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GDPR

Privacy Notice for Parents and Pupils – How we use your information

 

2019/20

Who are we? 

The Holy Family Catholic Multi Academy Company is the ‘data controller’. This means we are responsible for how your personal information is processed and for what purposes. 

 

The Holy Family Catholic Multi Academy Company is registered as the Data Controller with the Information Commissioner’s Office (ICO); Registration Number: ZA317593.

 

You can contact the school as the Data Controller in writing at:

The Holy Family Catholic Multi Academy Company, Kinwarton Road, Alcester. B49 6PX or admin3506@welearn365.com.

 

What is a Privacy Notice? 

A Privacy Notice sets out to individuals how we use any personal information that we hold about them. We are required to publish this information by data protection legislation. This Privacy Notice explains how we process (collect, store, use and share) personal information about our pupils and parents. 

 

What is Personal Information?

Personal information relates to a living individual who can be identified from that information. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. 

 

‘Special category’ personal information relates to personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. 

 

What personal information do we process about pupils and parents?

The pupil and parent information that we collect, hold and share includes:

 

·Personal information including a pupil’s name, date of birth, unique pupil number and home 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.

·Educational information including records of work, assessment results, relevant medical information, details of pupils’ special educational needs, exclusions/behavioural information, specific health and safety risk assessments, first aid slips and accident reports.

· Contact information for parents, carers and other relatives, including telephone numbers, home addresses and e-mail addresses.

·Information about a child’s home life, where required as part of necessary safeguarding and welfare processes.

· Photographs of children, only with written consent from parents and legal guardians.

 

Why do we use personal information? 

We use 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

•               to safeguard pupils 

•               to market the school 

 

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. 

 

What are the legal reasons for us to process your personal information? 

We are required to process personal information in accordance with data protection legislation and only do so when the law allows us to. The lawful reasons we have for processing personal information are as follows: 

1) To comply with the law

We collect and use general purpose pupil information in order to meet certain legal requirements and legal obligations placed upon the school by law.  We therefore are required to this process personal information for such purposes even if you have not consented to us doing so. 

Details of the type of processing that we must undertake, the personal data that is processed, the legislation which requires us to do so and who we may share this information with is set out in Table 1.

If you would like a copy of or further information regarding the statutory authorities that underpin our legal obligations, you should contact the school in writing. 

2) To protect someone’s vital interests

We are able to process personal information when there is an emergency and/or where a person’s life is in danger. 

Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 2.

3) With the consent of the individual to whom that information ‘belongs’ 

Whilst much of the personal information processed is in accordance with a legal requirement, there is some personal information that we can only process when we have your consent to do so. In these circumstances, we will provide you with specific and explicit information regarding the reasons the data is being collected and how the data will be used. 

Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 3.

 4) To perform a public task

It is a day-to-day function of the school to ensure that children receive the education and support they require. Much of this work is not set out directly in any legislation but it is deemed to be necessary in order to ensure that pupils are properly educated and supported 

Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 4.

Special category personal information 

In order to process ‘special category’ data, we must be able to demonstrate how the law allows us to do so. In additional to the lawful reasons above, we must also be satisfied that ONEof the following additional lawful reasons applies: 

1)    Explicit consent of the data subject

2)    Processing relates to personal data which is manifestly made public by the data subject

3)    Necessary for establishing, exercising or defending legal claims

4)    Necessary for reasons of substantial public interest

5)    Necessary for preventive or occupational medicine, or for reasons of public interest in the area of public health

6)    Necessary for archiving, historical research or statistical purposes in the public interest

 

The lawful reasons for each type of special category personal information data that we process is set out in the tables attached. 

 Who might we share your information with? 

We routinely share pupil information with:

 

·      schools that the pupils attend after leaving us

·      our local authority

·      the Department for Education (DfE) 

·      Catholic Education Service

·      Parent Pay

·      Classroom Monitor

·      Evolve (Warwickshire Schools)

·      SIMs

 

We do not share information about our pupils or parents unless the law and our policies allow us to do so. 

 Please refer to the tables for information about what personal information is shared with which specific third parties. 

 

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.

 

What do we do with your information? 

All personal information is held in a manner which is compliant with data protection legislation. Personal information is only processed for the purpose it was collected The school monitors the personal information it processes and will only share personal information with a third party if it has a legal basis to do so (as set out above).  

How long do we keep your information for? 

In retaining personal information, the school complies with the Retention Schedules provided by the Information Record Management Society. The schedules set out the Statutory Provisions under which the school are required to retain the information. 

 

A copy of those schedules can be located using the following link:

http://irms.org.uk/page/SchoolsToolkit

 

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.

What are your rights with respect of your personal information? 

Under data protection law, 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 to have access to your child’s educational record, contact the School Data Protection Officer at Warwickshire Legal Services via email at schooldpo@warwickshire.gov.ukor alternatively; 

School Data Protection Officer

Warwickshire Legal Services 

Warwickshire County Council 

Shire Hall

Market Square

Warwick

CV34 4RL

 

**Please ensure you specify which school your request relates to. 

 

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, 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/

 

Review

The content of this Privacy Notice will be reviewed 25.05.19.

