Privacy Notice/Subject Access Request
Under data protection law, updated May 2018 in line with GDPR, 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’ to individuals where we are processing their personal data.
This privacy notice explains how we collect, store and use personal data about pupils.
Blessed George Napier, are the ‘data controller’ for the purposes of data protection law. This means the school determines the purposes for which, and the manner in which, any personal data relating to pupils and their families is to be processed.
What personal data do we hold?
Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:
- Contact details, contact preferences, date of birth, identification documents
- Results of internal assessments and externally set tests
- Pupil and curricular records
- Characteristics, such as ethnic background, eligibility for free school meals, or special educational needs
- Exclusion information
- Details of any medical conditions, including physical and mental health
- Attendance information
- Safeguarding information
- Details of any support received, including care packages, plans and support providers
- CCTV images captured in school
- Recordings of live lessons (see our Remote Education Policy for further details)
- Biometrics - identify management/authentication (fingerprint for lunch purchases)
We may also hold data about pupils that we have received from other organisations, including other schools, local authorities and the Department for Education.
What do we use this data for?
We use this data to:
- Support pupil learning
- Monitor and report on pupil progress
- Provide appropriate pastoral care
- Protect pupil welfare and to keep children safe (eg food allergies or emergency contact numbers)
- Assess the quality of our services
- Administer admissions waiting lists
- Carry out research relating to Teaching & Learning
- Comply with the law regarding data sharing
What is our legal basis for using this data?
We collect and use pupil information under Section 537A of the Education Act 1996, Section 83 of the Children Act 1989 and The EU General Data Protection Regulation 2016/79 (GDPR) including Article 6 ‘Lawfulness of processing’ and Article 9 ‘Processing of special categories of personal data’. 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.
How do we store 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 record retention schedule sets out how long we keep information about pupils.
This information can be found in our Data Protection Policy.
Where do we store this data?
Staff, learners and other associates will make use of personal data, both in and outside of the organisation setting. This will include homework, planning, marking, remote learning and collaboration with colleagues. It will also include administration processes and facilities management. We will review the use of suitable technology for remote working and home learning, and ensure that appropriate technical, security and organisational measures are taken. The choice of technologies and processes will take into account our need to respect and protect the rights and freedoms of our staff, learning and the wider community with respect to personal data.
We do not share information about pupils with any third party 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 including, but not limited to:
- Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
- Youth support services (pupils aged 13+)
- The Pope Francis Multi Academy Trust
- Oxfordshire Health NHS Foundation Trust
- The Department for Education and other government bodies
- Our regulator Ofsted
- Suppliers and service providers – to enable them to provide the service we have contracted them for – eg running the VLE. A full list of suppliers and service providers can be found on our website.
For further information please contact the Principal.
National Pupil Database
We are required to provide information about pupils to the Department for Education as part of statutory data collections such as the school census - Regulation 5 of the Education (Information About Individual Pupils) (England) Regulations 2013.
Some of this information is then stored in the National Pupil Database (NPD), which is owned and managed by the Department and provides evidence on school performance to inform research.
The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including schools, local authorities and exam boards.
The Department for Education may share information from the NPD with other organisations which promote children’s education or wellbeing in England. Such organisations must agree to strict terms and conditions about how they will use the data.
For more information, see the Department’s webpage on how it collects and shares research data.
You can also contact the Department for Education with any further questions about the NPD.
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
- Public Health
Public Health Youth Support Services
Pupils aged 13+
Once our pupils reach the age of 13, we also pass pupil information to our local authority (Oxfordshire County Council) 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
- Careers advisers
- NEET (not in education, Employment or training) support
- A parent or guardian can request that only their child’s name, address and date of birth is passed to their local authority or provider of youth support services by informing us. This right is transferred to the child/pupil once he/she reaches the age 16.
Data is securely transferred to the youth support service via Egress. For retention information - see our Records and Retention Policy.
Pupils aged 16+
We will also share certain 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
- Careers advisers
Once our pupils reach the age of 13, we are legally required to pass on certain information about them to Oxfordshire County Council as it has legal responsibilities regarding the education or training of 13-19 year-olds.
This information enables it to provide youth support services, post-16 education and training services, and careers advisers.
Parents/carers, or pupils once aged 16 or over, can contact our data protection officer to request that we only pass the individual’s name, address and date of birth to Oxfordshire County Council.
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
If you want to have access to the data that the school holds about you, you need to make a ‘subject access request’, in writing to the Principal, to gain access to personal information that the school holds about them. The subject is the person that the data refers to.
Personal data about a child belongs to that child, and not the child’s parents or carers. 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 12), or where the school has obtained consent from the child.
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.
Under data protection law, individuals have certain rights (depending on the lawful basis for which the data was collected) 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
- Seek redress, either through the ICO, or through the courts
To exercise any of these rights, please contact our data protection officer.
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: Integra Schools - email: GDPR@integra.co.uk, tel: 01454 865300); https://www.integra.co.uk
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
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, in the first instance please contact the Principal (email: email@example.com. Tel: 01295 264216).
This notice is based on the Department for Education’s model privacy notice for pupils,
amended for parents and to reflect the way we use data in this school.