gdpr & secure data handling policy · web view2020. 10. 21. · the terms, “information”...

COLLINGBOURNE C OF E PRIMARY SCHOOL

GDPR & Secure Data Handling Policy

INTRODUCTION

Schools have access to a wide range of sensitive information1. There are generally two types of sensitive information; personal data concerning the staff and pupils and commercially sensitive financial data. We work to ensure that both types of information are managed in a secure way at all times.

Collingbourne C of E Primary School is registered with the Information Commissioner’s Office. The school is required to process relevant personal data and shall take all reasonable steps to do so in accordance with this Policy. The school has adopted an open approach to the reporting of possible breaches to the Data Controller.

Personal DataPersonal data is the most likely form of sensitive data that a school will hold. The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.

The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.

Personal data that has been pseudonymised – eg key-coded – can fall within the scope of the GDPR depending on how difficult it is to attribute the pseudonym to a particular individual.

Sensitive personal dataThe GDPR refers to sensitive personal data as “special categories of personal data”. The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual.

PRINCIPLES

The data protection principles set out the main responsibilities for everyone to adhere to. The Data Controller in our school is responsible for, and able to demonstrate, compliance with GDPR, ensuring that data is:

1) processed fairly and lawfully2) collected for a specified purpose and not used for anything incompatible with that purpose3) adequate, relevant and not excessive4) accurate and up-to-date5) not be kept longer than necessary6) processed in accordance with the rights of the data subject7) kept securely

1 The terms, “Information” and “data” are treated as the same for the purposes of this policy.Page | 1

8) not be transferred outside the EEA (European Economic Area) unless the country offers adequate protection.

The Data Protection Act states that some types of personal information demand an even higher level of protection, this includes information relating to:

racial or ethnic origin political opinions religious beliefs or other beliefs of a similar nature trade union membership physical or mental health or condition sexual life (orientation) the commission or alleged commission by them of any offence, or any proceedings for such or

the sentence of any court in such proceedings.

The three questions below can be used to quickly assess whether information needs to treated securely, i.e.

1. Would disclosure/loss place anyone at risk?2. Would disclosure/loss cause embarrassment to an individual or the school?3. Would disclosure/loss have legal or financial implications?

If the answer to any of the above is “yes” then it will contain personal or commercially sensitive information and needs a level of protection. (A more detailed assessment guide is contained with Appendix A).

In the most simplest sense, 2 identifying factors makes data sensitive i.e. a first and last name, a first name and date of birth, a photo and a name etc. Any data containing 2 identify factors must be handled and stored securely.

PROCEDURES AND PRACTICE

The following practices will be applied within the school: The amount of data held by the school should be reduced to a minimum. Data held by the school must be routinely assessed to consider whether it still needs to be kept

or not. Personal data held by the school will be securely stored and sent by secure means. All staff are aware what constitutes secure data and their duties to ensure it is handled securely. Transparency of why we collect data and what we use if for.

AUDITING

The school must be aware of all the sensitive data it holds, be it electronic or paper. A register (Appendix B) will be kept detailing the types of sensitive data held, where and by

whom, and will be added to as and when new data is generated. How long these documents need to be kept will be assessed using the Records Management

Toolkit. Audits will take place in line with the timetable (Appendix C).

This register will be sent to all staff each year to allow colleagues to revise the list of types of data that they hold and manage.

Any auditing will be completed by the Data Controller.

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RISK ASSESSMENT

The school will carry out a risk assessment to establish what security measures are already in place and whether or not they are the most appropriate and cost effective available.

Carrying out a risk assessment will generally involve: How sensitive is the data? What is the likelihood of it falling into the wrong hands? What would be the impact of the above? Does anything further need to be done to reduce the likelihood?

Once the risk assessment has been completed, the school can decide how to reduce any risks or whether they are at an acceptable level.

Risk assessment will be an on-going process and the school will have to carry out assessments at regular intervals as risks change over time.

SECURING AND HANDLING DATA HELD BY THE SCHOOL

The school will take appropriate technical and organisational steps to ensure the security of personal data. All staff will be made aware of this policy and their duties under the Act. The school and therefore all staff and pupils are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data. An appropriate level of data security must be deployed for the type of data and the data processing being performed.

The school will encrypt2 any data that is determined to be personal or commercially sensitive in nature. This includes fixed computers, laptops and memory sticks.

Staff should not remove or copy sensitive data from the organisation or authorised premises unless the media is:

encrypted, is transported securely will be stored in a secure location.

This type of data should not be transmitted in unsecured emails (e.g. pupil names and addresses, performance reviews etc).

Data transfer should be through secure websites e.g. S2S, Perspective, common transfer files and school census data. If this is not available then the file must be minimally password protected or preferably encrypted before sending via email, the password must be sent by other means and on no account included in the same email. A record of the email should be kept, to identify when and to whom the email was sent, (e.g. by copying and pasting the email into a Word document).

Data (pupil records, SEN data, contact details, assessment information) will be backed up, encrypted and stored in a secure place – e.g. safe/fire safe/remote backup.

All staff computers will be used in accordance with the Teacher Laptop Policy (Appendix C).

2 Encryption of computers and memory sticks can be provided by the school’s technical support. Page | 4

When laptops are passed on or re-issued, data will be securely wiped from any hard drive before the next person uses it (not simply deleted). This will be done by a technician using a recognised tool, e.g. McAfee Shredder.

The school’s wireless network (WiFi) will be secure at all times3. The school will identify which members of staff are responsible for data protection. The school will ensure that staff who are responsible for sets of information, such as SEN, medical, vulnerable learners, management data etc know what data is held, who has access to it, how it is retained and disposed of. Appendix B details which members of staff are responsible for which data. This is shared with all staff concerned within the school.

Where a member of the school has access to data remotely (e.g. SIMS from home), remote access off the school site to any personal data should be over an encrypted connection (e.g. VPN) protected by a username/ID and password. This information must not be stored on a personal (home) computer.

Members of staff (e.g. senior administrators) who are given full, unrestricted access to an organisation’s management information system should do so over an encrypted connection and use two-factor authentication, which is available to SIMS users from Capita. This information must not be stored on a personal (home) computer.

The school will keep necessary pupil and staff information in accordance with the Records Management Toolkit guidance (see references at the end of this document).

The school will securely delete commercially sensitive or personal data when it is no longer required as per the Records Management Toolkit guidance.

All staff will be trained to understand the need to handle data securely and the responsibilities incumbent on them this will be the responsibility of the Headteacher.

