Bignold Primary School collects and uses personal information about staff, pupils, parents and other individuals who come into contact with the school. This information is gathered in order to enable it to provide education and other associated functions. In addition, there may be a legal requirement to collect and use information to ensure that the school complies with its statutory obligations.
Schools have a duty to be registered, as Data Controllers, with the Information Commissioner’s Office (ICO) detailing the information held and its use. These details are then available on the ICO’s website. Schools also have a duty to issue a Fair Processing Notice to all pupils/parents, this summarises the information held on pupils, why it is held and the other parties to whom it may be passed on.
This policy should be read with reference to the articles of the UN Convention on the Rights of the Child. The Convention states what countries must do to ensure ALL children grow as healthy as possible, can learn at school, are protected, have their views listened to and our treated fairly. Article 1, 2 and 3 apply to all of our policies.
This policy has particular reference to Article 16: Every child has the right to privacy. The law should protect the child’s private, family and home life and Article 36: Government must protect children from all forms of bad treatment
This policy is intended to ensure that personal information is dealt with correctly and securely and in accordance with the Data Protection Act 1998, and other related legislation. It will apply to information regardless of the way it is collected, used, recorded, stored and destroyed, and irrespective of whether it is held in paper files or electronically.
All staff involved with the collection, processing and disclosure of personal data will be aware of their duties and responsibilities by adhering to these guidelines.
What is Personal Information?
Personal information or data is defined as data which relates to a living individual who can be identified from that data, or other information held.
Data Protection Principles
The Data Protection Act 1998 establishes eight enforceable principles that must be adhered to at all times:
- Personal data shall be processed fairly and lawfully;
- Personal data shall be obtained only for one or more specified and lawful purposes;
- Personal data shall be adequate, relevant and not excessive;
- Personal data shall be accurate and where necessary, kept up to date;
- Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose or those purposes;
- Personal data shall be processed in accordance with the rights of data subjects under the Data Protection Act 1998;
- Personal data shall be kept secure i.e. protected by an appropriate degree of security;
- Personal data shall not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of data protection.
The school is committed to maintaining the above principles at all times. Therefore the school will:
- Inform individuals why the information is being collected when it is collected.
- Inform individuals when their information is shared, and why and with whom it was shared.
- Check the quality and the accuracy of the information it holds.
- Ensure that information is not retained for longer than is necessary.
- Ensure that when obsolete information is destroyed that it is done so appropriately and securely.
- Ensure that clear and robust safeguards are in place to protect personal information from loss, theft and unauthorised disclosure, irrespective of the format in which it is recorded.
- Share information with others only when it is legally appropriate to do so.
- Set out procedures to ensure compliance with the duty to respond to requests for access to personal information, known as Subject Access Requests.
- Ensure our staff are aware of and understand our policies and procedures.
Security of information
We are committed to keeping all information safe and secure and follow the principals outlined below.
All users of information systems are to be provided with a summary of the information security policy.
- All users of information systems must manage the creation, storage, amendment, copying, archiving and disposal of information in a manner which safeguards and protects its confidentiality, integrity and availability.
- Any username and password or any other access credential shall be used in accordance with the E Safety Policy.
- All users must ensure they comply with school and site security especially during out of school hours.
- It is recognized that mobile computing is a normal part of school business. However, this entails additional risk and users must take additional precautions.
- Users who do work using equipment outside the school and/or remove data from the school must be aware of the additional risks and take appropriate steps to mitigate them. See more information in the E Safety Policy.
- Users of mobile computing equipment must adhere to the E Safety Policy.
- Users must take all steps to mitigate the risks associated with the environment or third party equipment they may use while engaged in mobile or off site working.
- Areas and offices which contain sensitive or personal information shall be given an appropriate level of physical security and access control, including protection from unauthorised access, and, for high criticality systems, protection from environmental hazards and electrical power failures.
- Duties and areas of responsibility, appropriate to the criticality of the system, shall be segregated to reduce the risk, and consequential impact, of information security incidents.
- Procedures will be established and widely communicated to report security incidents, data protection breaches and suspected security weaknesses in the school’s systems. Mechanisms shall be in place to monitor and learn from those incidents. Anonymous reporting is allowed where it is in line with the school’s whistleblowing policy.
- Procedures will be established to report software malfunctions and faults in the high criticality systems. Faults and malfunctions shall be logged and monitored and timely corrective action taken
Complaints will be dealt with in accordance with the school’s complaints policy. Complaints relating to information handling may be referred to the Information Commissioner (the statutory regulator).
This policy will be reviewed as it is deemed appropriate, but no less frequently than every 2 years. The policy review will be undertaken by the Headteacher, or nominated representative.
If you have any enquires in relation to this policy, please contact the Headteacher (firstname.lastname@example.org) who will also act as the contact point for any subject access requests.
Further advice and information is available from the Information Commissioner’s Office, www.ico.gov.uk or telephone 01625 545745 3