Privacy Notice (How we use pupil information)
Under the requirements of the General Data Protection Regulation and data protection legislation, Samuel Rhodes School is subject to a variety of obligations as the data controller of personal data (information) about pupils and their parents, carers and families.
Personal data is information that identifies you and your child and is about you and your child. This personal data might be provided to us by you, or provided by someone else (for example another school) or it could be created by the school.
This notice explains what personal data we hold about you and your child, how that information is collected, how we use and may share information about you and your child. Our Data Protection Officer is Claire Mehegan, Grow Education Partners, firstname.lastname@example.org
The categories of pupil information that we process include:
personal identifiers and contacts (such as name, unique pupil number, contact details and address)
characteristics (such as ethnicity, language, and free school meal eligibility)
safeguarding information (such as court orders and professional involvement)
special educational needs (including the needs and ranking)
medical and administration (such as doctors information, child health, dental health, allergies, medication and dietary requirements)
attendance (such as sessions attended, number of absences, absence reasons and any previous schools attended)
assessment and attainment (such as national curriculum assessment results and reports on pupil progress and attainment)
behavioural information (such as exclusions and any relevant alternative provision put in place)
photographs, images, audio/visual recordings and CCTV*
Why we collect and use pupil information
The personal data collected is essential for the school to fulfil its official functions and meet legal requirements.
We collect and use pupil information, for the following purposes:
to support pupil learning and educational provision
to monitor and report on pupil attainment progress
to moderate teacher assessment judgments
to provide appropriate pastoral care and support services
to assess the quality of our services
to keep children safe (food allergies, emergency contact details etc.)
to safeguard children and young people
to reduce the incidence of children missing education
to support children at risk from permanent exclusion
to support primary, secondary and in-year admissions process
to meet the statutory duties placed upon us by the Department for Education
We will not use your child’s personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for that processing.
The lawful basis on which we use this information
In most situations we collect and use pupil information because the processing is necessary for compliance with a legal obligation to which the school, as data controller, is subject, or in the exercise of official authority in our capacity as a school.
In particular, we collect and use personal information under section 537A of the Education Act 1996 and under section 83 of the Children Act 1989, to provide information to the Secretary of State and to carry out tasks in the public interest.
If we need to process ‘special category data’, we rely upon reasons of substantial public interest, for example promoting and securing equality of opportunity and eliminating discrimination. If special category data is processed for any other reason, you will be informed of the additional legal basis for this.
If there is processing or sharing that relies upon your consent, we will make this clear to you and ensure that we seek your consent. You will always be able to withdraw your consent at any time.
Collecting pupil information
We collect pupil information via;
CTF Files (Data files securely transferred between schools on admission).
Pupil data is essential for the schools’ operational use. Whilst the majority of pupil information you provide to us is mandatory, some of it is requested on a voluntary basis. In order to comply with data protection legislations, we will inform you at the point of collection, whether you are required to provide certain pupil information to us or if you have a choice in this and we will tell you what you need to do if you do not want to share this information with us.
Storing pupil data
We will always hold personal information about you and your child securely and in accordance with the law. This is stored electronically on a secure MIS system as well as on paper in student files, which are locked away.
We will retain and delete information in accordance with the School’s Records Management Policy / retention policy and as otherwise required by the General Data Protection Regulation and data protection legislation in force from time to time.
Any CCTV recordings are deleted after 30 days
Who we share pupil information with
We routinely share pupil information with:
schools that the pupils attend after leaving us
our local authority and/or its commissioned providers
the Department for Education (DfE)
the NHS and/or its commissioned providers (i.e. school nurse)
Camden & Islington Public Health and/or its commissioned providers
where the pupil is not resident in Islington, with their respective local authority
Think Forward Organisation
Why we regularly 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.
Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about pupils with our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions; The Department for Education, The pupil’s family and representatives’, Educators and examining bodies, Our regulator Ofsted, Suppliers and service providers – to enable them to provide the service we have contracted them for, central and local government, our auditors
- health authorities
- security organisations
- health and social welfare organisations
- professional advisers and consultants
- police forces, courts, tribunals
- professional bodies
Youth support services
Pupils aged 13+
Once our pupils reach the age of 13, we also pass basic pupil information (name, address and date of birth) to our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.
This enables them to provide services as follows:
youth support services
Any additional information is provided only with opt-in consent from the parent or guardian.
This right is transferred to the child/pupil once he/she reaches the age 16.
Pupils aged 16
We will also share basic information about pupils aged 16+ with our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.
This enables them to provide services as follows:
post-16 education and training providers
youth support services
For more information about services for young people, please visit our local authority website: https://www.islington.gov.uk/children-and-families/young-people
Department for Education
We regularly share pupil data with the Department for Education (DfE) on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring.
The DfE collects personal data from educational settings and local authorities via various statutory data collections. We are required to share information about our pupils with the DfE either directly or via our local authority for the purpose of those data collections, under:
section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.
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.
Requesting access to your personal data
Under GDPR, 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 Barbara McDonagh
Depending on the lawful basis above, you may also have the right to:
object to processing of personal data that is likely to cause, or is causing, damage or distress
prevent processing for the purpose of direct marketing
object to decisions being taken by automated means
in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
a right to seek redress, either through the ICO, or through the courts
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/
For further information on how to request access to personal information held centrally by DfE, please see the ‘How Government uses your data’ section of this notice.
Withdrawal of consent and the right to lodge a complaint
Where we are processing your personal data with your consent, you have the right to withdraw that consent. If you change your mind, or you are unhappy with our use of your personal data, please let us know by contacting Barbara McDonagh via email: email@example.com
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 on 28th July 2021.
If you would like to discuss anything in this privacy notice, please contact: Barbara McDonagh via email: firstname.lastname@example.org
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:
organisations connected with promoting the education or wellbeing of children in England
other government departments and agencies
organisations fighting or identifying crime
For more information about the Department’s NPD data sharing process, please visit:
Organisations fighting or identifying crime may use their legal powers to contact DfE to request access to individual level information relevant to detecting that crime. Whilst numbers fluctuate slightly over time, DfE typically supplies data on around 600 pupils per year to the Home Office and roughly 1 per year to the Police.
For information about which organisations the Department has provided pupil information, (and for which project) or to access a monthly breakdown of data share volumes with Home Office and the Police please visit the following website: https://www.gov.uk/government/publications/dfe-external-data-shares
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