When sensitive data is to be sent out of the school it must be done in a secure way.

RIGHTS OF ACCESS TO INFORMATION

Data subjects have the right of access to information held by the school, subject to the provisions of the Data Protection Act 1998 and the Freedom of Information Act 2000. Any data subject wishing to access their personal data should put their request in writing to the Data Controller. The school will endeavour to respond to any such written requests as soon as is reasonably practicable, but within 20 working days to provide a reply to an access to information request. The information will be imparted to the data subject as soon as is reasonably possible, within the required timeline after it has come to the school's attention and in compliance with the relevant Acts.

EXEMPTIONS

Certain data is exempted from the provisions of the Data Protection Act which includes the following: National security and the prevention or detection of crime The assessment of any tax or duty Where the processing is necessary to exercise a right or obligation conferred or imposed by law

upon the school, including safeguarding and prevention of terrorism and radicalisation

3 The school will use WPA2 (or WPA if WPA2 is not available). The older standard WEP will not be used.Page | 5

The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought from the ICO.

ACCURACY

The school will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the school of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.

The school will issue Privacy Notices to staff and parents of children informing what information we collect and why. These will be issued to new admissions and a yearly update will be sent out to existing data subjects to ensure accuracy. See Appendix F.

ENFORCEMENT

If an individual believes that the school has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, the member of staff should notify the Data Protection Officer, who will investigate the breach and inform the ICO as appropriate.

EXTERNAL PROCESSORS & 3 RD PARTYIES

The school will ensure that data processed by external processors and 3 rd parties, for example, service providers, photographers, Classroom Dojo, etc are compliant with GDPR, the relevant legislation and retention procedures.

SECURE DESTRUCTION

When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction. Certificates of secure destruction must be obtained from service providers if used i.e. photocopying company, professional shredding services etc.

RETENTION OF DATA

The school will retain data in line with the records management policy outlined in Appendix E – see particularly the Retention Table.

This policy was produced in line with guidance from Wiltshire Council and 001 Inspiration Ltd by the Headteacher.

This policy should be read and understood in conjunction with the following policies and guidance:

The Data Protection Act 1998 ICO General Data Protection Regulation

This policy will be reviewed every 2 years or as necessary.

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Written and Adopted: September 2009Last Review: February 2018Next Review: February 2020

References:

The Data Protection Act 1998: http://www.opsi.gov.uk/acts/acts1998/ukpga_19980029_en_1

Information Commissioner’s Officehttps://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr

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https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr

http://www.opsi.gov.uk/acts/acts1998/ukpga_19980029_en_1


Secure Data Handling Policy

Help sheet for assessing risk of sharing information

In deciding the most appropriate way to share information and the level of security required, you must always take into consideration the nature of the information and the urgency of the situation, i.e. take a risk based approach to determining appropriate measures.

The simplified process described below will help the school to choose the appropriate level of security to consider when emailing information.

Step 1Imagine a potential security breach (e.g. a confidential letter is left in a public area, a memory stick is lost or someone reads information on a computer screen while waiting to meet a member of staff), and consider:

1 Will it affect or identify any member of the school or community?2 Will someone lose / be out of pocket by / more than £100?3 Will it cause any kind of criminal case to fail?4 Is there a risk of discomfort / slur upon professional character of someone?5 Is anyone’s personal safety at risk?6 Will it embarrass anyone?

If you answered NO to all the questions, the document does not contain sensitive information. If you answered yes to any of the questions, the document with include some sensitive information and therefore requires a level of protection.

Step 2Imagine the same potential security breach as above, and consider:

7 Will it affect many members of the school or local community and need extra resources locally to manage it?

8 Will an individual or someone who does business with the school lose/be out of pocket by £1,000 to £10,000?

9 Will a serious criminal case or prosecution fail?10 Is someone’s personal safety at a moderate risk?11 Will someone lose his or her professional reputation?12 Will a company or organisation that works with the school lose £100,000 to £1,000,000?

If you have answered yes to any of the above questions the document contains sensitive information and additional security should be considered, such as, password protecting the document before you email it to a colleague outside of your organisation.

However, if you think that the potential impact exceeds that stated in the question (for example, someone’s personal safety is at high risk) think very carefully before you release this information.

Step 3All documents that do not fit into steps 1 or 2 might require a higher level of protection / security; organisations should err on the side of caution.

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Appendix A



Register of sensitive data held by the school

Type of data Held where Period to be retained Type of protection Who can access the data

Pupil SEN data Teacher/SENCO Cabinet Teacher/SENCO Laptop

Locked CabinetData is encrypted on laptop

SENCOHeadteacher

Pupil Data:PersonalAssessment

ClassroomsServerSchool OfficeHeadteacher Office

Locked CabinetsPassword Protected Computer AccessEncrypted Memory Sticks

HeadteacherTeachersOffice Staff

Pupil Data:Accident Forms

School Office Locked Cabinet HeadteacherOffice Staff

Pupil Data:Medical Information

School OfficeMedical needs poster (who’s who with need)

Locked CabinetMedical needs poster up in staff room with parents consent

HeadteahcerOffice StaffMedical needs poster - all

Staff DataPersonalSickness Absence

Headteachers OfficeSchool Office

Locked CabinetsAdmin Drive on Server

HeadteacherAdmin & Finance Officer

Staff DataPerformance Review

Headteachers Office Locked CabinetsHeadteacher Drive on Server

Safeguarding Records Headteachers Office Locked Cabinet Headteacher (DSL)Deputy DSLAdmin & Finance Officer

Exclusion Records School Office Locked Cabinet HeadteacherAdmin & Finance Officer

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Appendix B

Behaviour Records School Office Locked Cabinet HeadteacherAdmin & Finance Officer



Timetable for Information Security Management

Activity Frequency Lead

Audit of data held Annually Headteacher Admin & Finance Officer

Encrypting sensitive data On-going All staff

Reviewing data backup procedures Annual Admin & Finance Officer

Identifying staff responsible for data security and keep log of names and roles.

Annual Admin & Finance Officer

Wiping of laptop data when re-issued Annual and then when necessary. ICT Technician

Wiping of laptop data when discarded As necessary ICT Technician

Secure Data Wiping of Photocopier hard drive As necessary Admin & Finance Officer

3rd Party position on GDPR and retention information

Upon commencing working with 3rd party provider

HeadteacherAdmin & Finance Officer

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Appendix C



Staff Computer Use Policy

Passwords that I use to access school systems will be kept secure and secret – if I have reason to believe that my password is no longer secure I will change it.

