Privacy Notice, Data Protection and Financial Information
ROSEHILL INFANT & NURSERY SCHOOL
Key Worker Information
In order to comply with the Government’s guidance with regard to shutting schools and providing places for key worker children, it is necessary for us to collect and manage data about these children and their parents/carers in a different way.
Our standard GDPR policy applies, and information found on our privacy notices relating to staff, parents and of course pupils will apply in all cases.
We will use the information that relates to key workers in order to ensure that those children who are entitled to a place at school whilst schools are officially closed are correctly processed, managed and safeguarded.
The Data Controller continues to take its obligations to data processing seriously and will ensure that appropriate safeguards and measures are in place.
Data Protection and the GDPR – January 2021
As the UK transitional arrangements expired on 31 December 2020, there are some practical changes for Data Protection and the GDPR.
To comply with the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 please note that every policy, notice and procedural guide that refers to ‘GDPR’ shall now be read as ‘UK GDPR’.
The rights, responsibilities and data protection that the Data Protection Act 2018 and the GDPR are not changed. Our procedures and arrangements will not change.
If you have any queries please e-mail Helen Kelk, Head Teacher at head@rosehill.derby.sch.uk
Rosehill Nursery & Infant School
Privacy Notice – Pupil Data
Introduction
As a school we collect a significant amount of information about our pupils. This notice explains why we collect the information, how we use it, the type of information we collect and our lawful reasons to do so.
Why do we collect data?
We collect and use pupil data to:-
- Fulfil our statutory obligations to safeguard and protect children and vulnerable people
- Enable targeted, personalised learning for pupils
- Manage behaviour and effective discipline
- Monitor our effectiveness
- Comply with our legal and public obligations to share data
- Support pupils to fulfil their potential
- Keep pupils, parents and carers informed about school events and school news
Our Legal Obligations
We must make sure that information we collect and use about pupils is in line with the GDPR and Data Protection Act. This means that we must have a lawful reason to collect the data, and that if we share that with another organisation or individual we must have a legal basis to do so.
The lawful basis for schools to collect information comes from a variety of sources, such as the Education Act 1996, Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013, Article 6 and Article 9 of the GDPR.
The Department for Education and Local Authorities require us to collect certain information and report back to them. This is called a ‘public task’ and is recognised in law as it is necessary to provide the information.
With regards to infectious diseases such as Covid-19 we have a statutory and regulatory expectation that we support the wellbeing of pupils and staff. The legal basis set out by NHS England is that we may be required to share data so consent may not be required. However, our first response, where possible will be to make contact with individuals directly ourselves to manage information sharing. In some cases we may be required to provide information to a particular service such as Public Health England and we have a public duty to do so.
We also have obligations to collect data about children who are at risk of suffering harm, and to share that with other agencies who have a responsibility to safeguard children, such as the police and social care.
We also share information about pupils who may need or have an Education Health and Care Plan (or Statement of Special Educational Needs). Medical teams have access to some information about pupils, either by agreement or because the law says we must share that information, for example school nurses may visit the school.
Sharing Information
Other services, organisations and people we may share information with include:-
· schools or Academies that the students attend after leaving us (transition portals for the transfer of pupil data)
· relevant local authority/(ies)
· youth support services (students aged 13+)
· the Department for Education (DfE)
· the NHS as required
· School nursing service
· Parent/Carer
· Suppliers and service providers
· Health professionals
· Health & Social Welfare organisations
· Professional bodies
· Charities and voluntary organisations
· Auditors
· Survey & research organisations
· Social Care Organisations
· Police forces and Court services
- Suppliers of software and apps that are used in school
We must keep up to date information about parents and carers for emergency contacts.
The infant to junior transition portal will only retain data for as long as is necessary for the needs of transferring student date to allow successful school transitions.
How we use the data
In school we also use various third party tools to make sure that pupils best interests are advanced. We also record details about progress, attainment and pupil development to support future planning and learning.
We use software to track progress and attainment.
We use data to manage and monitor pastoral needs and attendance/absences so that suitable strategies can be planned if required.
Financial software to manage school budgets may include some basic pupil data. We use software to track progress and attainment.
Data can be used to monitor school effectiveness, the impact of intervention and learning styles across groups of pupils as well as individual children.
We may use consultants, experts and other advisors to assist the school in fulfilling its obligations and to help run the School properly. We might need to share pupil information with them if this is relevant to their work.
