Privacy Notice

Under data protection law, individuals have a right to be informed about how Barncroft Primary School uses any personal data that we hold about them. This Privacy Notice explains how we collect this information, how we store and process the information and informs you about the decisions you can make concerning any personal data we hold relating to pupils and their families. Barncroft Primary School are the “data controller” for the purposes of data protection law.

What is personal information?

Information that identifies you as an individual and relates to you is personal information. This can include but is not limited to contact details, photos, financial information and CCTV recordings.

The categories of personal information that we collect, hold and share include:

• Personal information (such as name, unique pupil number and 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) and exclusions
• Modes of travel
• Exclusions information (such as start date, number of days, category, reason and correspondence to parents)
• Assessment information (in year and end of key stage assessment scores/grades for each subject)
• Special Educational Need information (such as provision, needs, placements, payments, medical information, care information)
• Medical information (such as medical need, GP contact data, specialist contact details, dietary requirements)
• School history (such as previous school name, dates attended)
• Contact information (Address, Telephone number, email address)
• Parent/Carer information (such as name, address, contact details)
• Emergency contact information (such as name, address, contact details)
• Birth Certificate (verification of parental responsibility under GDPR)

CCTV (images captured on cameras located around the school. Signs clearly display CCTV cameras are operating.)

Why do we collect and use personal information?

We collect and use personal information:

• to support pupil learning
• to monitor and report on pupil progress
• to provide appropriate pastoral care
• to provide a service for parents and children
• to assess the quality of our services and how well our school is doing
• to comply with the law regarding data sharing
• to safeguard children
• to verify parental responsibility
• to support teaching and learning
• to meet statutory duties placed upon us for DfE data collections
• to carry out research
• to communicate with parents

The General Data Protection Regulation allows us to collect and use pupil information with consent of the data subject, where we are complying with a legal requirement, where pro-cessing is necessary to protect the vital interests of a data subject or another person and where 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. When the personal information is Special Category Information we may rely on processing being in the substantial public interest in addition to consent of the data subject and the vital interests of the data subject or another.

Our requirement for this data and our legal basis for processing this data includes the Education Act 1996, 2002 and 2011, The Children’s Act 1989 and 2004, Education and Skills Act 2008, Schools Standards and Framework Act 1998 and the Equalities Act 2010.

The lawful basis on which we use this information

Personal information will only be collected and used with your consent or where it is needed by the school or the local authority to comply with a legal obligation. For example, the Education Act 1999, which requires the collection of pupil data for school census purposes. Barncroft Primary School also process personal information under the following:

We collect personal data on the following legal basis (Article 6, GDPR):

• Article 6(1)(a) Consent of the data subject.
• Article 6(1)(b) Necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
• Article 6(1)(c) Necessary for compliance with a legal obligation.
• Article 6(1)(d) Necessary to protect the vital interests (life) of a data subject or another person.

Article 6 (1)(e) Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

We collect Special Category Data on the following legal basis (Article 9, GDPR):

• Article 9(2)(a) the data subject has given explicit consent to the processing of those personal data
• Article 9(2)(b) Necessary to meet obligations under employment, social security or social protection law, or a collective agreement.
• Article 9(2)(c) processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
• Article 9(2)(e) processing relates to personal data which are manifestly made public by the data subject;
• Article 9(2)(f) For the establishment, exercise or defence of legal claims or court judicial capacity.
• Article 9(2)(g) processing is necessary for reasons of substantial public interest
• Article 9(2)(j) processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
• The Children’s Act 1989 and 2004
• Education Act 1996, 2002 and 2011
• Health and Safety at Work Act 2015
• Limitation Act 1980
• Equality Act 2010
• The Disability Discrimination Act 2004
• Special Educational Needs (SEN) Code of Practice 2015
• Keeping Children Safe in Education
• Schools Standards and Framework 1998
• Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.
• And any subsequent amendments to the above

Collecting personal information

Whilst the majority of personal 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 personal information to us or if you have a choice in this. Where we are using your personal information only on the basis of your permission you may ask us to stop processing this personal information at any time.

Storing personal data

In accordance with GDPR, the school does not store personal data indefinitely; we hold pupil data for / in accordance with the Hampshire Schools Retention Schedule.

Who do we share pupil information with?

We routinely share pupil information with:

• Relevant staff within the school
• Public Health England e.g. in regard to contagious diseases
• Schools that the pupil’s attend after leaving us
• Our local authority
• Other local authorities if they have responsibility for a child such as SEN/LAC
• The Department for Education (DfE)
• Daily attendance will be shared with DfE and the Hampshire Local Authority’s commissioned service called ‘Welfare Call Ltd’ for all Looked After Children attending this school.
• The School Nursing Team
• NHS (Occupational Therapist, SALT, Physiotherapy)
• Health Professionals (CAMHS, Children’s Therapy Service, MABS, Educational Psychologist)
• Pupil and family support services (MASH, Young Carers, EMAS)
• Ofsted
• Police Force, courts
• Professional bodies

We also share personal information for administrative/research purposes with third parties:

• Rocket Computer Services (IT support and safety)
• Tucasi (financial management of payments for school dinners/Breakfast & After School Clubs/visits/pupil sales & Parents’ Evening bookings)

• HC3S (online catering company)
• Arbor (hosted support for the school’s information management system)
• ESS (formerly Capita)
• Cool Milk (supplies milk only with parental consent)
• Yellow Photographers (to process the photographing of pupils)
• Bikeability (Year 5/6 study funded by Department for Transport with parental consent)
• Evolve (online risk assessment for education visits)
• CPOMS
• Sign In App
• FFT Aspire (Fischer Family Trust) (Attendance, Assessment & Statutory Assessment data, Pupil tracking)
• Wonde (data extraction software from MIS to provide up to date information for DfE, Times Table Rockstars, ASSET For Schools, Tucasi, Sign In App, FFT Aspire Data Exchange)

Online/additional services to support your child’s learning:

• Tapestry (only with parental consent – an online journal recording children’s learning with parental input)
• Times Table Rockstars (sequenced programme of daily times tables practice)
• Libresoft Library Management (Harrap Computer Systems Ltd)
• Reception Baseline
• Ruth Miskin Literacy (Read Write Inc. Phonics)
• Oxford Owl (Phonics)
• Residential organisations/educational visit providers who require additional information for risk assessments
• Oxford Reading Buddy (online reading programme)

CPOMS

CPOMS is an online evidence based safeguarding programme developed specifically for schools for improving processes for managing child protection, safeguarding, inclusion, SEN, student welfare and other situations where security and data protection is paramount.

Why we share pupil information

Barncroft Primary School will not share information about our pupils with anyone without consent unless the law and our policies allow us to do so. We share pupils’ data with the Department for Education (DfE) on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring.

We are required to share information about our pupils with our local authority (LA) and the Department for Education (DfE) under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.

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. 

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 the school office on 02392 482331 or via admin@barncroftprimary.hants.sch.uk

You also have the right, subject to some limitations 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 Mrs Karen Tyrell, Data Protection Officer, via the school office on 02392 482331 or via admin@barncroftprimary.hants.sch.uk