I acknowledge that the computer provided for me to use remains the property of the school and should only be used for school business.

I will not access the files of others or attempt to alter the computer settings.

I will not update web content or use pictures or text that can identify the school, without the permission of the headteacher.

I will not alter, attempt to repair or interfere with the components, software or peripherals of any computer that is the property of the school. I will seek permission with the school’s technician/ Network Manager should I need to install additional software.

I will always adhere to the copyright.

I will always log off the system when I have finished working.

I understand that the school may monitor the Internet sites I visit.

I will not open e-mail attachments unless they come from a recognised and reputable source. I will bring any other attachments to the attention of the school technician/ Headteacher/Admin & Finance Officer.

Any e-mail messages I send will not damage the reputation of the school.

All joke e-mails and attachments are potentially damaging and undesirable and therefore should not be forwarded.

I understand that a criminal offence may be committed by deliberately accessing Internet sites that contain certain illegal material.

Use for personal financial gain, gambling, political purposes or advertising is forbidden.

Storage of e-mails and attachments should be kept to a minimum to avoid unnecessary drain on memory and capacity.

I understand that I am responsible for the safety of school data that I use or access.

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Appendix D

In order to maintain the security of data I will take the following steps: I will store data files in my user area only for as long as is necessary for me to carry out my

professional duties. I will not save data files to a PC or laptop other than that provided by the school. If I need to transfer sensitive data files and no secure electronic option is available I will only

do so using the encrypted USB key provided by the school. Sensitive data will only be sent electronically through a secure method, e.g. Perspective. If

this is not available then the minimum requirement is to password protect the document before attaching it to email.

Sensitive data includes: Pupil reports SEN records Letters to parents Class based assessments Exam results Whole school data Medical information Information relating to staff, e.g. Performance Management reviews.

If I am in any doubt as to the sensitivity of data I am using, I will consider these questions:

Would disclosure/loss place anyone at risk? Would disclosure/loss cause embarrassment to an individual or the school? Would disclosure/loss have legal or financial implications?

If the answer to any of these questions is yes, then the data should be treated as sensitive.

I understand that if I do not adhere to these rules outlined in this policy, my network access will be suspended immediately, my laptop removed and that other disciplinary consequences may follow including notification to professional bodies where a professional is required to register. If an incident is considered to be an offence under the Computer Misuse Act or the Data Protection Act this may be reference for investigation by the Police and could recorded on any future Criminal Record Bureau checks.

Name:

Date:

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Records Management Policy

Collingbourne C of E Primary School recognises that by efficiently managing its records, it will be able to comply with its legal and regulatory obligations and to contribute to the effective overall management of the school. Records provide evidence for protecting the legal rights and interests of the school, and provide evidence for demonstrating performance and accountability. This document provides the policy framework through which this effective management can be achieved and audited.

SCOPE OF THE POLICYThis policy applies to all records created, received or maintained by staff of the school in the course of carrying out its functions.

Records are defined as all those documents which facilitate the business carried out by the school and which are thereafter retained (for a set period) to provide evidence of its transactions or activities. These records may be created, received or maintained in hard copy or electronically.

A small percentage of the school’s records will be selected for permanent preservation as part of the institution’s archives and for historical research. This should be done in liaison with the County Archives Service.

RESPONSIBILITIESThe school has a corporate responsibility to maintain its records and record keeping systems in accordance with the regulatory environment. The person with overall responsibility for this policy is the Headteacher.

The person responsible for records management in the school will give guidance for good records management practice and will promote compliance with this policy so that information will be retrieved easily, appropriately and in a timely way. They will also monitor compliance with this policy by surveying at least annually to check if records are stored securely and can be accessed appropriately.

Individual staff and employees must ensure that records for which they are responsible are accurate, and are maintained and disposed of in accordance with the school’s records management guidelines.

RELATIONSHIP WITH EXISTING POLICIESThis policy has been drawn up within the context of:

Freedom of Information policy Data Protection Policy, GDPR & Secure Data Handling Policy and with other legislation or regulations (including audit, equal opportunities and ethics)

affecting the school.

PUPIL RECORDSThe pupil record starts its life when a file is opened for each new pupil as they begin school. This is the file which will follow the pupil for the rest of his/her school life. Here at Collingbourne C of E Primary School, we endeavour to be as paperless as possible in these modern times. Admissions forms are completed by parents for Reception children and any children starting mid-year and returned to the school office. These admission forms enable us to collate information required for specific purpose and

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Appendix E

we ensure privacy notices are circulated and the correct permissions to hold the personal data is obtained from parents. The information collected on the admissions form is used to populate the Schools Information Management System (SIMS). The following information is held on the admissions form (filed securely) and the SIMS only (to ensure we don’t duplicate information and hold data in too many areas):

Surname Forename DOB Unique Pupil Number (The Unique Pupil Number is a number that identifies each pupil in

England uniquely. It is intended to remain with them throughout their school career regardless of any change in school or Local Authority)

Gender Preferred name The name of the pupil’s doctor Emergency contact details Position in family Ethnic origin (Although this is “sensitive” data under the Data Protection Act 1998, the

Department for Education require statistics about ethnicity) Language of home (if other than English) (This needs to be recorded for the School Census

(Mother Tongue) Religion (Although this is “sensitive” data under the Data Protection Act 1998, the school has

good reasons for collecting the information) Any allergies or other medical conditions that it is important to be aware of (Although this is

“sensitive” data under the Data Protection Act 1998, the school has good reasons for collecting the information)

Names of adults who hold parental responsibility with home address and telephone number (and any additional relevant carers and their relationship to the child)

Name of the school, admission number and the date of admission and the date of leaving. Any other agency involvement e.g. speech and language therapist, paediatrician. It is essential

that these files, which contain personal information, are managed against the information security guidelines.

If the pupil has attended an early years setting, then the record of transfer should be included on the pupil file

Other stored items relating to pupils filed in secure separate area related files: Privacy Notice (issued annually with only the most recent on the file) Photography Consents Annual Written Report to Parents National Curriculum and Religious Education Locally Agreed Syllabus Record Sheets Any information relating to a major incident involving the child (either an accident or other

incident) Any reports written about the child Any information about a statement and support offered in relation to the statement (also on

SIMS) Any relevant medical information (also on SIMS) Child protection reports/disclosures (stored in line with the Child Protection Record Keeping &

Management Policy) Any information relating to exclusions (fixed or permanent) (also on SIMS) Any correspondence with parents or outside agencies relating to major issues Details of any complaints made by the parents or the pupil Absence notes

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Parental consent forms for trips/outings (in the event of a major incident all the parental consent forms should be retained with the incident report not in the pupil record)

Correspondence with parents about minor issues Accident forms (these should be stored separately and retained on the school premises until

their statutory retention period is reached. A copy could be placed on the pupil file in the event of a major incident).

