DATA PROTECTION POLICY FOR PUPILS AND PARENTS This Plicy is relevant t the whle schl including EYFS Cntents 1.0 Intrductin 2.0 Respnsibility fr data prtectin 3.0 Types f persnal data prcessed by the schl 4.0 Use f persnal data by the schl 5.0 Keeping in tuch & supprting the schl 6.0 Rights f access t persnal data 7.0 Whse rights? 8.0 Data accuracy and security 9.0 Queries and Cmplaints 1.0 Intrductin This plicy is intended t prvide infrmatin abut hw the schl will use (r "prcess") persnal data abut individuals including current, past and prspective pupils; and their parents, carers r guardians (referred t in this plicy as "parents"). It 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, including e.g. the schl's plicy n taking, string and using images f children. 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. RESPONSIBILITY FOR DATA PROTECTION In accrdance with the Data Prtectin Act 1998 ('the Act'), the schl has ntified the Infrmatin Cmmissiner's Office f its prcessing activities. The schl's ICO registratin number is Z1745766 and its registered address is Brambling Huse, Hady Hill, Chesterfield, Derbyshire S41 0EF. The Schl has appinted The CEO as Data Prtectin Officer ("DPO") wh will endeavur t ensure that all persnal data is prcessed in cmpliance with this plicy and the Act. 1
3.0 TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL The schl may prcess a wide range f persnal data abut individuals including current, past and prspective pupils and their 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; bank details and ther financial infrmatin, e.g. abut parents wh pay fees t the schl; past, present and prspective 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; and images f pupils (and ccasinally ther individuals) engaging in schl activities, and images captured by the schl's CCTV system (in accrdance with the schl's plicy n taking, string and using images f children); 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, 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. 4.0 USE OF PERSONAL DATA BY THE SCHOOL The schl will use (and where apprpriate share with third parties) persnal data abut individuals fr a number f purpses as part f its peratins, including as fllws: 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 extracurricular 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 infrmatin and references abut past, current and prspective pupils, including relating t utstanding fees r payment histry, t/frm any educatinal institutin that the pupil attended r where it is prpsed they attend; and t prvide references t ptential emplyers f past pupils; 2
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 IT: acceptable use plicy; T make use f phtgraphic images f pupils in schl publicatins, n the schl website in accrdance with the schl's plicy n taking, string and using images f children; 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 Where therwise reasnably necessary fr the schl's purpses, including t btain apprpriate prfessinal advice and insurance fr the schl. 5.0 KEEPING IN TOUCH AND SUPPORTING THE SCHOOL 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. Unless the relevant individual bjects, the schl may als: 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 PTA. Cntact parents and/r alumni, including via the PTA, by pst and email in rder t prmte and raise funds fr the schl. Shuld yu wish t limit r bject t any such use, r wuld like further infrmatin abut them, please cntact the DPO in writing. 6.0 RIGHTS OF ACCESS TO PERSONAL DATA ("SUBJECT ACCESS REQUEST") Individuals have the right under the Act t access t persnal data abut them held by the schl, subject t certain exemptins and limitatins set ut in the Act. Any individual wishing t access their persnal data shuld put their request in writing t the DPO. The schl will endeavur t respnd t any such written requests (knwn as "subject access requests") as sn as is reasnably practicable and in any event within statutry time-limits. Yu shuld be aware that certain data is exempt frm the right f access under the Act. This may include infrmatin which identifies ther individuals, r infrmatin which is subject t legal prfessinal privilege. The schl is als nt required t disclse any pupil examinatin scripts (thugh examiners' cmments may fall t be disclsed), nr any reference given by the schl fr the purpses f the educatin, training r emplyment f any individual. Pupils can make subject access requests fr their wn persnal data, prvided that, in the reasnable pinin f the schl, they have sufficient maturity t understand the request they are making. Pupils aged 13 r ver are generally assumed t have 3
this level f maturity, althugh this will depend n bth the child and the persnal data requested. All subject access requests frm pupils will therefre be cnsidered n a case by case basis. A persn with parental respnsibility will generally be expected t make a subject access request n behalf f yunger pupils. A pupil f any age may ask a parent r ther representative t make a subject access request n his/her behalf. 7.0 WHOSE 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, 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 plicy n pupils use f IT and ther electrnic equipment and the schl rules. 8.0 DATA ACCURACY AND SECURITY The schl will endeavur t ensure that all persnal data held in relatin t an individual is as up t date and accurate as pssible. Individuals must ntify the DPO f any changes t infrmatin held abut them. An individual has the right t request that inaccurate infrmatin abut them is erased r crrected (subject t certain exemptins and limitatins under the Act) and may d s by cntacting the DPO in writing. The schl will take apprpriate technical and rganisatinal steps t ensure the security f persnal data abut individuals. All staff will be made aware f this plicy and their duties under the Act. 9.0 QUERIES AND COMPLAINTS Any cmments r queries n this plicy shuld be directed t the DPO using the e- mail address kspiby@spsp.rg.uk r via telephne n 01246 278522. 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/grievance prcedure and shuld als ntify the DPO. 4
Plicy last reviewed March 2018 Next Review March 2019 Review initiated by CEO 5