Personal data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:  

• Personal information such as name, student number, date of birth, gender and contact information
• Emergency contact and family lifestyle information such as names, relationships, phone numbers and emails as well as contact preferences,
• Identification documents
• Results of internal assessments and externally set tests
• Pupil and curricular records
• Characteristics, such as ethnic background, nationality, language, county of birth, eligibility for free school meals, or special educational needs
• Behavioural information including exclusions.
• Details of any medical conditions, including physical, mental health and special educational needs and disabilities
• Attendance information such as sessions attended, number of absences and reasons for absence.
• Financial details such as proof of earnings when applying for free school meals
• Destination of pupils after they have left us
• Safeguarding information
• Details of any support received, including care packages, plans and support providers
• Photographs
• CCTV images captured in school

We may also hold data about pupils that we have received from other organisations, including other schools, local authorities and the Department for Education.

We use this data to:

• Support pupil learning
• Inform decisions such as the funding of schools.
• Enable pupils to take part in assessments & to publish & record the results
• Monitor and report on pupil progress
• Provide appropriate pastoral care
• Protect pupil welfare – safeguarding, health & safety, diversity monitoring
• Assess the quality of our services
• Administer admissions waiting lists
• Carry out research
• Comply with the law regarding data sharing

We only collect and use 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  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Where we have obtained consent to use  personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.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  personal data overlap, and there may be several grounds which justify our use of this data.

While the majority of information we collect about our children and their families is mandatory, there is some information that can be provided voluntarily.

In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain information to us or if you have a choice in this.

We keep all personal information secure electronically (via use of password and limited user privileges) and/or it is stored securing in locked filing cabinets/cupboard. For more information, see the Data Security Policy.

We keep personal information about pupils and families while they are attending our school and/or Startwell centre. We may also keep it beyond their attendance if this is necessary in order to comply with our legal obligations. Our Retention Schedule Policy sets out how long we keep information.

A copy of our retention schedule can be obtained on request.

We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so. We only ever provide the limited information requested. There are strict controls on who can see your information and we will not share your data if you have advised us that you do not want it shared unless it’s the only way we can make sure you stay safe and healthy or we are legally required to do so.

Where it is legally required, or necessary (and it complies with data protection law) we may share personal information with:

• Local Authority
• The NHS
• Pupil’s destinations upon leaving school including the relevant LA
• Ofsted
• Police forces, courts, tribunals
• Our school counsellor
• Health authorities
• Tess team
• Educational Psychology Service
• IT provider
• Central and local government
• Professional education advisers and consultants
• Educators and examining bodies & other professional bodies
• Legal Teams

• Professional bodies

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 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

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.

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 13), or where the child has provided consent.

Parents and their families 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.

If you would like to make a request please contact our DPO.

Parents/carers also have a legal right to access to their child’s educational record. To request access, this can be carried out under a subject access request by contacting the Data Protection Officer.

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 data protection officer.

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

We reserve the right to update this privacy notice at any time and we will notify you of the new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Data Protection Officer:

• Mrs Joanne Buckley – coo@epworthtrust.org.uk