Privacy Notice

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

 

2018/19

Who are we?

Kenilworth School and Sixth Form is the ‘data controller’. This means we are responsible for how your personal information is processed and for what purposes.

 

Kenilworth School and Sixth Form is registered as the Data Controller with the Information Commissioner’s Office (ICO); Registration Number:  ZA356716

 

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

school@ksnadmin.ksn.org.uk

 

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, post-16 learning information.
  • 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.
  • CCTV images captured in school
  • Photographs

 

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
  • administer admissions waiting lists

 

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:

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 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 [specify as appropriate, e.g. Ofsted, Independent Schools Inspectorate]
  • Suppliers and service providers – to enable them to provide the service we have contracted them for
  • Financial organisations
  • Central and local government
  • Our auditors
  • Survey and research organisations
  • Health authorities
  • Security organisations
  • Health and social welfare organisations
  • Professional advisers and consultants
  • Charities and voluntary organisations
  • Police forces, courts, tribunals
  • Professional bodies

 

 

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 detailed in this document.

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.

For example, with the emergency services.

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.

For example, photographs, health information for school trips and vaccinations.

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.

 

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 ONE of 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:

 

  • 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 [specify as appropriate, e.g. Ofsted, Independent Schools Inspectorate]
  • Suppliers and service providers – to enable them to provide the service we have contracted them for
  • Financial organisations
  • Central and local government
  • Our auditors
  • Survey and research organisations
  • Health authorities
  • Security organisations
  • Health and social welfare organisations
  • Professional advisers and consultants
  • Charities and voluntary organisations
  • Police forces, courts, tribunals
  • Professional bodies
  • Schools that pupils attend after leaving us

 

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

 

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.uk or 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 May 2019.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Privacy Notice for Pupils and Parents

 

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

Pupil full name

 

 

 

 

                               

 

 

 

 

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online payment system

MyMaths online learning

Doddle Suite online learning

GCSE Pod online

PiXL online learning

learning

Junior Librarian

MLS library system

Cashless Catering system

School Counsellor

South Warwickshire Immunisation Team

County Music

Consent of the individual to whom the information ‘belongs’

Class Charts

Other local schools for sports events

SISRA Analytics

Performance of a Public Task

Gender

 

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online payment system

Cashless catering system

South Warwickshire Immunisation Team

MLS library system

County Music

 

Consent of the individual to whom that information ‘belongs’

Class Charts

SISRA Analytics

 

Performance of a public task

Date of Birth

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online payment system

Cashless catering system

South Warwickshire Immunisation Team

MLS library system

 

Consent of the individual to whom that information ‘belongs’

Class Charts

SISRA Analytics

 

Performance of a public task

Home Address

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online payment system

Cashless catering system

South Warwickshire Immunisation Team

 

Consent of the individual to whom that information ‘belongs’

First Language

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Ethnicity

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

National Identity, Country of Birth, Nationality

Education Act 1996 Section 537A

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Religion

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

n/a

Medical staff, hospitals, ambulance and paramedics

Vital Interest

Date of Admission to school

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

 

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Last School attended – name and address

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 5

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

National curriculum year group

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online system

MLS library system

County Music

 

 

Consent of the individual to whom that information ‘belongs’

Class Charts

SISRA Analytics

Performance of a public task

Unique pupil number

Education Act 1996 Section 537A

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Class Charts

SISRA Analytics

Performance of a public task

Eligibility for Free School Meals

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

ParentPay online system

County Music

Consent of the individual to whom that information ‘belongs’

Mode of Travel to School

Education Act 1996 Section 508A

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Proficiency in English

Education Act 1996 Section 537A

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Whether a pupil is looked after and the Local Authority by whom the pupil is looked after

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Where a pupil has been but is no longer looked after, the type of order resulting in them no longer being looked after

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Special Educational Needs status, start date, details of needs and provision

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Details of exclusions: start and end dates, number of sessions, fixed length/permanent, reason for exclusion

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Assessment date – end of key stage 2, 3 and 4

The Education (Pupil Information)(England) Regulations 2005

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

SISRA Analytics

Performance of a public task

Pupil Annual Reports

The Education (Pupil Information) (England) Regulations 2005

n/a

School to which pupil has transferred

Legal Obligation

Attendance records including whether absence was authorised/unauthorised and reason for absence

The Education (Information about Individual Pupils)(England) Regulations 2013, Regulation 3(2)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

SISRA Analytics

Performance of a public task

Parents’ names and addresses

The Education (Pupil Information) (England) Regulations 2006 Regulation 5 (1)(c)

n/a

Local Authority

Department of Education

School to which the pupil has transferred

South Warwickshire Immunisation Team

Legal Obligation

Teachers for communication

County Music

Consent of the individual to whom that information ‘belongs’

Parents’ telephone number (if pupil usually resides with them)

The Education (Pupil Information) (England) Regulations 2006 Regulation 5 (1) (c)

n/a

Local Authority

Department of Education

School to which pupil has transferred

Legal Obligation

Teachers for communication

 

Consent of the individual to whom that information ‘belongs’

Pupil assessment data (Curricular record)

The Education (Pupil Information) (England) Regulations 2005, Regulation 4

n/a

SISRA Analytics

Performance of a public task

 

 

 

 

 

 

Table 2 -  Medical Information including allergies.

Information Type

Special Category – additional lawful reason

Third Parties with whom we share the information

Lawful reason for sharing

Medical information including allergies

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

Emergency Services

Proetection of vital interests

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

Parent mobile telephone number

n/a

ParentPay online payment system

Consent of the individual to whom that information ‘belongs’

Parent email address

n/a

ParentPay online payment system

County Music

Consent of the individual to whom that information ‘belongs’

Pupil Images

n/a

Class Charts

Capita SIMS

Consent of the individual to whom that information ‘belongs’

Parent name, date of birth, National Insurance number

n/a

Local Authority

Consent of the individual to whom that information ‘belongs’

 

 

 

 

 

 

 

 

 

 

 

 

 

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

Names, telephone numbers and addresses of emergency contacts other than parent(s) with whom pupil resides

n/a

Not shared

n/a

Registration Group

n/a

ParentPay Online payment system

Consent of the individual to whom that information ‘belongs’

Child Protection and Safeguarding documentation including concern form and case documentation

n/a

Local Authority

Legal requirement – Children’s Act 1989, sections 17 and 47

Police

Performance of a public task

Special Educational Needs documentation including SEND provision maps, Personal Learning Plans, Education and Healthcare plans, reports from external agencies

n/a

Local Authority

Performance of a public task

Dietary restrictions

n/a

ParentPay online payment system

Consent of the individual to whom that information ‘belongs’

Medical information including allergies

Necessary for preventative or occupational medicine

Warwickshire Health and Wellbeing Service

Consent of the individual to whom that information ‘belongs’