TRANSFERRING THE PUPIL RECORD TO THE SECONDARY SCHOOLThe pupil record will not be ‘weeded’ before transfer to secondary school unless any records with a short retention period have been placed in the file.

We will not keep copies of any records in the pupil record except if there is an ongoing legal action when the pupil leaves the school. Custody of and responsibility for the records passes to the school the pupil transfers to.

Files will not be sent by post unless absolutely necessary. If files are sent by post, they should be sent by registered post with an accompanying list of the files. The secondary school should sign a copy of the list to say that they have received the files and return the list to us. Where appropriate, records can be delivered by hand with signed confirmation for tracking and auditing purposes.

Electronic documents that relate to the pupil file also need to be transferred, or, if duplicated in a master paper file, destroyed.

As we are paperless with most of our information stored on the SIMS which is securely transferred to the new school via a CTF. Child Protection records are transferred in line with the Child Protection Record Keeping & Management Policy.

RESPONSIBILITY FOR THE PUPIL RECORD ONCE THE PUPIL LEAVES THE SCHOOLThe school which the pupil attended until statutory school leaving age (18 years old) is responsible for retaining the pupil record until the pupil reaches the age of 25 years.

SAFE DESTRUCTION OF THE PUPIL RECORDThe pupil record should be disposed of in accordance with the safe disposal of records guidelines.

TRANSFER OF A PUPIL RECORD OUTSIDE THE EU AREALocal Authority advice will be sought if we are requested to transfer a pupil file outside the EU area because a pupil has moved into that area.

STORAGE OF PUPIL RECORDSAll pupil records are kept securely at all times. Paper records, for example, are kept in lockable storage areas with restricted access, and the contents should be secure within the file. Equally, electronic records have appropriate security. Access arrangements for pupil records should ensure that confidentiality is maintained whilst equally enabling information to be shared lawfully and appropriately, and to be accessible for those authorised to see it.

E-MAIL

As communicating by e-mail is quick and easy, many people have replaced telephone conversations and memos with e-mail discussions. However, the language in which e-mail is written is often less formal and more open to misinterpretation than a written memo or a formal letter. E-mails should be laid out and formulated to the school’s standards for written communications.

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E-mail is not always a secure medium to send confidential information. The consequences of an e-mail containing sensitive information being sent to an unauthorised person could be a civil penalty of up to £500,000 from the Information Commissioner. Confidential or sensitive information should only be sent by a secure encrypted e-mail system. Personal information (such as a pupil’s name) must never be in the subject line of an e-mail.

All school e-mail is disclosable under Freedom of Information and Data Protection legislation, anything written in an email could potentially be made public. E-mails can remain in a system for a period of time after deletion. It’s worth noting that although you may have deleted your copy of the e-mail, the recipients may not and therefore there will still be copies in existence. These copies could be disclosable under the Freedom of Information Act 2000 or under the Data Protection Act 1998.

All attachments in e-mail should be saved into any appropriate electronic filing system or printed out and placed on paper files.

DIARIES AND WRITTEN NOTES

Anything written down regarding a data subject is disclosable under Freedom of Information and Data Protection legislation, meaning anything written in a diary or in workplace notebooks etc could potentially be made public. Names and secure data should not be put in diaries and notes should be filed in the appropriate file or destroyed when no longer needed.

RETENTION GUIDELINES

Under the Freedom of Information Act 2000, schools are required to maintain a retention schedule listing the record series which the school creates in the course of its business. The retention schedule lays down the length of time which the record needs to be retained and the action which should be taken when it is of no further administrative use. The retention schedule lays down the basis for normal processing under both the Data Protection Act 1998 and the Freedom of Information Act 2000.

Members of staff are expected to manage their current record keeping systems using the retention schedule and to take account of the different kinds of retention periods when they are creating new record keeping systems.

The retention schedule refers to record series regardless of the media in which they are stored.

There are a number of benefits which arise from the use of a complete retention schedule: Managing records against the retention schedule is deemed to be “normal processing” under the

Data Protection Act 1998 and the Freedom of Information Act 2000. Members of staff should be aware that once a Freedom of Information request is received or a legal hold imposed then records disposal relating to the request or legal hold must be stopped.

Members of staff can be confident about safe disposal information at the appropriate time. Information which is subject to Freedom of Information and Data Protection legislation will be

available when required. The school is not maintaining and storing information unnecessarily.

Where appropriate the retention schedule will be reviewed and amended to include any new record series created and remove any obsolete record series.

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The retention schedule contains recommended retention periods for the different record series created and maintained by the school in the course of it’ business. The schedule refers to all information regardless of the media in which it is stored.Some of the retention periods are governed by statute. Others are guidelines following best practice. Every effort has been made to ensure that these retention periods are compliant with the requirements of the Data Protection Act 1998 and the Freedom of Information Act 2000.

Managing record series using these retention guidelines will be deemed to be “normal processing” under the legislation mentioned above. If record series are to be kept for longer or shorter periods than laid out in this document the reasons for this need to be documented.

The Retention Schedule is divided into five sections:1. Management of the School2. Human Resources3. Financial Management of the School4. Property Management5. Pupil Management6. Curriculum Management7. Extra-Curricular Activities8. Central Government and Local Authority

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1. MANAGEMENT OF THE SCHOOL1.1 Governing Body

File Description Data Protection Issues Statutory Provisions Retention Period (Operational)

Action at the end of the administrative life of the record

1.1.1 Agendas for Governing Body meetings

There may be data protection issues if the meeting is dealing with confidential issues relating to staff

One copy should be retained with the master set of minutes. All other copies can be disposed of.

Secure Disposal

1.1.2 Minutes of Governing Body meetings

There may be data protection issues if the meeting is dealing with confidential issues relating to staff

1 x Permanent1 x inspection copies from date of meeting for 3 years.

