurate or incomplete
• You have a right to have personal data erased in specific circumstances
• You have the right to request the EA to limit or restrict the processing of your personal data in specific circumstances
• You have the right to data portability in specific circumstances
• You have the right to object to the use of your data in specific circumstances

If any of these rights are applicable to you and you wish to exercise them, please submit your request to dpo@eani.org.uk or contact us using the details for the DPO provided above.

If you are unhappy with how any aspect of this privacy notice, or how your personal information is being processed, please contact us first at dpo@eani.org.uk. 

If you are still not happy, you have the right to complain to the Information Commissioner’s Office (ICO). Contact details of the ICO are available at  ICO website.