DATA PROTECTION POLICY: PUPILS AND PARENTS 1 Abut this Plicy The privacy f ur pupils and parents is very imprtant t the schl and we have taken steps t prtect it. This plicy explains hw we use (r "prcess") persnal data abut pupils and their parents and yur rights in relatin t yur wn persnal data. Persnal Data means infrmatin which is capable f identifying a living individual. Any reference t pupils includes current, past and prspective pupils and any reference t parents includes current, past and prspective parents, carers r guardians. This plicy applies in additin t the schl's terms and cnditins, and any ther infrmatin the schl may prvide abut a particular use f persnal data. Fr example, the schl's plicy n pupil bimetric infrmatin. Anyne wh wrks fr, r acts n behalf f, the schl (including staff, vlunteers, gvernrs and service prviders) shuld als be aware f and cmply with the schl's data prtectin plicy fr staff, which als prvides further infrmatin abut hw persnal data abut thse individuals will be used. 2 Respnsibility fr Data Prtectin The data cntrller f the persnal data we hld abut yu is Bryanstn Schl Incrprated (r the Schl ) and it is prcessed by us strictly in accrdance with the Data Prtectin Act 1998 ( the Act ). In accrdance with the Act, the schl has ntified the Infrmatin Cmmissiner's Office f its prcessing activities and a cpy f ur entry can be fund at www.ic.gv.uk under registratin number Z6599431. The schl has appinted the Finance Bursar as Data Prtectin Officer ("DPO") wh will endeavur t ensure that all persnal data is prcessed in cmpliance with this plicy and the Act. The DPO s cntact details are in paragraph 14. 3 Types f persnal data prcessed by the schl In rder t carry ut its functins, the schl may prcess a wide range f persnal data abut pupils and parents as part f its peratin, including by way f example: names, addresses, telephne numbers, e-mail addresses and ther cntact details; car details (abut thse wh use ur car parking facilities); bimetric infrmatin, which will be cllected and used by the schl in accrdance with the schl's bimetrics plicy. bank details and ther financial infrmatin, e.g. abut parents wh pay fees t the schl r any ther relevant schl; pupils' academic, disciplinary, admissins and attendance recrds (including infrmatin abut any special needs) and examinatin scripts and marks; where apprpriate, infrmatin abut individuals' health, and cntact details fr their next f kin; references given r received by the schl abut pupils and infrmatin prvided by previus educatinal establishments and/r ther prfessinals r rganisatins wrking with pupils; Authr: Data Prtectin Officer Page 1 f 6
images and in sme cases, vide and audi data, f pupils (and ccasinally ther individuals) engaging in schl activities which will be prcessed in accrdance with paragraph 5 f this plicy belw. data cllected frm mnitring devices. Fr example, clsed-circuit televisin (CCTV) and ther security systems, telephne, email and internet access lgs and recrdings. Generally, the schl receives persnal data frm the individual directly (r, in the case f pupils, frm parents). Hwever in sme cases persnal data may be supplied by third parties (fr example anther schl, r ther prfessinals r authrities wrking with that individual), r cllected frm publicly available resurces. The schl may, frm time t time, need t prcess "sensitive persnal data" regarding individuals. Sensitive persnal data includes infrmatin abut an individual's physical r mental health, race r ethnic rigin, plitical r religius beliefs, sex life, trade unin membership r criminal recrds and prceedings. Sensitive persnal data is entitled t special prtectin under the Act, and will nly be prcessed by the schl with the explicit cnsent f the apprpriate individual r as therwise permitted by the Act. 4 Use f persnal data by the schl The schl will use (and where apprpriate share with third parties) persnal data abut individuals fr a wide variety f peratinal, regulatry and ther purpses, including fr example: Fr the purpses f pupil selectin and t cnfirm the identity f prspective pupils and their parents; T prvide educatin services (including SEN), career services and extra-curricular activities t pupils; mnitring pupils' prgress and educatinal needs; and maintaining relatinships with alumni and the schl cmmunity; Fr the purpses f management planning and frecasting, research and statistical analysis, and t enable the relevant authrities t mnitr the schl's perfrmance; T give and receive pupil infrmatin and references including the prvisin f references t ptential emplyers f past pupils; T supply and receive infrmatin relating t payment histry including details f utstanding fees t/frm any educatinal institutin that the pupil attended r where it is prpsed they attend; T enable pupils t take part in natinal r ther assessments and t publish the results f public examinatins r ther achievements f pupils f the schl; T safeguard pupils' welfare and prvide apprpriate pastral (and where necessary, medical) care, and t take apprpriate actin in the event f an emergency r accident, including by disclsing details f an individual's medical cnditin where it is in the individual's interests t d s, fr example fr medical advice, insurance purpses r t