Secure disposal is containing sensitive, personal information

1.1.3 Reports presented to the Governing body

There may be data protection issues if the report deals with confidential issues relating to staff

Reports should be kept for a minimum of 6 years. However, if the minutes refer directly to individual reports then the reports should be kept permanently

Secure disposal or retain with the signed set of minutes

1.1.4 Meeting papers relating to the annual parents’ meeting held under section 33 of the Education Act 2002

No Education Act 2002, Section 33

Date of the meeting + a minimum of 6 years

Secure Disposal

1.1.5 Instruments of Government including Articles of Association

No Permanent These should be retained in the school whilst the school is open and then offered to County Archives Service when the school closes

1.1.7 Action plans created and administered by the Governing Body

No Life of the action plan + 3 years

Secure Disposal

1.1.8 Policy documents created and administered by the Governing Body

No Life of the Policy + 3 years Secure Disposal

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1.1.9 Records of complaints dealt with by the Governing Body

Yes Date of the resolution of the complaint + a minimum of 6 years then review doe further retention in case of contentious disputes

Secure Disposal

1.1.10 Annual Reports created under the requirements of the Education (Governor’s Annual Reports) (England) (Amendment) Regulations 2002

No Education (Governor’s Annual Reports) (England) (Amendment) Regulations 2002 SI 2002 No 1171

Date of report + 10 years Secure Disposal

1.1.11 Proposals concerning the change of status of a maintained school including Academies

No Date proposal accepted or declined + 3 years

Secure Disposal

1.2 Headteacher and Senior Management TeamFile Description Data Protection Issues Statutory Provisions Retention Period

(Operational)Action at the end of the administrative life of the record

1.2.1 Log books of activity in the school maintained by the Headteacher

There may be data protection issues if the log book refers to individual pupils or members of staff

Date of last entry in the book + a minimum of 6 years then review

These could be of permanent historic value and should be offered to County Archives Service if appropriate.

1.2.2 Minutes of Senior Management Team meetings and the meetings of other internal administrative bodies

There may be data protection issues if the minutes refer to individual pupils or members of staff

Date of the meeting + 3 years then review

Secure Disposal

1.2.3 Reports created by the Headteacher or Senior Management Team

There may be data protection issues if the report refers to individual pupils or members of staff

Date of the report + a minimum of 3 years then review

Secure Disposal

1.2.4 Records created by Headteacher, Senior Management Team and

There may be data protection issues if the records refer to individual

Current academic year + 6 years then review

Secure Disposal

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other members of staff with administrative responsibilities

pupils or members of staff

1.2.5 Correspondence created by Headteacher, Senior Management Team and other members of staff with administrative responsibilities

There may be data protection issues if the correspondence refers to individual pupils or members of staff

Date of correspondence + 3 years then review

Secure Disposal

1.2.6 Professional Development Plans

Yes Life of the plan + 6 years Secure Disposal

1.2.7 School Development Plans No Life of the plan + 3 years Secure Disposal

1.3 Admissions ProcessFile Description Data Protection Issues Statutory Provisions Retention Period


1.3.1 All records relating to the creation and implementation of the School’s Admissions Policy

No School Admissions Code Statutory guidance for admission authorities, governing bodies, local authorities, schools adjudicators and admission appeals panels December 2014

Life of the Policy + 3 years then review

Secure Disposal

1.3.2 Admissions – if the admission is successful

Yes School Admissions Code Statutory guidance for admission authorities, governing bodies, local authorities, schools adjudicators and admission appeals panels December 2014

Date of admission + 1 year Secure Disposal

1.3.3 Admissions – if the appeal is unsuccessful

Yes School Admissions Code Statutory guidance for admission authorities,

Resolution of case + 1 year Secure Disposal

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governing bodies, local authorities, schools adjudicators and admission appeals panels December 2014

1.3.4 Register of Admissions Yes School attendance: Departmental advice for maintained schools, academies, independent schools and local authorities October 2014

Every entry in the admission register must be preserved for a period of 3 years after the date on which the entry was made

Review – schools may wish to consider keeping the admission register permanently as often schools receive enquiries from past pupils to conform the dates they attended the school

1.3.6 Proofs of address supplied by parents as part of the admissions process

Yes School Admissions Code Statutory guidance for admission authorities, governing bodies, local authorities, schools adjudicators and admission appeals panels December 2014

Current year + 1 year Secure Disposal

1.3.7 Supplementary Information form including additional information such as religion, medical conditions etc

Yes For successful admissions

For unsuccessful admissions

Information added to the pupil file

Until appeals process completed

Secure disposal

1.4 Operational AdministrationFile Description Data Protection Issues Statutory Provisions Retention Period


1.4.1 General file series No Current year + 5 years then review

Secure disposal

1.4.2 Records relating to the creation and publication of the school brochure or prospectus

No Current year + 3 years Standard Disposal

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1.4.3 Records relating to the creation and distribution of circulars to staff, parents or pupils

No Current year + 1 year Standard Disposal

1.4.4 Newsletters and other items with short operational use

No Current year + 1 year Standard Disposal

1.4.5 Visitors books and signing in sheets

Yes Current year + 6 years then review

Secure Disposal

1.4.6 Records relating to the creation and management of parent teacher associations and/or old pupils associations

No Current year + 6 years then review

Secure Disposal

2. HUMAN RESOURCES2.1 Recruitment

File Description Data Protection Issues Statutory Provisions Retention Period (Operational)


2.1.1 All records leading up to the appointment of a new Headteacher

Yes Date of appointment + 6 years

Secure Disposal

2.1.2 All records leading up to the appointment of a new member of staff – unsuccessful candidates

Yes Date of appointment of successful candidate + 6 months

Secure Disposal

2.1.3 All records leading up to the appointment of a new member of staff – successful candidate

Yes All the relevant information should be added to the staff personal file (see below) and all other information retained for 6 months

Secure Disposal

2.1.4 Pre-employment vetting information – DBS checks

No DBS Update Service Employer Guide June 2014: Keeping children safe in education. July 2015 (Statutory Guidance from

The school does not have to keep copies of DBS certificates. If the school does so the copy must NOT be retained for more than 6

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Dept. of Education) Sections 73, 74

months

2.1.5 Proofs of identity collected as part of the process of checking ‘portable’ enhanced DBS disclosure

Yes Where possible these should be checked and a note kept of what was seen and what has been checked. If it is felt necessary to keep copy documentation then this should be placed on the member of staff’s personal file

2.1.6 Pre-employment vetting information – evidence providing the right to work in the United Kingdom

Yes An employer’s guide to right to work checks (Home Office May 2015)

