DRAFT PRIVACY NOTICE RELATING TO PUPIL INFORMATION
What is the purpose of this Notice?
This is the Pupil Privacy Notice of Romero Catholic Academy Trust which is intended to provide you with information about how and why we process pupil information. It is also intended to provide you with other information which is required under the UK General Data Protection Regulation (the retained EU law version of the General Data Protection Regulation (EU) 2016/679) (GDPR) and the Data Protection Act 2018 (DPA). The GDPR and DPA contain the key laws relating to data protection.
It is important to us, and a legal requirement, that we are transparent about how we process pupil information. As a MAT that processes pupil information, we are known as a “data controller”. This means that we collect and use personal information for specified purposes which this Privacy Notice has been designed to tell you about.
The Data Protection Officer
We have an appointed Data Protection Officer (DPO), HY Education, who can be contacted in writing at HY Education, 3 Reed House, Hunters Lane, Rochdale, OL16 1YL or by telephone on 0161 543 8884 or by email (DPO@wearehy.com). You can contact the DPO should you wish to discuss any issues or concerns that you have about data protection.
What categories of pupil information do we collect?
The types of pupil information that we collect include:
- Pupil names, unique pupil numbers, contact details including emergency contacts
- Characteristics such as ethnicity, language, religion
- Free school meal and pupil premium eligibility
- Medical information and administration such as doctors’ information, child health, dental health, allergies, medication, and dietary requirements
- Admissions information
- Attendance information such as sessions attended, number of absences, absence reasons and previous school(s) attended
- Information relating to pupil exclusion and behaviour
- Attainment records and assessment results
- Reported accidents
- Safeguarding information such as court orders and professional involvement
- Special educational needs information including the need
- Biometric data (finger prints)
- Careers information
We may also receive some information from our Local Authority, other schools and the DfE.
What is the purpose of us collecting and using pupil information?
The purposes for which the MAT collects personal information are as follows:-
- To provide appropriate pastoral care
- Census reporting
- To provide free school meals
- To support children with medical conditions, allergies, and SEN
- To manage admissions
- To monitor attendance
- To manage exclusions and behaviour
- For assessment and examination purposes
- For health and safety purposes
- To address safeguarding concerns
- To promote the school and celebrate educational achievement
- To ensure that the school is safe and secure
- To allow cashless payments to be made
- To provide careers advice and support
Why is it lawful to collect this pupil information?
As a MAT, we are subject to a wide range of laws which we must comply with to further pupil education and to safeguard their wellbeing. To comply with these laws, we only process personal information as far as is necessary to meet those obligations. We also process some of the information described in this privacy notice to carry out public tasks vested in us to effectively manage the MAT.
In limited circumstances, we will obtain your consent; for example, if we want to place photographs of pupils on our website, in the newspaper or on social media. Even if you consent to us collecting and using personal information, you have a right to withdraw your consent at any time.
Some types of pupil information are regarded as more sensitive under the GDPR and referred to as being a ‘special category’ of personal information. This could include information which we collect for safeguarding or SEN purposes. Where we process this type of personal information, it will often be processed for reasons of substantial public interest such as safeguarding or to comply with statutory requirements.
Withdrawal of consent
Where we are processing your personal data with your consent, you have the right to withdraw your consent at any time. If you change your mind, or you are unhappy with our use of your personal data, please let us know by contacting Ms Helen Whitaker (email@example.com)
Who will we share pupil information with?
Those who we may share pupil information with include the following:-
- Our local authority
- The Department for Education (DfE)
- Other education providers
- School nurse service
- Multi-agency partners
- Professional advisors
- Careers service providers
- Service providers who provide learning platforms, IT and communication tools
The 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 with the Department for Education (DfE) either directly or via our local authority for the purpose of those data collections, under:
Section 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.
We may be required to share information about our pupils with the local authority to ensure that they can conduct their statutory duties under the Schools Admission Code, including conducting Fair Access Panels.
How long will we hold pupil information for?
We will hold pupil information for a period of time specified by law and as detailed within our retention policy. For more information, please contact the DPO.
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 [insert].
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
- Claim compensation for damages caused by a breach of the Data Protection laws.
Making a complaint
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with the Data Protection Officer in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns
We may need to update this privacy notice periodically so we recommend that you revisit this information from time to time. This version was last updated in September 2022.
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 the DfE to request access to individual level information relevant to detecting that crime.
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
How to find out what personal information DfE hold about you
Under the terms of the Data Protection Act 2018, you are entitled to ask the Department:
- if they are processing your personal data
- for a description of the data they hold about you
- the reasons they’re holding it and any recipient it may be disclosed to
- for a copy of your personal data and any details of its source
If you want to see the personal data held about you by the Department, you should make a ‘subject access request’. Further information on how to do this can be found within the Department’s personal information charter that is published at the address below:
To contact DfE: https://www.gov.uk/contact-dfe
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