rganisers f schl trips; T mnitr (as apprpriate) use f the schl's IT and cmmunicatins systems in accrdance with the schl's Digital Cmmunicatin Plicy; T use phtgraphs and vide in schl and ther publicatins, n the schl website and (where apprpriate) n the schl's scial media channels. The use f images in this way will be strictly in accrdance with the schl s plicy n use f images; (See paragraph 5 belw). Fr fundraising, marketing r schl prmtinal purpses and t maintain relatinships between the schl cmmunity and alumni, including thrugh ur alumni rganisatins. Use f persnal data fr these purpses will be strictly in accrdance with the schl s plicy n the use f data fr such purpses; (See paragraph 7 belw). Fr security purpses, and fr regulatry and legal purpses (fr example child prtectin and health and safety) and t cmply with its legal bligatins and Authr: Data Prtectin Officer Page 2 f 6
Where therwise reasnably necessary fr the schl's purpses, including t btain apprpriate prfessinal advice, supprt and services including where necessary frm external parties and t btain insurance fr the schl. 5 Use f Phtgraphic Images and Vide by the Schl The schl may prcess phtgraphic images f pupils and where relevant ccasinally thers such as parents r vide in the fllwing ways: Fr the purpse f hlding a digital frmal identity phtgraph f each pupil fr administrative and pastral purpses which d nt include schl publicity. Other pupil images and vide may be held fr pastral care, t supprt teaching and learning and t internally recrd and celebrate pupil achievement. Where yur specific written cnsent* has been prvided the schl may prcess phtgraphic images and vide in the fllwing ways: Fr the purpses f schl prmtinal activity and publicity. Fr example, n the schl s scial netwrking services, the schl website, e-bulletins, newsletters and in printed material such as the schl prspectus. Fr disclsure t third party media (fr example, external jurnalists) fr their wn jurnalistic purpses. *On jining the schl, parents and pupils are invited t indicate whether they cnsent r bject t the use f images and vide fr varius different purpses via a written cnsent frm. Subsequently, preferences may be amended by writing t the schl s DPO using the cntact details in paragraph 14 f this plicy. Any changes made t yur preferences will take effect frm the date we issue ur written acknwledgement f receipt. Where cnsent is withdrawn, we will make reasnable effrts t ensure that the image is nt further used. Hwever, it may nt always be pssible t remve media that has already been published and r circulated. 6 Use f Phtgraphs and Vide by Pupils, Parents and Others Where parents, pupils and thers attend schl perfrmances and sprting events etc. the schl will generally permit reasnable phtgraphy and vide recrding fr purely persnal dmestic purpses. Hwever, in rder t prtect the privacy f everyne, the schl des nt permit the publishing f any phtgraph r vide f children ther than yur wn. This includes publicity n any scial netwrking service r website. The schl s plicy reflects the schl s legal bligatin t prtect the privacy and in sme cases persnal safety f all ur pupils and in recgnitin f the fact that nt all pupils and parents wish t have their image etc. published. This is ur general plicy and may be subject t variatin n a case by case basis. 7 Keeping in tuch and supprting the schl The schl will use the cntact details f parents, alumni and ther members f the schl cmmunity t keep them updated abut the activities f the schl, including by sending updates and newsletters, by email and by pst. Yu can limit r bject t us ding this by writing t the DPA using the cntact details at paragraph 14 belw. In additin, unless the relevant individual bjects, the schl may als: Authr: Data Prtectin Officer Page 3 f 6
Share persnal data abut parents and/r alumni, as apprpriate, with rganisatins set up t help establish and maintain relatinships with the schl cmmunity, such as the Bryanstn Sciety Limited and the varius Old Bryanstnian Assciatins; Cntact parents and/r alumni (including via the rganisatins abve) by pst and email in rder t prmte and raise funds fr the schl and, where apprpriate, ther wrthy causes; Cllect infrmatin frm publicly available surces abut parents' and frmer pupils' ccupatin and activities, in rder t maximise the schl's fundraising ptential. Shuld yu wish t limit r bject t any such use, r wuld like further infrmatin abut them, please cntact the DPO in writing using the cntact details in paragraph 14 f this plicy. 