Data & Privacy

Privacy Notice for Pupils, Parents and Carers

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, Wrotham School, are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is the SPS SPO Services (see ‘Contact us’ below) sps-dpo-services@isystemsintegration.com

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:

• Name
• Contact details, contact preferences, date of birth, identification documents
• Parental, sibling and extended family details
• Children who are adopted from care, looked after children, under special guardianship
• Results of internal assessments and externally set tests
• Pupil and curricular records
• Characteristics, such as ethnic background, language, eligibility for free school meals, Pupil Premium 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
• Photographs of your child
• Carefully chosen and vetted educational apps
• CCTV images

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
• Monitor and report on pupil progress
• Provide appropriate pastoral care
• Protect pupil welfare
• Assess the quality of our services
• Administer admissions waiting lists
• Carry out research
• Comply with the law regarding data sharing

In order to meet statutory requirements around appropriate education provision and to fulfil safeguarding requirements, we share information about school history and the latest known pupil and parent address and contact details in the event of a Child Missing Education, or becoming Electively Home Educated. This information also supports the in-year admissions process.

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.

Whenever we seek to collect information from you or your child, we make it clear whether providing it is mandatory or optional. If it is mandatory, we will explain the possible consequences of not complying.

How we store this data

Children’s records are stored securely in paper files and on the school’s secure server.

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. We will adhere to the Information Management Toolkit for Schools Document.

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. Where it is legally required, or necessary (and it complies with the General Data Protection Regulation, otherwise known as the GDPR) we may share personal information about pupils with:

• Our local authority (e.g. admissions)
• The Department for Education (e.g. attainment)
• The pupil’s family and representatives (e.g. attendance)
• Educators and examining bodies ( e.g. SATS test papers)
• Our regulators Ofsted, DFE and the ESFA (e.g. pupil data)
• Suppliers and service providers (e.g. sports coaches)
• Central and local government (e.g. attainment) Health authorities (e.g. immunisations)
• Health and social welfare organisations (e.g. social services)
• Professional advisers, bodies and consultants (e.g. Educational psychologist)
• Police forces, courts, tribunals (in relation to safeguarding)
• Collaborating schools for moderating purposes

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.

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.

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 12), 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.

Parents/carers of a pupil attending a maintained school also have a legal right to access to their child’s educational record. To request access, please contact Ms Nichola Donovan, Office Manager.

If you require access to the above, please apply in writing, citing your reasons to the Headteacher. Your other rights regarding your data 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 Headteacher.

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 the school in the first instance. To make a complaint, please contact our Headteacher. 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

Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Headteacher in the first instance. Otherwise contact:

• SPS DPO Services at sps-dpo-services@isystemsintegration.com
• SPS SPO Services, iSystems Integration, Devonshire House, 29-31 Elmfield Road, Bromley, Kent BR1 1LT

This notice is based on the Department for Education’s model privacy notice for the school workforce, amended to reflect the way we use data in this school.

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Privacy Notice for Staff

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 individuals we employ, or otherwise engage, to work at our school.

We, Wrotham School, are the ‘data controller’ for the purposes of data protection law. Our data protection officer is the SPS SPO Services (see ‘Contact us’ below). sps-dpo-services@isystemsintegration.com

The personal data we hold

We process data relating to those we employ, or otherwise engage, to work at our school. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

• Name
• Contact details
• Date of birth, marital status and gender
• Next of kin and emergency contact numbers
• Salary, annual leave, pension and benefits information
• Bank account details, payroll records, National Insurance number and tax status information
• Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process
• Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships
• Safeguarding information, DBS number, Disqualification by Association information
• Performance information
• Outcomes of any disciplinary and/or grievance procedures
• Absence data
• Copy of driving license and car registration
• Photographs
• CCTV images We may also collect, store and use information about you that falls into “special categories” of more sensitive personal data. This includes information about (where applicable):
• Race, ethnicity, religious beliefs and sexual orientation
• Health, including any medical conditions, sickness records and disability status

Why we use this data

The purpose of processing this data is to help us run the school, including to:

• Enable you to be paid including necessary deductions
• Facilitate safe recruitment, as part of our safeguarding obligations towards pupils
• Support effective performance management
• Inform our recruitment and retention policies
• Allow better financial modelling and planning
• Enable ethnicity and disability monitoring
• Improve the management of workforce data across the sector
• Support the work of the School Teachers’ Review Body
• To report to the DFE

Our legal basis for using this data

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

• Fulfil a contract we have entered into with you
• Comply with a legal obligation
• Carry out a task in the public interest Less commonly, we may also use personal information about you where:
• You have given us consent to use it in a certain way
• We need to protect your vital interests (or someone else’s interests)

Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so. Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the school’s use of your data.

Collecting this information

While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us. Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.

How we store this data

Staff records are stored securely in paper files and on the school’s secure server. We create and maintain an employment file for each staff member.

The information contained in this file is kept secure and is only used for purposes directly relevant to your employment.

Once your employment with us has ended, we will retain this file and delete the information in it in accordance with the Information and Records Management Society’s toolkit for schools, available on request from the school office.

Data sharing

We do not share information about you with any third party without your consent unless the law and our policies allow us to do so. Where it is legally required, or necessary (and it complies with the General Data Protection Regulation, otherwise known as the GDPR) we may share personal information about you with:

• Our local authority, to meet legal obligation
• The Department for Education, to meet legal obligation
• Your family or representatives with written consent, to protect your vital interests
• Educators and examining bodies, to fulfill a contract
• Our regulator, ESFA, to meet legal obligation
• Suppliers and service providers – to enable them to provide the service we have contracted them for, such as payroll
• Our auditors, to meet legal obligation
• Health authorities, to fulfill a contract
• Health and social welfare organisations, to meet legal obligation such as Riddor reporting
• Professional advisers and consultants, to fulfill a contract
• Police forces, courts, tribunals, to meet legal obligation
• Ofsted, to meet legal obligation

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 the GDPR.

Your rights

How to access personal information we hold about you. Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school holds about them. If you make a subject access request, and if we do hold information about you, 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
• 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

You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like to make a request, please apply in writing, citing your reasons to the Headteacher Your other rights regarding your data Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:

• Object to the use of your personal data if it would cause, or is causing, damage or distress
• Prevent your data being used to send direct marketing
• Object to the use of your personal data for 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 Headteacher.

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

Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Headteacher in the first instance.

• SPS DPO Services at sps-dpo-services@isystemsintegration.com
• SPS SPO Services, iSystems Integration, Devonshire House, 29-31 Elmfield Road, Bromley, Kent BR1 1LT

This notice is based on the Department for Education’s model privacy notice for the school workforce, amended to reflect the way we use data in this school.