As you may be aware, new EU data protection laws, known as GDPR, came into force in May 2018 and as a result we have made some changes to our privacy notice for parents/carers and pupils.
Under data protection law, individuals have a right to be informed about how the school uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ to individuals where we are processing their personal data.
We, Streatley C of E Primary School, are the ‘data controller’ for the purposes of data protection law.
Our Data Protection Officer is Thomas Ng (see ‘Contact us’ below).
The personal data we hold
Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:
- Personal identifiers and contacts (such as name, date of birth, unique pupil number, contact details and address);
- Characteristics (such as ethnicity, language, Special Education Needs and free school meal eligibility);
- Safeguarding information (such as court orders and professional involvement);
- Medical condition and administration of medicines (such as doctors information, child health including physical and mental health, dental health, allergies, medication and dietary requirements);
- Attendance (such as sessions attended, number of absences, absence reasons and any previous schools attended);
- Assessment and attainment (such as Key Stage 1 SATs and phonics results, Key Stage 2 SATs and any other relevant results);
- Behavioural information (such as exclusions and any relevant alternative provision put in place);
- Photographs and videos.
Our legal basis for using this data
Streatley C of E Primary holds the right to collect and use personal data relating to pupils and their families, and we may also receive information regarding them from previous school, local authorities and the Department for Education.
We collect and use personal data in order to meet legal requirements and legitimate interests set out in the GDPR and UK law, including those in relation to the following:
- Article 6 and Article 9 of the GDPR
- Education Act 1996
- Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013
In accordance with the above, the personal data of pupils and their families is collected and used for the following reasons:
- Support pupil learning;
- Monitor and report on pupil progress;
- Provide appropriate pastoral care;
- Protect pupil welfare;
- Assess the quality of our services;
- Administer admissions waiting lists;
- Carry out research;
- Comply with the law regarding data sharing.
We only collect and use pupils’ personal data when the law allows us to. Most commonly, we process it where:
- We need to comply with a legal obligation;
- We need it to perform an official task in the public interest.
Less commonly, we may also process pupils’ personal data in situation where:
- We have obtained consent to use it in a certain way;
- We need to protect the individual’s vital interests (or someone else’s interests).
Where we have obtained consent to use pupils’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.
Some of the reasons listed above for collecting and using pupils’ personal data overlap, and there may be several grounds which justify our use of this data.
Collecting pupil information
We collect pupil information via the registration forms collected at the start of the school year or a secure file transfer from a previous school.
Pupil data is essential for the schools’ operational use. Whilst the majority of pupil information you provide to us is mandatory, some of it requested on a voluntary basis. In order to comply with the data protection legislation, we will inform you at the point of collection, whether you are required to provide certain pupil information to us or if you have a choice in this.
How we store this data
We keep personal information about pupils while they are attending our school. We may also keep it beyond their attendance at our school if this is necessary in order to comply with our legal obligations.
Who we share pupil information with:
We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so.
Where it is legally required or necessary (and it complies with data protection law) we may share personal information about pupils with:
- Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions;
- The Department for Education;
- The pupil’s family and representatives;
- Educators and examining bodies;
- Secondary schools or in year transfer to other primary schools (EU only);
- Our regulator, e.g. Ofsted, SIAMS;
- Suppliers and service providers – to enable them to provide the service we have contracted them for e.g. , Eduspot and Caterlink (School Meals Provider) ;
- Central and local government;
- Our auditors;
- Health authorities;
- Health and social welfare organisations;
- Professional advisers and consultants;
- Police forces, courts, tribunals.
Department for Education
The Department for Education (DfE) collects personal data from educational settings and local authorities via various statutory data collections. We are required to share information about our pupils with the Department for Education (DfE) either directly or via our local authority for the purpose of those data collections, under Section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.
Some of this information is then stored in the National Pupil Database (NPD), which is owned and managed by the DfE and provides evidence on school performance to inform research.
The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including schools, local authorities and exam boards.
The Department for Education may share information from the NPD with other organisations which promote children’s education or wellbeing in England. Such organisations must agree to strict terms and conditions about how they will use the data.
For more information, see the Department’s webpage on how it collects and shares research data.
You can also contact the Department for Education with any further questions about the NPD.
Requesting access to your personal data
Under data protection legislation, parents and pupils have the right to request access to information about them that we hold. To make a request for your personal information, or be given access to your child’s educational record, please contact Claire Slade via the school contact phone number or email address.
You also have the right to:
- Ask us for access to information about you that we hold;
- Have your personal data rectified, if it is inaccurate or incomplete;
- Request the deletion or removal of personal data where there is no compelling reason for its continued processing;
- Restrict our processing of your personal data (i.e. permitting its storage but no further processing);
- Object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics;
- Not be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
You can make a complaint to the Information Commissioner’s Office:
- Report a concern online at https://ico.org.uk/concerns/
- Call 0303 123 1113
- Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact the school’s Data Protection Officer:
Data Protection Officer:
Thomas Ng, BEd(Hons) MA MBA NPQH FBCS CITP - firstname.lastname@example.org
School Improvement Adviser:
West Berkshire Council Education Service, West Street House, West Street, Newbury RG14 1BD
Tel: 01635 503430