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, Blessed William Howard Catholic High School, are the ‘data controller’ for the purposes of data protection law. Our data protection officer is Mrs Baskeyfield (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
- Exclusion information
- Attendance information
- CCTV images captured in school
Special categories of data that we may collect, use, store and share (when appropriate) about pupils includes, but is not restricted to:
- Characteristics, such as religious beliefs, ethnic background, eligibility for free school meals, or special educational needs
- Details of any medical conditions, including physical and mental health
- Safeguarding information
- Details of any support received, including care packages, plans and support providers
- Biometric information (used for secure entry to Sixth Form building, processed under Article 9 (2) a, where ‘the subject has given explicit consent to the processing of those personal data for one or more specified purposes’)
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
- To meet the statutory duties placed upon us by the Department for Education
Our legal basis for using this data
We collect and use pupil information under Article 6 GDPR (1) e ‘Public Task’ https://gdpr-info.eu/art-6-gdpr/. This is because we need to process personal data in order to:
- Carry out a task in the public interest
- Exercise our official authority
Blessed William Howard can process data for our school to run properly, and to fulfil our official functions as set out in law.
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)
Article 6(1)(f) ‘Legitimate interests’ https://gdpr-info.eu/art-6-gdpr/
This gives us a lawful basis for processing where:
- “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
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.
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 Data Protection and Information Security Policy explains that the College uses the Information and Records Management Society’s toolkit for school, which sets out how long we keep information about pupils: https://irms.org.uk/page/SchoolsToolkit
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, e.g. Ofsted
- 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
From time to time the school is required to pass on some of this data to local authorities, the Department for Education (DfE), and to agencies that are prescribed by law, such as Ofsted, the Department of Health (DH), and Primary Care Trusts (PCT). All these are data controllers for the information they receive. The data must only be used for specific purposes allowed by law.
The Local Authority (LA) uses information about children for whom it provides services to carry out specific functions for which it is responsible, for example, the assessment of any special educational needs the child may have and careers advice. It also uses the information to derive statistics to inform decisions on, for example, the funding of schools, and to assess the performance of schools and set targets for them. The statistics are used in such a way that individual children cannot be identified from them. We may be required to share information about our pupils with the local authority to ensure that they can conduct their statutory duties under the Schools Admission Code, including conducting Fair Access Panels. For further information please see or contact:
Information Governance Unit, Staffordshire County Council, St Chad’s Place, Stafford, ST16 2LR.
The Qualifications and Curriculum Development Agency (QCDA) uses information about pupils to administer the national curriculum assessments portfolio throughout Key Stages 1 to 3. This includes both assessments required by statute and those that are optional. The results of these are passed on to DfE to compile statistics on trends and patterns in levels of achievement. The QCDA uses the information to evaluate the effectiveness of the national curriculum and the associated assessment arrangements, and to ensure that these are continually improved. For further information please see or contact:
Data Protection Officer, Qualifications and Curriculum Development Agency, 53-55 Butts Road, Earlsdon Park, Coventry CV1 3BH
Ofsted uses information about the progress and performance of pupils to help inspectors evaluate the work of schools, to assist schools in their self-evaluation, and as part of Ofsted’s assessment of the effectiveness of education initiatives and policy. Ofsted also uses information about the views of children and young people to inform children’s services inspections in local authority areas. Inspection reports do not identify individual pupils. For further information please see or contact:
Data Protection Officer, Aviation House, 125 Kingsway, London WC2B 6SE
Primary Care Trusts (PCT) use information about pupils for research and statistical purposes, to monitor the performance of local health services and to evaluate and develop them. The statistics are used in such a way that individual pupils cannot be identified from them. Information on the height and weight of individual pupils may however be provided to the child and its parents and this will require the PCTs to maintain details of pupils’ names for this purpose for a period designated by the Department of Health following the weighing and measuring process. PCTs may also provide individual schools and LAs with aggregate information on pupils’ height and weight. For further information please see or contact:
The Department of Health (DH) uses aggregate information (at school year group level) about pupils' height and weight for research and statistical purposes, to inform, influence and improve health policy and to monitor the performance of the health service as a whole. The DH will base performance management discussions with Strategic Health Authorities on aggregate information about pupils attending schools in the PCT areas to help focus local resources. The Department of Health will also provide aggregate PCT level data to the Healthcare Commission for performance assessment of the health service. For further information please see or contact:
Data Protection Officer at Skipton House 80 London Road London SE1 6LH
The Department for Education (DfE) uses information about pupils for research and statistical purposes to inform, influence and improve education policy and to monitor the performance of the education service as a whole. The DfE will feedback to LAs and schools information about their pupils for a variety of purposes that will include data checking exercises, use in self-evaluation analyses and where information is missing because it was not passed on by a former school. The DfE will also provide Ofsted with pupil data for use in school inspection. Where relevant, pupil information may also be shared with post-16 learning institutions to minimise the administrative burden on application for a course and to aid the preparation of learning plans. Pupil information may be matched with other data sources that the Department holds in order to model and monitor pupils’ educational progression; and to provide comprehensive information back to LAs and learning institutions to support their day to day business. The DfE may also use contact details from these sources to obtain samples for statistical surveys. These surveys may be carried out by research agencies working under contract to the Department and participation in such surveys is usually voluntary. The Department may also match data from these sources to data obtained from statistical surveys.
Pupil data may also be shared with other government departments and agencies (including the Office for National Statistics) for statistical or research purposes only. In all these cases the matching will require that individualised data is used in the processing operation, but that data will not be processed in such a way that it supports measures or decisions relating to particular individuals or identifies individuals in any results. This data sharing will be approved and controlled by the Department’s Chief Statistician. The DfE may also disclose individual pupil information to independent researchers into the educational achievements of pupils who have a legitimate need for it for their research, but each case will be determined on its merits and subject to the approval of the Department’s Chief Statistician. For further information please see or contact:
Data Protection Officer, DfE, Sanctuary Buildings, Great Smith Street, London, SW1P 3BT
National Pupil Database
We are required to provide information about you to the Department for Education (a government department) as part of data collections such as the school census.
Some of this information is then stored in the National Pupil Database, which is managed by the Department for Education and provides evidence on how schools are performing. This, in turn, supports research.
The database is held electronically so it can easily be turned into statistics. The information it holds is collected securely from schools, local authorities, exam boards and others.
The Department for Education may share information from the database with other organisations which promote children’s education or wellbeing in England. These organisations must agree to strict terms and conditions about how they will use your data.
You can find more information about this on the Department for Education’s webpage on how it collects and shares research data.
You can also contact the Department for Education if you have any questions about the database.
Youth support services
Once our pupils reach the age of 13, we are legally required to pass on certain information about them to Staffordshire youth support services, as it has legal responsibilities regarding the education or training of 13-19 year-olds. This information enables it to provide youth support services, post-16 education and training services, and careers advisers. Parents/carers, or pupils once aged 16 or over, can contact our data protection officer to request that we only pass the individual’s name, address and date of birth to Staffordshire youth support services.
Transferring data internationally
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.
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 lead, who will liaise with 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 lead.
Withdrawal of Consent & Complaints
Where we are processing your personal data with your consent, you have the right to withdraw that consent. If you change your mind, or you are unhappy with our use of your personal data, please let us know by contacting. 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 directly.
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
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our data protection lead:Mrs Baskeyfield
Telephone: 01538 493777
Write to: Painsley Catholic Academy, Station Road, Cheadle, ST10 1LH