We also use contact information to keep pupils, parents, carers up to date about school events.
What type of data is collected?
The DfE and government require us to collect a lot of data by law, so that they can monitor and support schools more widely, as well as checking on individual schools effectiveness.
The categories of pupil information that the school collects, holds and shares include the following:
Personal information – such as but not limited to, name, unique pupil number, feeder and destination school, telephone numbers and addresses
Characteristics – such as but not limited to ethnicity, language, nationality, country of birth and free school meal eligibility
Attendance information – such as but not limited to attendance percentages, number of absences and absence reasons
Assessment information – such as but not limited to national curriculum assessment results
Relevant medical information and social care
Information relating to SEND and health needs
Behavioural information – such as but not limited to number of temporary exclusions
Safeguarding information (such as, but not limited to, involvement of other agencies)
CCTV, photos and video recordings are also personal information.
The following personal data will be held for users of the Transition Portal:
Personal information (such as name, job title, email address, employment, IP address, Session IDs)
Interactions between Transition Portal Users and School Transition Limited, such as support tickets raised or queries made with our support team
Information collected automatically relating to the Transition Portal to include information eg a user’s IP address, device type, unique device identification numbers and login information, browser-type and version, time zone setting, operating system and platform, broad geographic location (e.g. country or city-level location) and other such technical information
Data will only be retained for as long as is necessary for the purpose of transition. Following confirmation that the transition process is complete the data will be securely deleted.
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.
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 pupil information we share with the department, for the purpose of data collections, go to https://www.gov.uk/education/data-collection-and-censuses-for-schools.
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
Requesting access to your personal data
Under data protection legislation, 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 Helen Kelk, Headteacher head@rosehill.derby.sch.uk or Lisa Hopwell, School Business Manager, lisa.hopwell@rosehill.derby.sch.uk
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/
Contact:
If you would like to discuss anything in this privacy notice, please contact Lisa Hopwell, School Business Manager, lisa.hopwell@rosehill.derby.sch.uk
More information about Data Protection and Our Policies
How we manage the data and our responsibilities to look after and share data is explained in our Data protection Policy, and connected policies, which are also available on our website.
If you feel that data about your child is not accurate, or no longer needed please contact the schools office. Our complaints policy explains what to do if there is a dispute. Subject Access Requests are dealt with by the specific policy on the website.
Privacy Notice – Coronavirus - Track and Trace
Responding to the Coronavirus advice from the Government is an obligation on all schools in England.
The development of the NHS ‘Track and Trace’ scheme is a key part of the government plan to manage Coronavirus.
As more pupils are returning to our schools, the safety and wellbeing of pupils, staff and their families is a priority.
Planning to manage a safe return is in place, however our responsibility extends beyond the school gates.
We hold a lot of data, and it may be necessary for us to share that data on request from NHS Track and Trace workers.
We will do this and will play our part in making this process as effective as possible.
It is likely that we will be asked to provide contact details if a case of Coronavirus or a suspected case arises in our school.
There is an obligation to support the government planning. We will provide details as requested to do this.
We will be sharing data on the basis that this is a Public Duty (see below) and that in the case of any health data it is necessary for the public interest, as set out.
Please be assured that we will keep a record of information that we share.
This Privacy Notice should be read in alongside the other GDPR and Data Protection on our website.
If you have any questions please contact the school office.
NHS Test and Trace and the law
The law on protecting personally identifiable information, known as the General Data Protection Regulation (GDPR), allows Public Health England to use the personal information collected by NHS Test and Trace.
The section of the GDPR that applies is:
Article 6(1)(e) ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’
As information about health is a special category of personal information, a further section of the GDPR applies:
Article 9(2)(i) ‘processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare’
Public Health England also has special permission from the Secretary of State for Health and Social Care to use personally identifiable information without people’s consent where this is in the public interest. This is known as ‘Section 251’ approval and includes the use of the information collected by NHS Test and Trace to help protect the public from coronavirus. The part of the law that applies here is Section 251 of the National Health Service Act 2006 and the associated Health Service (Control of Patient Information) Regulations 2002.
Rosehill Infant & Nursery school
Privacy Notice School Workforce
This privacy notice explains how we collect, process and manage information for the school workforce. That includes employed members of staff, volunteers, including trustees and governors, trainee teachers, apprentices and work experience/workplace placements.