8 Rights f access t persnal data ( Subject Access Request ) Under the Act, pupils and parents each have a right f access t their wn persnal data held by the Schl tgether with ther infrmatin abut the way in which that data is prcessed. This is knwn as the right f subject access. The right f subject access applies subject t the applicatin f legal restrictins. Fr example, yu may nt be able t access infrmatin which is capable f identifying ther peple r infrmatin which is subject t legal privilege (such as legal advice given t the Schl), cnfidential references given by the Schl and cpies f examinatin scripts. Pupils are free t make their wn Subject Access Request if they chse prvided that we think they are sufficiently mature enugh t understand the cnsequences f their request. Generally, pupils that are age 12 r ver are cnsidered t have achieved this level f maturity althugh this will depend upn the individual child, the cntext and the nature f the persnal data which they culd ptentially have access t. We will cnsider each pupil Subject Access Request n an individual basis. A pupil may ask a parent r ther representative t make a Subject Access Request n their behalf. Hwever, generally, we wuld expect a persn with parental respnsibility t make a subject access request n behalf f yunger pupils. Where a parent r ther adult makes a Subject Access Request n behalf f a pupil, the Schl is required t cnsider if the request is in fact being made n behalf f the pupil and if disclsure is in the pupil s best interests. In sme cases, where apprpriate, we may need t discuss the request with the pupil themselves. Subject Access Requests shuld be made in writing t the Schl s DPO using the cntact details in paragraph 14. In sme cases, the Schl may ask fr further infrmatin t cnfirm the identity f the requestr r fr infrmatin t help lcate the infrmatin requested. Requests will be prcessed as quickly as is reasnably practicable and within the statutry time limit f 40 calendar days. The Schl may charge a fee f 10 t prcess a Subject Access Request. 9 Whse Rights The rights under the Act belng t the individual t whm the data relates. Hwever, the schl will in mst cases rely n parental cnsent t prcess persnal data relating t pupils (if cnsent is required under the Act) unless, given the nature f the prcessing in questin, and the pupil's age and understanding, it is mre apprpriate t rely n the pupil's cnsent. Parents shuld be aware that in such situatins they may nt be cnsulted. In general, the schl will assume that pupils cnsent t disclsure f their persnal data t their parents, e.g. fr the purpses f keeping parents infrmed abut the pupil's activities, Authr: Data Prtectin Officer Page 4 f 6
prgress and behaviur, and in the interests f the pupil's welfare, unless, in the schl's pinin, there is a gd reasn t d therwise. Hwever, where a pupil seeks t raise cncerns cnfidentially with a member f staff and expressly withhlds their agreement t their persnal data being disclsed t their parents, the schl will maintain cnfidentiality unless, in the schl's pinin, there is a gd reasn t d therwise; fr example where the schl believes disclsure will be in the best interests f the pupil r ther pupils. Pupils are required t respect the persnal data and privacy f thers and t cmply with the schl's Digital Cmmunicatins Plicy, Anti-Bullying Plicy, Cyber-Bullying Plicy, Behaviur Plicy and the Schl Rules. 10 Data Accuracy and Standards f Handling The law requires the Schl t take apprpriate technical and rganisatinal security measures t prtect persnal data and t prevent its unauthrised r unlawful prcessing r accidental lss, damage r destructin. Accrdingly, the Schl has implemented technical steps t prtect persnal data held bth manually and electrnically and regularly reviews these measures t ensure they are adequate. Organisatinal steps t prtect persnal data include but are nt limited t regular staff training in data prtectin. The Schl als takes steps t ensure that yur persnal data is kept accurate and up t date, is adequate, relevant and nt excessive in relatin t the purpse/s fr which the data is being prcessed. In mst cases, yu have the right t request that any inaccurate infrmatin is erased r crrected and may d s by cntacting the Schl s DPO using the cntact details belw. We endeavr t ensure that infrmatin is nt kept fr lnger than necessary and is deleted as sn as reasnably practicable. Hwever, the Schl may retain sme persnal data s that we can cmply with regulatry r legal bligatins and fr legitimate rganisatinal reasns. 11 Transferring Yur Infrmatin Overseas Occasinally, the schl may need t transfer persnal data verseas including utside the Eurpean Ecnmic Area (EEA) fr the purpses set ut abve. Fr example, t facilitate schl trips utside the EEA r t cmmunicate with parents residing utside the EEA. Where this happens we will ensure that apprpriate safeguards are put in place t prtect yur persnal data. 12 Yur Obligatins In rder t help the Schl t keep its recrds accurate and adequate we need t ensure that they are kept up t date. Yu are required t infrm us f any changes t the persnal data that we hld s that we can amend ur recrds accrdingly. Fr example, please ntify us immediately f any change f address r ther cntact details r any specific medical r health infrmatin. Please ntify changes t yur persnal data t by email t changes@bryanstn.c.uk. 13 Queries and cmplaints Any cmments r queries n this plicy shuld be directed t the DPO using the cntact details belw. Authr: Data Prtectin Officer Page 5 f 6
If an individual believes that the schl has nt cmplied with this plicy r acted therwise than in accrdance with the Act, they shuld utilise the schl cmplaints prcedure and shuld als ntify the DPO. 14 Cntact the Schl s Data Prtectin Officer The schl s DPO can be cntacted using the methds belw. By Pst: The Data Prtectin Officer, Bryanstn Schl, Blandfrd Frum, Drset, DT11 0PX By email: dp@bryanstn.c.uk. Authr: Data Prtectin Officer Page 6 f 6