Where possible these documents should be added to the staff personal file (see below), but if they are kept separately then the Home Office requires that the documents are kept for termination of employment plus not less than 2 years

2.2 Operational Staff ManagementFile Description Data Protection Issues Statutory Provisions Retention Period


2.2.1 Staff Personal File Yes Limitation Act 1980 (Section 2)

Termination of Employment + 6 years

SECURE DISPOSAL

2.2.2 Timesheets Yes Current year + 6 years SECURE DISPOSAL2.2.3 Annual appraisal/Assessment

recordsYes Current year + 5 years SECURE DISPOSAL

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2.3 Management of Disciplinary and Grievance ProcessesFile Description Data Protection Issues Statutory Provisions Retention Period


2.3.1 Allegation of a child protection nature against a member of staff including where the allegation is unfounded*

Yes “Keeping children safe in education Statutory guidance for schools and colleges March 2015”, “Working together to safeguard children. A guide to inter-agency working to safeguard and promote the welfare of children March 2015”.

Until the person’s normal retirement age or 10 years from the date of the allegation whichever is the longer then REVIEW. Note allegations that are found to be malicious should be removed from personnel files. If found they are to be kept on the file and a copy provided to the person concerned.

SECURE DISPOSALThese records must be shredded

2.3.2 Disciplinary Proceedings YesOral warning Date of warning + 6 months SECURE DISPOSAL

If warnings are placed on personal files then they must be weeded from the file

Written warning – level 1 Date of warning + 6 monthsWritten warning – level 2 Date of warning + 12 monthsFinal Warning Date of warning + 18 monthsCase not found If the incident is child

protection related then see above, otherwise dispose of at the conclusion of the case

SECURE DISPOSAL

2.4 Health and SafetyBasic File Description Data Protection Issues Statutory Provisions Retention Period


2.4.1 Health and Safety Policy Statements

No Life of policy + 3 years SECURE DISPOAL

2.4.2 Health and Safety Risk Assessments

No Life of risk assessment + 3 years

SECURE DISPOAL

2.4.3 Records relating to Yes Date of incident + 12 years SECURE DISPOAL

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accident/injury at work In the case of serious accidents a further retention period will need to be applied

2.4.4 Accident reporting Yes Social Security (Claims and Payments) Regulations 1979 Regulation 25. Social Security Administration Act 1992 Section 8. Limitation Act 1980.

Adults Date of incident + 6 years SECURE DISPOSALChildren DOB of the child + 25 years SECURE DISPOSAL

2.4.5 Control of Substances Hazardous to Health (COSHH)

No Control of Substances Hazardous to Health Regulations 2002. SI 2002 No 2677 Regulation 11; Records kept under the 1994 and 1999 Regulations to be kept as if the 2002 Regulations had not been made. Regulation 18 (2)

Current Year + 40 years SECURE DISPOSAL

2.4.6 Process of monitoring of areas where employees and persons are likely to have become in contact with asbestos

No Control of Asbestos at Work Regulations 2012 SI 1012 No 632 Regulation 19

Last action + 40 years SECURE DISPOSAL

2.4.7 Process of monitoring of areas where employees and persons are likely to have become in contact with radiation

No Last action + 50 years SECURE DISPOSAL

2.4.8 Fire Precautions log books No Current year + 6 years SECURE DISPOSAL

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2.5 Payroll and PensionsBasic File Description Data Protection Issues Statutory Provisions Retention Period


2.5.1 Maternity pay records Yes Statutory Maternity Pay (General) Regulations 1986 (SI1986/1960), revised 1999 (SI1999/567)

Current year + 3 years SECURE DISPOAL

2.5.2 Records held under Retirement Benefits Schemes (Information Powers) Regulations 1995

Yes Current year + 6 years SECURE DISPOSAL

3. FINANCIAL MANAGEMENT OF THE SCHOOL3.1 Risk Management and Insurance

Basic File Description Data Protection Issues Statutory Provisions Retention Period (Operational)


3.1.1 Employer’s Liability Insurance Certificate

No Closure of the school + 40 years

SECURE DISPOSAL

3.2 Asset ManagementBasic File Description Data Protection Issues Statutory Provisions Retention Period


3.2.1 Inventories of furniture and equipment

No Current year + 6 years SECURE DISPOSAL

3.2.2 Burglary, theft and vandalism reporting forms


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3.3 Accounts and Statements including budget managementBasic File Description Data Protection Issues Statutory Provisions Retention Period


3.3.1 Annual Accounts No Current year + 6 years STANDARD DISPOSAL3.3.2 Loans and grants managed

by the schoolNo Date of last payment on the

loan + 12 years then REVIEWSECURE DISPOSAL

3.3.3 Student Grant applications Yes Current year + 3 years SECURE DISPOSAL3.3.4 All records relating to the

creation and management of budgets including the Annual Budget Statement and background papers

No Life of the budget + 3 years SECURE DISPOSAL

3.3.5 Invoices, receipts, order books and requisitions, delivery notices

No Current financial year + 6 years

SECURE DISPOSAL

3.3.6 Records relating to the collection and banking of monies


SECURE DISPOSAL

3.3.7 Records relating to the identification and collection of debt

No Current Financial year + 6 years

SECURE DISPOSAL

3.4 Contract ManagementBasic File Description Data Protection Issues Statutory Provisions Retention Period


3.4.1 All records relating to the management of contracts under seal

No Limitation Act 1980 Last payment on the contract + 12 years

SECURE DISPOSAL

3.4.2 All records relating to the management of contracts under signature

No Limitation Act 1980 Last payment on the contract + 6 years

SECURE DISPOSAL

3.4.3 Records relating to the monitoring of contracts


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3.5 School FundBasic File Description Data Protection Issues Statutory Provisions Retention Period


3.5.1 School Fund Cheque Books No Current year + 6 years SECURE DISPOSAL3.5.2 School fund Paying in books No Current year + 6 years SECURE DISPOSAL3.5.3 School fund Ledger No Current year + 6 years SECURE DISPOSAL3.5.4 School fund Invoices No Current year + 6 years SECURE DISPOSAL3.5.5 School fund Receipts No Current year + 6 years SECURE DISPOSAL3.5.6 School fund Bank Statements No Current year + 6 years SECURE DISPOSAL3.5.7 School fund Journey Books No Current year + 6 years SECURE DISPOSAL

3.6 School Meals ManagementBasic File Description Data Protection Issues Statutory Provisions Retention Period


3.6.1 Free School Meals Registers Yes Current year + 6 years SECURE DISPOSAL3.6.2 School Meals Registers No Current year + 3 years SECURE DISPOSAL3.6.3 School Meals Summary

SheetsNo Current year + 3 years SECURE DISPOSAL

4. PROPERTY MANAGEMENT4.1 Property Management



4.1.1 Title deeds of properties belonging to the school

No PERMANENTThese should follow the property unless the property has been registered with the Land Registry

4.1.2 Plans f property belonging to the school

No These should be retained whilst the building belongs to the school and should be passed onto any new owners

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if the building is leased or sold.

