General Data Protection Regulations
From 25 May 2018 new data protection legislation (GDPR) is effective in the UK governing how personal data is protected.
As a School we take the protection of pupil, parent, staff and other community members’ personal data very seriously. We have updated our privacy notices which set out information on what types of personal information are held by the school, what it is used for and who it is shared with. The privacy notices also set out details about what rights you have in relation to your personal data.
The school's Data Protection Officer is:
Mr Gary HIpple, Wandsworth Borough Council firstname.lastname@example.org
How We Use Your Information - Privacy Notice for Pupils/Parents
This notice is to help parents understand how and why Earlsfield Primary School collects your child's personal information and what we do with that information. It also explains the decisions that you can make about your child's information. We are giving you this notice because you are able to exercise your child's data protection rights on their behalf. When your child is older (usually when they reach the age of 13) they will be considered mature enough to exercise their own data protection rights. If you have any questions about this notice please talk to the Headteacher.
What is "personal information"?
Personal information is information that the School holds about your child which identifies your child. This includes information such as their date of birth and address as well as things like exam results, medical details and behaviour records. The School may also record your child's religion or ethnic group. CCTV, photos and video recordings of your child are also personal information.
How and why does the School collect and use personal information?
We set out below examples of the different ways in which we use personal information and where this personal information comes from. Our primary reason for using your child's information is to provide your child with an education. The admissions forms which you complete on entry to the School give us personal information about your child, such as name, proof of address, medical and/or dietary information etc and contact information for parents and carers. We also get information from your child, their teachers and other pupils. Your child's previous school/nursery also gives us information about your child if we need this to teach and care for them. Sometimes we get information from your child's doctor and other professionals where we need this to look after your child.
We collect this information to help the School run properly and safely and to let others know what we do here. Here are some examples
- We need to tell all appropriate members of staff if your child is allergic to something or might need extra help with some tasks.
- We may need to share information about your child's health and wellbeing with the School Nurse or counsellor.
- We may use CCTV to make sure the school site is safe. CCTV is not used in private areas such as changing rooms. CCTV data is overwritten approximately every 30 days although, only in specific circumstances, footage is retained for a longer period to safeguard the children in accordance with our internal policy.
- We may need to report some of your child's information to the government. For example, we may need to tell the local authority that your child attends our school or let them know if we have any concerns about your child's welfare.
- We may need information about any court orders or criminal petitions which relate to your child. This is so that we can safeguard your child's welfare and wellbeing and the other pupils at the school. • Depending on where your child will go when they leave us we may need to provide their information to other schools. For example, we may share information about your child's results and provide references. We may need to pass on information which they need to look after your child.
- We may need to share information with the police or our legal advisers if something goes wrong or to help with an inquiry.
- Occasionally we may use consultants, experts and other advisors to assist the School in fulfilling its obligations and to help run the School properly. We might need to share your child's information with them if this is relevant to their work.
- If your child have misbehaved in a serious way, and the police have become involved, we may need to use information about the action taken by the police.
- We may share some information with our insurance company to make sure that we have the insurance cover that we need.
- We may share your child's academic and (where fair) their behaviour records with you or their education guardian so you can support their schooling.
- We will monitor your child's use of email, the internet and mobile electronic devices at School e.g. iPads. This is to check that your child is not misbehaving when using this technology or putting themselves at risk of harm. If you would like more information about this you can read the acceptable use of IT and email policy or speak to the administration team or School Business Manager
- Sometimes we use photographs and videos for teaching purposes, for example, to highlight an activity in your child’s exercise books or record a particular lesson. We will not include names next to photographs. If you have any concerns about us using photographs or videos of your child please speak to the administration team or School Business Manager
- We publish our public exam results, events and other news on the website and put articles and photographs in the school newsletter and occasionally the local news to tell people about what we have been doing.
- We sometimes use contractors to handle personal information on our behalf. The next section provides some examples.
- IT consultants might access information about your child when checking the security of our IT network; and - we use third party "cloud computing" services to store some information rather than the information being stored on hard drives located on the school site.
We will only share your child's information with other people and organisations when we have a good reason to do so. In exceptional circumstances, we may need to share it more widely than we would normally.
If you have any concerns about the above, please speak to the administration team or School Business Manager. .
Who do we share pupil information with?
We routinely share pupil information with:
The Department for Education. We share pupils’ data with the Department for Education on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring.
- Our local authority. We are required to share information about our pupils with our local authority under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.
- Schools that the pupils attend after leaving us.
- A provider of Education sector-wide software (Capital SIMS) is used by the school which holds all the personal details of every school pupil to assist the school in management of data and reporting.
- The School’s catering company (Edwards and Ward) which holds information on any pupil who has an eating allergy to ensure their safety at lunchtimes.
