This policy is intended to provide information about how we, the Denmark Road High School will use (or "process") personal data about our pupils.
This information is provided because the General Data Protection Regulation (GDPR) gives individuals rights to understand how their data is used. Parents, pupils and others are all encouraged to read this Privacy Notice and understand the school’s obligations to its community.
The categories of pupil information that we process include:
· personal identifiers and contacts (such as name, unique pupil number, contact details and address)
· characteristics (such as ethnicity, language, and free school meal eligibility)
· safeguarding information (such as court orders and professional involvement)
· special educational needs (including the needs and ranking)
· medical and administration (such as doctors information, child 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 courses enrolled for and any relevant results)
· behavioural information (such as uniform, homework or lack of equipment incidents)
· trips and visits (such as permission slips, attendance registers)
· images of pupils (such as engaging in school activities/trips, images captured by the school's CCTV system)
Why we collect and use pupil information
We collect and use pupil information, for the following purposes:
a) to support pupil learning
b) to monitor and report on pupil attainment progress
c) to provide appropriate pastoral care
d) to assess the quality of our services
e) to keep children safe (food allergies, or emergency contact details)
f) to meet the statutory duties placed upon us for DfE data collections
Under the General Data Protection Regulation (GDPR), Article 6, the lawful bases we rely on for processing pupil information are:
for the purposes of supporting pupil learning in accordance with the legal basis of A6(1)(f) the “legitimate interests” condition,
for the purposes of monitoring and reporting on pupil attainment progress in accordance with the legal basis of A6(1)(f) the “legitimate interests” condition,
for the purposes of providing appropriate pastoral care in accordance with the legal basis of A6(1)(f) the “legitimate interests” condition,
for the purposes of assessing the quality of our services in accordance with the legal basis of A6(1)(f) the “legitimate interests” condition,
for the purposes of keeping children safe in accordance with the legal basis of A6(1)(e): The processing is necessary for administering justice or for exercising statutory/governmental or other public functions,
for the purposes to meet the statutory duties placed upon us for DfE data collections in accordance with the legal basis of A6(1)(e): The processing is necessary for administering justice or for exercising statutory/governmental or other public functions.
In addition, the School will on occasion need to process special category personal data (concerning health, ethnicity, religion or biometrics) in accordance with rights or duties imposed on it by law, including as regards safeguarding, or from time to time by explicit consent (Article 9 2a Explicit Consent ) where required. These reasons will include:
• To safeguard pupils' welfare and provide appropriate pastoral (and where necessary, medical) care, and to take appropriate action in the event of an emergency, incident or accident, including by disclosing details of an individual's medical condition or other relevant information where it is in the individual's interests to do so: e.g. for medical advice, for social protection, safeguarding, and cooperation with police or social services, for insurance purposes or to caterers or organisers of school trips who need to be made aware of dietary or medical needs;
• To provide educational services in the context of any special educational needs of a pupil;
• To provide spiritual education in the context of any religious beliefs;
• For legal and regulatory purposes (e.g. child protection, diversity monitoring and health and safety) and to comply with its legal obligations and duties of care.
How we collect pupil information
We collect pupil information via data collection forms at the start of the school year or from Common Transfer File (CTF) 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 pupil data
The School will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep pupil files is until their 25th birthday. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Office Manager at the school. However, please bear in mind that the School will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, e.g.; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
Who we share pupil information with
Occasionally the school will share pupil information with:
· schools that the pupils attend after leaving us
· our local authority
· youth support services (pupils aged 13+)
· the Department for Education (DfE)
Youth support services
Pupils aged 13+
Once our pupils reach the age of 13, we also pass pupil information to our local authority provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.
This enables them to provide services as follows:
· youth support services
· careers advisers
The information shared is limited to the child’s name, address and date of birth. However where a parent or guardian provides their consent, other information relevant to the provision of youth support services will be shared. This right is transferred to the child / pupil once they reach the age 16.
Pupils aged 16+
We will also share certain information about pupils aged 16+ with our local authority provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.
This enables them to provide services as follows:
· post-16 education and training providers
· youth support services
· careers advisers
For more information about services for young people, please visit www.gloucestershire.gov.uk/education-and-learning/
Department for Education
The Department for Education (DfE) collects personal data from schools 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:
Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.
All data is transferred securely and held by DfE under a combination of software and hardware controls, which meet the current government security policy framework.
For more information, please see ‘How Government uses your data’ section of this Privacy Notice.
Why we share pupil information
For the most part, personal data collected by the School will remain within the School, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of pastoral and safeguarding files.
However, a certain amount of any SEN pupil’s relevant information will need to be provided to staff more widely in the context of providing the necessary care and education that the pupil requires.
We are under duties imposed by law and statutory guidance (including Keeping Children Safe in Education) to record or report incidents and concerns that arise or are reported to it, in some cases regardless of whether they are proven, if they meet a certain threshold of seriousness in their nature or regularity. This is likely to include file notes on safeguarding files, and in some cases referrals to relevant authorities such as the police. For further information about this, please view the School’s Safeguarding Policy.
Finally, in accordance with Data Protection Law, some of the School’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the School’s specific directions.
Data accuracy and security
The School will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the school of any significant changes to important information, such as contact details, held about them.
The School will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff and governors will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
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, contact the Office Manager at the school.
You also have the right to:
· object to processing of personal data that is likely to cause, or is causing, damage or distress
· prevent processing for the purpose of direct marketing
· object to decisions being taken by automated means
· in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
· a right to seek redress, either through the ICO, or through the courts
If you have a concern or complaint about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/
The School will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
If you would like to discuss anything in this privacy notice, please contact: The Assistant Headteacher Progress & Achievement at the school.
How Government uses your data
The pupil data that we lawfully share with the DfE through data collections:
· underpins school funding, which is calculated based upon the numbers of children and their characteristics in each school.
· informs ‘short term’ education policy monitoring and school accountability and intervention (for example, school GCSE results or Pupil Progress measures).
· supports ‘longer term’ research and monitoring of educational policy (for example how certain subject choices go on to affect education or earnings beyond school)
Data collection requirements
To find out more about the data collection requirements placed on us by the Department for Education (for example; via the school census) go to https://www.gov.uk/education/data-collection-and-censuses-for-schools
The National Pupil Database (NPD)
Much of the data about pupils in England goes on to be held in the National Pupil Database (NPD).
The NPD is owned and managed by the Department for Education and contains information about pupils in schools in England. It provides invaluable evidence on educational performance to inform independent research, as well as studies commissioned by the Department.
It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including schools, local authorities and awarding bodies.
To find out more about the NPD, go to https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information
Sharing by the Department
The law allows the Department to share pupils’ personal data with certain third parties, including:
· local authorities
· organisations connected with promoting the education or wellbeing of children in England
· other government departments and agencies
· organisations fighting or identifying crime
For more information about the Department’s NPD data sharing process, please visit:
Organisations fighting or identifying crime may use their legal powers to contact DfE to request access to individual level information relevant to detecting that crime. Whilst numbers fluctuate slightly over time, DfE typically supplies data on around 600 pupils per year to the Home Office and roughly 1 per year to the Police.
For information about which organisations the Department has provided pupil information, (and for which project) or to access a monthly breakdown of data share volumes with Home Office and the Police please visit the following website: https://www.gov.uk/government/publications/dfe-external-data-shares
To contact DfE: https://www.gov.uk/contact-dfe
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