4.1.3 Leases of property leased by or to the school

No Expiry of lease + 6 years SECURE DISPOSAL

4.1.4 Records relating to the letting of school premises


SECURE DISPOSAL

4.2 MaintenanceBasic File Description Data Protection Issues Statutory Provisions Retention Period


4.2.1 All records relating to the maintenance of the school carried out by contractors


4.2.2 All records relating to the maintenance of the school carried out by school employees including maintenance log books


5. PUPIL MANAGEMENT5.1 Pupil’s Educational Record



5.1.1 Pupil’s Educational Record required by The Education (Pupil Information) (England) Regulations 2005

Yes The Education (Pupil Information) (England) Regulations 2005 SI 2005 No 1437

Primary Retain whilst the child remains at the primary school

The file should follow the pupil when he/she leaves the primary school. This will include: To another primary

school To a secondary school

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To a pupil referral unit If the pupil dies whilst at

primary school the file should be returned to the Local Authority to be retained for the statutory retention period.

If the pupil transfers to an independent school, transfers to home schooling or leaves the country the file should be returned to the Local Authority to be retained for the statutory retention period. Primary Schools do not ordinarily have sufficient storage space to store records for pupils who have not transferred in the normal way. It makes more sense to transfer the record to the Local Authority as it is more likely that the pupil will request the record from the Local Authority.

Secondary Limitation Act 1980 (Section 2)

Date of Birth of the pupil + 25 years

SECURE DISPOSAL

5.1.2 Examination Results – Pupil Copies

Yes

Public This information should be added to the pupil file

All uncollected certificates should be returned to the examination boards.

Internal This information should be added to the pupil file

5.1.3 Child Protection information held on pupil file

Yes “Keeping children safe in education Statutory guidance

If any records relating to child protection issues are

SECURE DISPOSAL – these records MUST be shredded

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for schools and colleges March 2015”, “Working together to safeguard children. A guide to inter-agency working to safeguard and promote the welfare of children March 2015”.

places on the pupil file, it should be in a sealed envelope and then retained for the same period of time as the pupil file.

5.1.4 Child Protection information held in separate files

Yes “Keeping children safe in education Statutory guidance for schools and colleges March 2015”, “Working together to safeguard children. A guide to inter-agency working to safeguard and promote the welfare of children March 2015”.

DOB of the child + 25 years then review.This retention period was agreed in consultation with the Safeguarding Children Group on the understanding that the principal copy of this information will be found on the Local Authority Social Services record.

SECURE DISPOSAL – these records MUST be shredded

5.2 AttendanceBasic File Description Data Protection Issues Statutory Provisions Retention Period


5.2.1 Attendance Registers Yes School attendance: Departmental advice for maintained schools, academies, independent schools and local authorities October 2014.

Every entry in the attendance register must be preserved for a period of 3 years after the date on which the entry was made.

SECURE DISPOSAL

5.2.2 Correspondence relating to authorised absence

Education Act 1996 Section 7 Current academic year + 2 years

SECURE DISPOSAL

5.3 Special Educational Needs5.3.1 Special Educational Needs Yes Limitation Act 1980 (Section Date of Birth of the pupil + REVIEW

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files, reviews and Individual Education Plans

2) 25 years NOTE: This retention period is the minimum retention period that any pupil file should be kept. Some authorities choose to keep SEN files for a longer period of time to defend themselves in a “failure to provide a sufficient education” case. There is an element of business risk analysis involved in any decision to keep the records longer than the minimum retention period and this should be documented.

5.3.2 Statement maintained under Section 234 of the Education Act 1990 and any amendments made to the statement

Yes Education Act 1996 Special Educational Needs and Disability Act 2001 Section 1

Date of birth of the pupil + 25 years (this would normal be retained on the pupil file)

SECURE DISPOSAL unless the document is subject to a legal hold

5.3.3 Advice and information provided to parents regarding educational needs

Education Act 1996 Special Educational Needs and Disability Act 2001 Section 2



5.3.4 Accessibility Strategy Education Act 1996 Special Educational Needs and Disability Act 2001 Section 14



6. CURRICULUM MANAGEMENT6.1 Statistics and Management Information



6.1.1 Curriculum returns No Current year + 3 years SECURE DISPOSAL6.1.2 Examination Results (Schools

Copy)Yes Current year + 6 years SECURE DISPOSAL

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SATs records: YesResults The SATs results should be

recorded on the pupil’s educational file and will therefore be retained until the pupil reaches the age of 25 years. The school may wish to keep a composite record of all the whole year SATs results.These could be kept for current + 6 years to allow suitable comparison.

SECURE DISPOSAL

Examination papers The examination papers should be kept until any appeals/validation process is complete.

SECURE DISPOSAL

6.1.3 Published Admission Number (PAN) Reports


6.1.4 Value Added and Contextual Data


6.1.5 Self Evaluation Forms Yes Current year + 6 years SECURE DISPOSAL

6.2 Implementation of CurriculumBasic File Description Data Protection Issues Statutory Provisions Retention Period


6.2.1 Schemes of Work No Current year + 1 year It may be appropriate to review these records at the end of each year and allocate a further retention period or SECURE DISPOSAL

6.2.2 Timetable No Current year + 1 year6.2.3 Class Record Book No Current year + 1 year6.2.4 Mark Books No Current year + 1 year6.2.5 Record of homework set No Current year + 1 year6.2.6 Pupil’s work No Where possible pupils’ work

should be returned to the pupil at the end of the academic years. If this this is

SECURE DISPOSAL

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not the school’s policy then current year + 1

7. EXTRA CURRICULAR ACTIVITIES7.1 Educational Visits outside the Classroom



7.1.1 Records created by schools to obtain approval to run an Educational Visit outside the Classroom

No Outdoor Education Advisers’ Panel National Guidance website http://oeapng.info specifically Section 3 – “Legal Framework and Employer Systems” and Section 4 – “Good Practice”.