- Supplier of academic marking, attainment and progress software (Target Tracker) used by the school which holds the name, class and marks for each pupil’s school and home work.
- Supplier of software (Parentmail) is used by the school to facilitate parents paying for school dinners, schoolclubs, school trips and uniforms. It also helps the school communicate with parents by sending texts. It holds the pupil’s name, pupil’s class, parent’s name and telephone number.
- Supplier of software is used by the school to register any incidents which need medical intervention (Medical Tracker). This holds the pupils name, pupil’s class, details of any incident and of any medical intervention supplied and by whom.
- Supplier of safeguarding software (Safeguard) is used by the school to assist the school in managing the safeguarding of pupils’ mental and physical wellbeing on a case by case basis. This holds the name of any pupil for whom a member of staff has a concern.
- Counselling service (Place2Be) which provides support to pupils to cope with emotional and behavioural difficulties.
- Supplier of software used by Governors and senior members of school staff to exchange school information (Basecamp).
- Learning centres and other establishments where the school organises school journeys or trips (Treginnis and Sayers Croft) which may require relevant information on pupils attending.
- Supplier of signing in software (Inventry) which is used for pupils signing in as late arrivals and signing out as early or late ‘collections'.
We use ‘child observation’ software (Tapestry) internally which contains pictures, videos and observations of the children’s work as they access early years curriculum.
The information shared with the above is only as much as they need to achieve the stated purpose agreed with the school. Information accessed on pupils by staff is only as much as they need to fulfil the requirements of their job descriptions with different levels of permissions depending upon the member of staff’s professional requirements.
Our legal grounds for using your information
This section contains information about the legal basis that we are relying on when handling your child’s information.
Public interests This means that the processing of your child’s data is necessary for public interests. The School relies on public interests for most of the ways in which it uses your child’s information. Specifically, the School has a public interest in:
- Providing your child with an education.
- Safeguarding and promoting your child’s welfare and the welfare of other children.
- Promoting the objectives and interests of the School.
- Facilitating the efficient operation of the School.
- Ensuring that all relevant legal obligations of the School are complied with.
Legal obligation Where the School needs to use your child’s information in order to comply with a legal obligation, for example to report a concern about your child’s wellbeing to Children's Services, we may also have to disclose your child’s information to third parties such as the courts, the local authority or the police where legally obliged to do so.
Legitimate interest Personal data may be processed on the basis that the school has a legitimate interest in processing that data, provided that such legitimate interest is not overridden by the rights or freedoms of the child.
The School must also comply with an additional condition where it processes special categories of personal information. These special categories include: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information, health information etc
Vital interests To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.
Legal claims The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.
Collecting Personal Information with consent We may ask for your consent to use your child's information in certain ways which are not otherwise covered by any of the reasons set out above, such as for direct marketing purposes. If we ask for your consent to use your or your child's personal information for these reasons you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please contact the School Business Manager if you would like to withdraw any consent given. Please note the right to withdraw consent does not apply where the School is using your or your child’s information for any of the other reasons set out above, such as where required in order to provide your child with an education (public interest).
Sending information to other countries We may send your child's information to countries which do not have the same level of protection for personal information as there is in the UK. For example, we may store your child's information on cloud computer storage based overseas or communicate with you about your child by email when you are overseas (for example, when you are on holiday).
The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm If the country that we are sending your information to is not on the list or, is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland) then, it might not have the same level of protection for personal information as there is the UK. Where this is the case we will seek additional safeguards from the relevant third parties before supplying them with personal data. If you have any questions about the safeguards that are in place please contact the School Business Manager.
For how long do we keep your child’s information?
We keep your child's information for as long as we need to in order to educate and look after them. We will keep certain information after your child has left the School. In exceptional circumstances, we may keep your child's information for a longer time than usual, but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.
What decisions can you make about your child’s information?
From May 2018 you will be able to make various decisions about your child's information. Some of these are new rights whilst others build on your child's existing rights. Your child's rights are as follows:
- if information is incorrect you can ask us to correct it;
- you can also ask what information we hold about your child and be provided with a copy. We will also give you extra information, such as why we use this information about your child, where it came from and what types of people we have sent it to;
- you can ask us to delete the information that we hold about your child in certain circumstances. For example, where we no longer need the information;
- you can ask us to send you, or another organisation, certain types of information about your child in a format that can be read by computer;
- our use of information about your child may be restricted in some cases. For example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy. We will update the information when you provide revised details.
Further information and guidance
This notice is to explain how we look after your child's personal information. The School Business Manager can answer any questions which you might have. Please speak to The School Business Manager if:
- you object to us using your information for marketing purposes. We will stop using your information for marketing purposes if you tell us not to; or
- you would like us to update the information we hold about your child; or
- you have any concerns about our data processing.
If you consider that we have not acted properly when using your child's personal information you can also contact the Information Commissioner's Office: ico.org.uk