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Trinity

CofE

VA Primary &

Nursery School

Privacy Notice - GDPR

GDPR Data Protection Policy

Privacy notice for parents/carers

Under data protection law, individuals have a right to be informed about how the school uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about pupils.

We, Trinity CofE VA Primary and Nursery School, are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is Karen McNair (see ‘Contact us’ below).

 

The personal data we hold

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

· Contact details, contact preferences, date of birth, identification documents

· Results of internal assessments and externally set tests

· Pupil and curricular records

· Characteristics, such as ethnic background, eligibility for free school meals, or special educational needs

· Exclusion information

· Details of any medical conditions, including physical and mental health

· Attendance information

· 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.

 

Why we use this data

We use this data to:

· Support pupil learning

· Monitor and report on pupil progress

· Provide appropriate pastoral care

· Protect pupil welfare

· Assess the quality of our services

· Administer admissions waiting lists

· Carry out research

· Comply with the law regarding data sharing

 

Our legal basis for using this data

We only collect and use pupils’ 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 pupils’ 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 pupils’ 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 pupils’ personal data overlap, and there may be several grounds which justify our use of this data.

 

Collecting this information

While the majority of information we collect about pupils is mandatory, there is some information that can be provided voluntarily.

Whenever we seek to collect information from you or your child, we make it clear whether providing it is mandatory or optional. If it is mandatory, we will explain the possible consequences of not complying.

 

How we store this data

We keep personal information about pupils while they are attending our school. We may also keep it beyond their attendance at our school if this is necessary in order to comply with our legal obligations. Our record retention policy sets out how long we keep information about pupils.

Record Retention Schedule

Employees should give special consideration to the categories of documents listed in the record retention schedule below. Avoid retaining a record if there is no business reason for doing so, and consult with the Privacy Officer if unsure.

RECORD

RETENTION PERIOD

Personnel Records

Benefits descriptions per employee

7 years

Employee applications and resumes

1 year

Employee offer letters (and other documentation regarding hiring, promotion, demotion, transfer, lay-off, termination or selection for training)

1 year from date of making record or action involved, whichever is later, or 1 year from date of involuntary termination

Records relating to background checks on employees

5 years from when the background check is conducted

Employment contracts; employment and termination agreements

7 years from the date of termination

Employee records with information on expenses and non-salaried pay

5 years

Hazardous material exposures

Indefinitely

Supplemental record for each occupational injury or illness

Indefinitely

Job descriptions, performance goals and reviews; garnishment records

7 years from the date of termination

Employee tax records

7 years from the date tax is due or paid

Medical exams

30 years from the termination of employment

Pension plan and retirement records

Indefinitely

Payroll Records

Payroll registers (gross and net)

Indefinitely

Corporate Records

Articles of Incorporation, Bylaws, Corporate Seal

Indefinitely

Annual corporate filings and reports to secretary of state and attorney general

Indefinitely

Board policies, resolutions, meeting minutes, and committee meeting minutes

Indefinitely

Contracts

14 years from the date of termination

Construction documents

Indefinitely

Emails (business related)

14 years

Fixed Asset Records

Indefinitely

Sales and purchase records

Indefinitely

Resolutions

Indefinitely

Accounting and Finance

Accounts Payable and Receivables ledgers and schedules

7 years

Annual audit reports and financial statements

Permanent

Annual plans and budgets

2 years

Bank statements, cancelled checks, deposit slips

7 years

Business expense records

7 years

Electronic fund transfer documents

7 years

Employee expense reports

7 years

General ledgers

Indefinitely

Journal entries

7 years

Invoices

7 years

Petty cash vouchers

3 years

Legal and Insurance Records

Appraisals

Indefinitely

Environmental studies

Indefinitely

Insurance claims/ applications

Indefinitely

Insurance contracts and policies

Indefinitely

Warranties

Duration of warranty + 7 years

 

Data sharing

We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so.

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

· Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions

· The Department for Education

· The pupil’s family and representatives

· Educators and examining bodies

· Our regulator [specify as appropriate, e.g. Ofsted, Independent Schools Inspectorate]

· Suppliers and service providers – to enable them to provide the service we have contracted them for

· Financial organisations

· Central and local government

· Our auditors

· Survey and research organisations

· Health authorities

· Security organisations

· Health and social welfare organisations

· Professional advisers and consultants

· Charities and voluntary organisations

· Police forces, courts, tribunals

· Professional bodies

 

National Pupil Database

We are required to provide information about pupils to the Department for Education as part of statutory data collections such as the school census and early years census.

Some of this information is then stored in the National Pupil Database (NPD), which is owned and managed by the Department and provides evidence on school performance to inform research.

The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including schools, local authorities and exam boards.

The Department for Education may share information from the NPD with other organisations which promote children’s education or wellbeing in England. Such organisations must agree to strict terms and conditions about how they will use the data.

For more information, see the Department’s webpage on how it collects and shares research data.

You can also contact the Department for Education with any further questions about the NPD.

 

Parents and pupils’ rights regarding personal data

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 12), or where the child has provided consent.

Parents 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 data protection officer.

Parents/carers also have a legal right to access to their child’s educational record. To request access, please contact Karen McNair – Data Protection Officer – admin@trinityprimaryexeter.co.uk

 

Other rights

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.

 

Complaints

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

 

Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection officer:

  • Karen McNair – admin@trinityprimaryexeter.co.uk

This notice is based on the Department for Education’s model privacy notice for pupils, amended for parents and to reflect the way we use data in this school.

 

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