Date of visit + 14 years SECURE DISPOSAL

7.1.2 Parental consent forms for school trips where there has been no major incident

Yes Conclusion of the trip Although the consent forms could be retained for DOB + 22 years, the requirement for them being needed is low and most schools do not have the storage capacity to retain every single consent form issued by the school for this period of time.

7.1.3 Parental permission slips for school trips – where there has been a major incident

Yes Limitation Act 1980 (Section 2)

DOB of the pupil involved in the incident + 25 yearsThe permission slips for all the pupils o the trip need to be retained to show that the rules had been followed for all pupils.

7.2 Walking BusBasic File Description Data Protection Issues Statutory Provisions Retention Period Action at the end of the

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http://oeapng.info/

(Operational) administrative life of the record

7.2.1 Walking Bus Registers Yes Date of register + 3 yearsThis takes into account the fact that if there is an incident requiring an accident report the register will be submitted with the accident report and kept for the period of time required for accident reporting.

SECURE DISPOSAL(If these records are retained electronically any backup copies should be destroyed at the same time)

7.3 Family Liaison Officers and Home School Liaison AssistantsBasic File Description Data Protection Issues Statutory Provisions Retention Period


7.3.1 Day Books Yes Current year + 2 years then review

7.3.2 Reports for outside agencies – where the report has been included on the case file created by the outside agency

Yes Whilst child is attending school then destroy

7.3.3 Referral forms Yes While the referral is current7.3.4 Contact data sheets Yes Current year then review, if

contact is no longer active the destroy

7.3.5 Contact Database entries Yes Current year then review, if contact is no longer active the destroy

7.3.6 Group Registers Yes Current year + 2 years

8. CENTRAL GOVERNMENT AND LOCAL AUTHORITY8.1 Local Authority

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8.1.1 Secondary Transfer Sheets (Primary)


8.1.2 Attendance Returns Yes Current year + 1 year SECURE DISPOSAL8.1.3 School Census Returns No Current year + 5 years SECURE DISPOSAL8.1.4 Circulars and other

information sent from the Local Authority

No Operational use SECURE DISPOSAL

8.2 Central GovernmentBasic File Description Data Protection Issues Statutory Provisions Retention Period


8.2.1 OFSTED reports and papers No Life of the report then REVIEW

SECURE DISPOSAL

8.2.2 Returns made to central government


8.2.3 Circulars and other information sent from central government

No Operational use SECURE DISPOSAL

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Privacy Notice (How we use pupil information)

We Collingbourne C of E Primary School are a data controller for the purposes of the Data Protection Act.

The categories of pupil information that we collect, hold and share include:

Personal information (such as name, unique pupil number and address) Characteristics (such as ethnicity, language, nationality, country of birth and free school

meal eligibility) Attendance information (such as sessions attended, number of absences and absence

reasons) Assessment information Relevant medical information Special educational needs information Exclusion records and information Behaviour records and information

Why we collect and use this information

We use the pupil data:

to support pupil learning to monitor and report on pupil progress to provide appropriate pastoral care to assess the quality of our services to comply with the law regarding data sharing

The lawful basis on which we use this information

We collect and use pupil information under the following lawful bases:

Article 6:

Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

Article 9:

The data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject.

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Appendix F

Collecting pupil information

Whilst the majority of pupil information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain pupil information to us or if you have a choice in this.

Storing pupil data

We hold pupil data in line with timescales deatiled in our Retention Schdule, which can be found in our GDPR & Secure Data Handling Policy.

Who we share pupil information with

We routinely share pupil information with:

schools that the pupil’s attend after leaving us our local authority the Department for Education (DfE) The school nurse

Why we share pupil information

We do not share information about our pupils with anyone without consent unless the law and our policies allow us to do so.

We share pupils’ data with the Department for Education (DfE) on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring.

We are required to share information about our pupils with our local authority (LA) and the Department for Education (DfE) under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.

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)

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.

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https://www.gov.uk/education/data-collection-and-censuses-for-schools

https://www.gov.uk/education/data-collection-and-censuses-for-schools

We are required by law, to provide information about our pupils to the DfE as part of statutory data collections such as the school census and early years’ census. Some of this information is then stored in the NPD. The law that allows this is the Education (Information About Individual Pupils) (England) Regulations 2013.

To find out more about the NPD, go to https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information.

The department may share information about our pupils from the NPD with third parties who promote the education or well-being of children in England by:

conducting research or analysis producing statistics providing information, advice or guidance

The Department has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. Decisions on whether DfE releases data to third parties are subject to a strict approval process and based on a detailed assessment of:

who is requesting the data the purpose for which it is required the level and sensitivity of data requested: and the arrangements in place to store and handle the data

To be granted access to pupil information, organisations must comply with strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the department’s data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

For information about which organisations the department has provided pupil information, (and for which project), please visit the following website: https://www.gov.uk/government/publications/national-pupil-database-requests-received

To contact DfE: https://www.gov.uk/contact-dfe

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 Kerry Heath, Admin & Finance Officer and Data Controller for the school.

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https://www.gov.uk/contact-dfe

https://www.gov.uk/government/publications/national-pupil-database-requests-received

https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information

https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information

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 regulations

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

Contact

If you would like to discuss anything in this privacy notice, please contact: Kerry Heath, Admin & Finance Officer and Data Controller for the school.

If you require more information about how the Local Authority (LA) and/or DfE store and use your information, then please go to the following websites:

http://www.wiltshire.gov.uk/privacy

https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

If you are unable to access these websites we can send you a copy of this information. Please contact the LA or DfE as follows:

Pip RabbittsData and Information Sharing Manager Wiltshire CouncilBythesea RoadTrowbridgeBA14 8JNemail: [email protected]

Telephone: 01225 713091

Public Communications UnitDepartment for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT

http://www.education.gov.uk/help/contactusTelephone: 0370 000 2288

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http://www.education.gov.uk/help/contactus

mailto:[email protected]

https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

http://www.wiltshire.gov.uk/privacy

https://ico.org.uk/concerns/

Signed: __________________________________________________ (Headteacher)

This policy was produced in line with guidance from irms.

Link policies: GDPR & Secure Handling E-Safety Business Continuity Plan

Written and Adopted: February 2018Last Review: February 2020Next Review: February 2020

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gdpr & secure data handling policy · web view2020. 10. 21. · the terms, “information”...

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