The categories of school workforce information that we collect, process, hold and share include:
- personal information (such as name, employee or teacher number, national insurance number)
- special categories of data including characteristics information such as gender, age, ethnic group
- contract information (such as start dates, hours worked, post, roles and salary information)
- work absence information (such as number of absences and reasons)
- qualifications (and, where relevant, subjects taught)
- medical information
- other personal information
- references
We use and share information to comply with statutory, regulatory, practice and contractual obligations. These may include, but are not limited to:-
- improving the management of workforce data across the sector
- enabling development of a comprehensive picture of the workforce and how it is deployed
- pay salaries and pension contributions
- informing the development of recruitment and retention policies
- allowing better financial modelling and planning
- enabling ethnicity and disability monitoring
- supporting the work of the School Teachers’ Review Body
- comply with guidance such as ‘Working Together’ and safeguarding obligations
- facilitating good governance
- internal reviews and quality monitoring
- CPD and staffing issues
If we are required to comply with other legal obligations not listed above we will share data only when it is lawful to do so.
The lawful basis on which we collect and process this information
We must make sure that information we collect and use about pupils is in line with the GDPR and Data Protection Act. This means that we must have a lawful reason to collect the data, and that if we share that with another organisation or individual we must have a legal basis to do so.
The lawful basis for schools to collecting and processing information comes from a variety of sources, such as the Article 6 and Article 9 of the GDPR, the Safeguarding of Vulnerable Groups Act 2006. We also have obligations to organisations such as HMRC and the Department of Work and Pensions.
Collecting this information
Whilst the majority of information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with data protection legislation, we will inform you whether you are required to provide certain school workforce information to us or if you have a choice in this.
Storing this information
We hold school workforce data for in accordance with our HR and Retention Policy
Who we share this information with
We may share this information with organisations such as:
- Our local authority
- The Department for Education (DfE)
- Safeguarding and protection for children and vulnerable adults
- Payroll services
- Financial services
- Legal Advisers
- Insurance providers
- HMRC
- Teacher Pension Scheme and the Local Government Pension Scheme (and other pension providers
- Health professionals
Why we share school workforce information
We do not share information about workforce members with anyone without consent unless the law and our policies allow us to do so.
Local authority
We are required to share information about our workforce members with our local authority (LA) under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and amendments.
Department for Education (DfE)
We share personal data with the Department for Education (DfE) on a statutory basis. This data sharing underpins workforce policy monitoring, evaluation, and links to school funding / expenditure and the assessment educational attainment.
We are required to share information about our school employees with our local authority (LA) and the Department for Education (DfE) under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and amendments.
Data collection requirements
The DfE collects and processes personal data relating to those employed by schools (including Multi Academy Trusts) and local authorities that work in state funded schools (including all maintained schools, all academies and free schools and all special schools including Pupil Referral Units and Alternative Provision). All state funded schools are required to make a census submission because it is a statutory return under sections 113 and 114 of the Education Act 2005
To find out more about the data collection requirements placed on us by the Department for Education including the data that we share with them, go to https://www.gov.uk/education/data-collection-and-censuses-for-schools.
The department may share information about school employees with third parties who promote the education or well-being of children or the effective deployment of school staff in England by:
- conducting research or analysis
- producing statistics
- providing information, advice or guidance
The department has robust processes in place to ensure that the confidentiality of personal data is maintained and there are stringent controls in place regarding access to it and its use. Decisions on whether DfE releases personal 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 securely store and handle the data
To be granted access to school workforce information, organisations must comply with its 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
To contact the department: https://www.gov.uk/contact-dfe
Requesting access to your personal data
Under data protection legislation, you have the right to request access to information about you that we hold. To make a request for your personal information, contact Helen Kelk, Head Teacher, head@rosehill.derby.sch.uk, Lisa Hopwell, School Business Manager, lisa.hopwell@rosehill.derby.sch.uk or J A Walker, DPO Officer, Solicitor, john.walker@phplaw.co.uk
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
More details about how we use and manage data can be found in the ‘Data Processing Notices – Common Principles and Processes’, the Data protection Policy and other relevant polices for the School Workforce on the website.
Paper copies of any of the information held on our website can be provided upon request via the School Office.
Privacy Notices
Useful forms and guidance
Financial Information
There are NO £100,000 plus salaries at our school
For information on income and expenditure please follow the link below: