Under data protection law, individuals have a right to be informed about how the school uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about pupils.

We, Epworth Trust, are the ‘data controller’ for the purposes of data protection law.

The data protection officer for Epworth Trust is Joanne Buckley.

 

The personal data we hold

Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:  

• Personal information such as name, student number, date of birth, gender and contact information
• Emergency contact and family lifestyle information such as names, relationships, phone numbers and emails as well as contact preferences,
• Identification documents
• Results of internal assessments and externally set tests
• Pupil and curricular records
• Characteristics, such as ethnic background, nationality, language, county of birth, eligibility for free school meals, or special educational needs
• Behavioural information including exclusions.
• Details of any medical conditions, including physical, mental health and special educational needs and disabilities
• Attendance information such as sessions attended, number of absences and reasons for absence.
• Financial details such as proof of earnings when applying for free school meals
• Destination of pupils after they have left us
• Safeguarding information
• Details of any support received, including care packages, plans and support providers
• Photographs
• CCTV images captured in school

We may also hold data about pupils that we have received from other organisations, including other schools, local authorities and the Department for Education.

Why we use this data

We use this data to:

• Support pupil learning
• Inform decisions such as the funding of schools.
• Enable pupils to take part in assessments & to publish & record the results
• Monitor and report on pupil progress
• Provide appropriate pastoral care
• Protect pupil welfare – safeguarding, health & safety, diversity monitoring
• Assess the quality of our services
• Administer admissions waiting lists
• Carry out research
• Comply with the law regarding data sharing

Our legal basis for using this data:

We only collect and use pupils’ personal data when the law allows us to. Most commonly, we process it where:

• We need to comply with a legal obligation
• We need it to perform an official task in the public interest

Less commonly, we may also process pupils’ personal data in situations where:

• We have obtained consent to use it in a certain way
• We need to protect the individual’s vital interests (or someone else’s interests)

Where we have obtained consent to use pupils’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.

Some of the reasons listed above for collecting and using pupils’ personal data overlap, and there may be several grounds which justify our use of this data.

Collecting this information:

While the majority of information we collect about pupils is mandatory, there is some information that can be provided voluntarily.

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.

How we store this data:

We keep all personal information about pupils secure electronically (via use of password and limited user privileges) and/or it is stored securing in locked filing cabinets/cupboard. For more information, see the Data Security Policy.

How long to do you keep this data:

We keep personal information about pupils while they are attending our school. We may also keep it beyond their attendance at our school if this is necessary in order to comply with our legal obligations. Our Retention Schedule Policy sets out how long we keep information about pupils.

A copy of our retention schedule can be obtained on request.

Data sharing:

We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so. We only ever provide the limited information requested. There are strict controls on who can see your information and we will not share your data if you have advised us that you do not want it shared unless it’s the only way we can make sure you stay safe and healthy or we are legally required 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:

• Professional bodies

 

National Pupil Database:

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.

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

Transferring data internationally:

Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.

Parents and pupils’ rights regarding personal data:

Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school holds about them.

Parents/carers can make a request with respect to their child’s data where the child is not considered mature enough to understand their rights over their own data (usually under the age of 13), or where the child has provided consent.

Parents also have the right to make a subject access request with respect to any personal data the school holds about them.

If you make a subject access request, and if we do hold information about you or your child, we will:

• Give you a description of it
• Tell you why we are holding and processing it, and how long we will keep it for
• Explain where we got it from, if not from you or your child
• Tell you who it has been, or will be, shared with
• Let you know whether any automated decision-making is being applied to the data, and any consequences of this
• Give you a copy of the information in an intelligible form

Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request please contact our Trust Business Manager.

Parents/carers also have a legal right to access to their child’s educational record. To request access, this can be carried out under a subject access request by contacting the Data Protection Officer.

Other rights

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:

• Object to the use of personal data if it would cause, or is causing, damage or distress
• Prevent it being used to send direct marketing
• Object to decisions being taken by automated means (by a computer or machine, rather than by a person)
• In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
• Claim compensation for damages caused by a breach of the data protection regulations

To exercise any of these rights, please contact our data protection officer.

Complaints:

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our data protection officer.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

• Report a concern online at https://ico.org.uk/concerns/
• Call 0303 123 1113
• Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Changes to this Privacy notice:

We reserve the right to update this privacy notice at any time and we will notify you of the new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Contact us:

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Data Protection Officer:

• Mrs Joanne Buckley – coo@epworthtrust.org.uk