 

Table 1– Personal information we are required to process to comply with the law:

 

Information

Type

Relevant legislation

Special Category– additional lawful reason

Third Parties with whom we share the information

Lawful reason for sharing

Contact details

 

Education (Pupil Registrations England) Regulations 2006, Regulation 4.

The processing is necessary for complying with the law.

LA Admissions, HM Chief Inspector of Education.

Legal Obligation

Characteristics (age, ethnicity, religion etc)

 

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

LA or Secretary of State.

Legal Obligation

Medical conditions

Dietary requirements

 

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

 

Necessary to protect vital interests of data subject or another person where the data subject is physically or legally incapable of giving consent.

Health staff, police or fire crews.

Legal Obligation and Vital Interests.

Special educational needs

 

Education Act 1996, section 317

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

Local Authority

Legal Obligation.

Free school meals/pupil premium/whether they are a looked-after child

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

LA or Secretary of State.

Legal Obligation

Emergency contact details

 

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

 

Necessary to protect vital interests of data subject or another person where the data subject is physically or legally incapable of giving consent.

Health staff, police or fire crews.

Legal Obligation and Vital Interests.

Attendance

 

Education (Pupil Registration) (England) Regulations 2006, Regulation 4.

The processing is necessary for complying with the law.

LA Admissions, HM Chief Inspector of Education.

Legal Obligation

Admissions

Education (Pupil Registration) (England) Regulations 2006, Regulation 4.

The processing is necessary for complying with the law.

LA Admissions, HM Chief Inspector of Education.

Legal Obligation

Exclusion

Education Act 1996, section 51A

The processing is necessary for complying with the law.

LA Admissions, HM Chief Inspector of Education.

Legal Obligation

Safeguarding and promoting welfare of pupils

Education Act 2002, section 175

Children’s Act 1989, section 17

Children’s Act 1989, section 47

Children’s Act 1989, section 83

Children’s Act 1989, section 11

The processing is necessary for complying with the law.

LA

MASH Warks

FAMILY FRONT DOOR (WORCS)

 

Legal Obligation

Academic Results

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

LA

Secretary of State

Public

Legal Obligation

Reports to Parents

Education (information About Individual Pupils) (England) Regulations 2013, Regulation 5.

The processing is necessary for complying with the law.

Transferring to another educational establishment.

Legal Obligation

 

Table 2– Personal information we are required to process as it is necessary to protect someone’s vital interests

 

Information

Type

Special Category - additional lawful reason

Third Parties with whom we share the information

Lawful reason for sharing

Medical conditions

Dietary requirements

 

3

Necessary to protect vital interests of data subject or another person where the data subject is physically or legally incapable of giving consent.

Health staff, police or fire crews.

Vital Interests

 

Safeguarding and promoting welfare of pupils

The processing is necessary for complying with the law.

LA

Multi Agency Safeguarding Hub

Police

Legal Obligation

 

Table 3 - Personal information we are required to process with the consent of the individual to whom that information ‘belongs’

 

Information Type

Special Category - additional lawful reason

Third Parties with whom we share the information

Lawful reason for sharing

Images of pupils

Data subject has given explicit consent.

Primary Site (hosts school website)

Media

Aspens

Consent

Name of Doctor surgery

 

Data subject has given explicit consent.

Multi Agency Safeguarding Hub

 

Consent and Public Task

Contact details

 

Data subject has given explicit consent.

Multi Agency Safeguarding Hub

 

Consent and Public Task

Parents'/carers' bank details

 

Data subject has given explicit consent.

None

Consent and Public Task

Consent forms (photographs, school trips etc)

 

Data subject has given explicit consent.

School Photos Photography

The Stratford Herald, The MidWeek, Evening News The Observer

School Website

Educational Visits (EVOLVE)

Consent and Public Task

 

Table 4 - Personal information we are required to process because it is necessary to do so in order to perform a public task

Information Type

Special Category - additional lawful reason

Third Parties with whom we share the information

Lawful reason for sharing

Name of Doctor surgery

Data subject has given explicit consent.

Multi Agency Safeguarding Hub

Consent and Public Task

Contact details

 

Data subject has given explicit consent.

Multi Agency Safeguarding Hub

 

Consent and Public Task

Parents'/carers' bank details

Data subject has given explicit consent.

None

Consent and Public Task

Consent forms (photographs, school trips etc)

 

Data subject has given explicit consent.

School Photography

The Stratford Herald, The MidWeek, Evening News The Observer

School Website

Educational Visits (EVOLVE)

Consent and Public Task

Behaviour incidents

 

Processing is necessary to perform official functions.

SENDAR/LEA Exclusion. SEN, Round Oak/Children's parents/Multi Agency Safeguarding Hub

Public Task

Accident reports

 

Processing is necessary to perform official functions.

HSE, MASH (Warwickshire),Family front Door (Worcestershire) Parents, Medical Staff.

 

Public Task

In-class app data

 

Processing is necessary to perform official functions.

Ckassroom Monitor

Accelerated Reader

Public Task

Records of interventions provided

 

Processing is necessary to perform official functions.

Another school when pupils transfer. SENDAR, Ed Psych, SEND Reported, Round Oak

Public Task

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