Data Protection and GDPR

Last Update March 2026

Smart Steps Ltd. trading as Smart Steps is committed to protecting the privacy and personal data of children, parents/guardians, staff, and others connected with the service.

We handle personal data lawfully, fairly, transparently, and securely in line with data protection law. This page explains what personal data we collect, why we collect it, how we use it, how we store it, and the rights of individuals in relation to that data.

Policy Contents

Policy Statement

Purpose

Scope

What Personal Data We Collect

How We Collect Personal Data

Why We Use Personal Data

Sharing Personal Data

How We Store and Protect Data

Retention of Records

Photographs and Videos

Individual Rights

Data Breaches

Contact Details

Related Policies and Documents

Policy Statement

Smart Steps Ltd. trading as Smart Steps is committed to protecting the privacy and personal data of all children, parents/guardians, staff, and others connected with the service.

We recognise the importance of handling personal data lawfully, fairly, transparently, and securely. Personal data is collected, used, stored, retained, and shared only where necessary and in line with data protection law.

Purpose

The purpose of this policy is to explain how Smart Steps manages personal data and to ensure that personal information is handled responsibly, securely, and in accordance with legal requirements.

This policy also helps to protect the rights and privacy of children, parents/guardians, staff, and others connected with the service.

Scope

This policy applies to all personal data processed by Smart Steps in any format, including paper records, digital records, emails, photographs, videos, and information stored on approved systems.

It applies to personal data relating to children attending the service, parents/guardians, emergency and authorised contacts, staff, students, volunteers, contractors, and others connected with the operation of the service where relevant.

What Personal Data We Collect

Depending on the circumstances, Smart Steps may collect and process:

  • parent/guardian contact details

  • child registration details

  • emergency and authorised collection information

  • medical, dietary, allergy, and medication information

  • attendance, booking, and fee records

  • accident, incident, injury, and medication records

  • information required for funded childcare schemes, where applicable

  • relevant safeguarding or legal information where necessary

  • photographs or videos, where appropriate consent has been provided

How We Collect Personal Data

We collect personal data in a number of ways, including through enrolment and registration forms, direct communication with parents/guardians, attendance and operational records, payment records, and approved management systems used by the service.

We may also receive or create records where necessary to support the safe and effective operation of the service and to meet legal, regulatory, safeguarding, insurance, or administrative requirements.

Why We Use Personal Data

Smart Steps uses personal data only where it is relevant and necessary for the safe and effective operation of the service.

This may include:

  • administering enrolments and registrations

  • providing appropriate care, supervision, and support

  • maintaining contact with parents/guardians and authorised persons

  • responding to health needs, accidents, incidents, or emergencies

  • keeping required attendance, welfare, safeguarding, and operational records

  • managing fees, payments, and general administration

  • meeting legal, regulatory, safeguarding, insurance, and scheme requirements

  • protecting the health, safety, and wellbeing of children and staff

Sharing Personal Data

Smart Steps treats personal data confidentially and does not share it unnecessarily.

Information may be shared where appropriate and necessary, including with authorised staff members, statutory or regulatory bodies, scheme administrators, insurers, legal advisers, or other professional advisers where required.

Only the minimum necessary information will be shared.

How We Store and Protect Data

We take appropriate steps to keep personal data secure and protected from unauthorised access, loss, misuse, disclosure, alteration, or destruction.

This includes secure storage of paper records, password-protected devices and systems, restricted access to records, use of approved digital systems, and secure handling and disposal of personal data.

Retention of Records

Smart Steps keeps personal data only for as long as necessary and in line with legal, regulatory, insurance, safeguarding, and operational requirements.

Some records are kept for a limited period after a child leaves the service, while certain records, such as accident, injury, safeguarding, insurance-related, or legal records, may need to be retained for longer where required.

When records are no longer needed, they are securely deleted, destroyed, or shredded.

Photographs and Videos

Photographs and videos of children are only taken, used, stored, or shared in line with Smart Steps procedures and consent arrangements.

Where consent is required, it is obtained separately from parents/guardians and may be withdrawn for future use at any time.

Individual Rights

Individuals have rights in relation to personal data, including the right to request access to personal data, request correction of inaccurate or incomplete data, request erasure in certain circumstances, request restriction of processing in certain circumstances, object to processing in certain circumstances, request data portability where applicable, and withdraw consent where processing is based on consent.

Individuals also have the right to raise a concern or complaint with the appropriate authority.

Data Breaches

Smart Steps takes any actual or suspected personal data breach seriously.

Where a breach is identified, appropriate action will be taken promptly. This may include containing the breach, assessing the impact, keeping a record of the incident, notifying relevant parties where required, and reporting the breach to the appropriate authority where legally necessary.

Contact Details

If you have any questions about how Smart Steps handles personal data, or if you wish to make a request in relation to your data, please contact:

Smart Steps Ltd.
Smart Steps HQ
2A Leck Road Business Park

Letterkenny

Co.Donegal
F92 P28F


Email: smartstepsafterschool@gmail.com
Phone: 087 776 9476

If you are not satisfied with how your personal data has been handled, you may contact the Data Protection Commission.

Policy Information