Privacy Policy

Students and Pupils

How we use pupil information

The Eastern Learning Alliance is classed as a ‘Data Controller’ under the General Data Protection Regulation 2016 (GDPR). The Trust is registered with the Information Commissioner’s Office and follows the principles of the GDPR.  This privacy notice covers all schools within the Trust.

We take your privacy seriously and this notice outlines what sort of personal data we collect, why we do this, how long we store it and who we share it with. Access to personal data is only available to those who need it for a specific purpose.

1. The categories of pupil information that we process include:

  • Personal information (such as name, unique pupil number, address, family details and contact information)
  • Characteristics (such as ethnicity, language and free school meal eligibility)
  • Safeguarding information (such as court orders and professional involvement)
  • Special Educational Needs (SEN) information
  • Relevant medical information
  • Attendance information (such as sessions attended, number of absences and absence reasons and previous schools attended)
  • Assessment and Attainment information (Including Post 16)
  • Behavioural/Exclusions information
  • Information to enable educational trips (such as passport details where relevant)
  • Images of pupils through photographs and videos
  • Images of pupils through CCTV at various locations around the site
  • Biometric data points of a fingerprint This list is not exhaustive.

2. Why we collect and use this information

We only collect and use pupils’ personal data when the law or our policies allows us to. We collect and use pupil information, for the following purposes using these lawful bases of the GDPR: 

Purpose of collection and use

Lawful basis for collection of personal data from Article 6 GDPR

Lawful basis for collection of special category personal data from Article 9 GDPR

a) to support pupil learning and improve the teaching & learning process across the

Trust

Article 6 (1)(e) – public task

Article 9 (2)(g) – substantial public interest (for medical and SEN information)

b) to monitor and report on pupil attainment progress

Article 6 (1)(e) – public task

Article 9 (2)(g) – substantial public interest (medical information for exams) 

c) to provide appropriate pastoral care

Article 6 (1)(e) – public task

 

d) to assess the quality of our services

Article 6 (1)(e) – public task

 

e) to keep children safe 

Article 6 (1)(e) – public task

Article 6(1)(c) – legal obligation 

Article 9 (2)(g) – substantial public interest (for Child Protection information)

f) to meet statutory duties placed upon us for DfE data collections

Article 6 (1)(e) – public task

Article 6 (1)(c) – legal obligation

Article 9 (2)(g) – substantial public interest 

g) to enable the use of some of our finance and education systems (including parent payment systems)

Article 6 (1)(e) – public task

Article 6 (1)(a) – consent (for biometric data)

Article 9 (2)(a) – explicit consent

h) to share data for statutory inspections and audit purposes

Article 6 (1)(e) – public task

Article 6 (1)(c) – legal obligation

 

i) for detection/prevention of crime (CCTV footage)

Article 6 (1)(e) – public task

 

j) improving the school environment and for marketing purposes

Article 6 (1)(e) – public task

Article 6 (1)(a) – consent (for photographs and videos)

Article 9 (2)(a) – explicit consent (for photos and videos)

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. 

We also collect and use pupil information under:

  • Education Act 1996 – this information can be found in the guide documents on the following website https://www.gov.uk/education/data-collection-and-censuses-for-schools
  • The Education (Pupil Registration) (England) Regulations
  • The School Standards and Framework Act 1998
  • The School Admissions Regulations 2012
  • Children and Families Act 2014
  • The Special Educational Needs and Disability Regulations 2014
  • The Education (Information about Individual Pupils) (England) Regulations 2013
  • Part 6 of the Schedule to the Education (Independent School Standards) Regulations 2014


3. How we collect Pupil Information

We collect pupil information via registration forms on entry to a school, through the Common Transfer File or by secure file transfer from a previous school.

Pupil data is essential for the schools’ operational use. Whilst the majority of pupil information you provide to us is mandatory, some of it is requested on a voluntary basis. In order to comply with the data protection legislation, we will inform you at the point of collection, whether you are required to provide certain pupil information to us or if you have a choice in this.


4. How we store pupil data

Personal data will be kept secure whilst it is being stored, used and when it is being shared with others. We hold pupil data until the pupil reaches the age of 25 or until they leave the school and their records are transferred. After this time the paper records are securely shredded and the electronic files are deleted. 

CCTV footage is overwritten on a rolling approximately 7 week schedule unless exported for evidential purposes in line with our ICO registered purposes (detection and prevention of crime). Our Data Retention Policy can be viewed on our website.


5. Who we share pupil information with

We routinely share pupil information with:


We share specific pupil information, as necessary, with:

  • School Nurse and Health services
  • Exam Boards
  • Support professionals such as counsellors
  • Travel companies for school trips
  • Companies including SISRA, GL Assessment and PIXL for assessment data comparisons
  • Suppliers including those for photography services, cashless catering systems and parent finance


6. Why we share pupil information

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

We share pupils’ data with the Department for Education (DfE) on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring. We are required to share information about our pupils with the DfE under regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013. 

We share information with the Eastern Learning Alliance to monitor and support pupil progress.


7. Youth support services


7.1 Pupils aged 13+ 

Once our pupils reach the age of 13, we also pass pupil information to our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996. 

This enables them to provide services as follows:

  • youth support services
  • careers advisers


This information is limited to the child’s name, address and date of birth. However where consent is granted, other information relevant to the provision of youth services will be shared. 

Data is securely transferred to the youth support service via a secured method and is securely stored in line with the local authorities retention schedule.


7.2 Pupils aged 16+ 

We will also share certain information about pupils aged 16+ with our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.

This enables them to provide services as follows: 

  • post-16 education and training providers
  • youth support services
  • careers advisers


For more information about services for young people, please visit our local authority website, https://www.cambridgeshire.gov.uk/

8. Department for Education

The Department for Education (DfE) collects personal data from educational settings and local authorities via various statutory data collections. 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. Some of this information is then stored in the National Pupil Database. The law that allows this is Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.

All data is transferred securely and held by the DfE under a combination of software and hardware controls, which meet current government security policy framework.

For more information please see Section 11:‘How Government uses your data’.

9. Requesting access to your personal data

Under data protection legislation, pupils have the right to request access to information about them that we hold. To make a request for your personal information, contact the Data Protection Officer at  Judicium Consulting Limited is contactable via Email:   or by letter to Judicium Consulting Limited, 72 Cannon Street, London, EC4N 6AE

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

10. Contact

If you would like to discuss anything in this privacy notice, please contact:

Data Protection Officer at Judicium Consulting Limited is contactable via Email: or by letter to Judicium Consulting Limited, 72 Cannon Street, London, EC4N 6AE

11. How Government uses your data

The pupil data that we lawfully share with the DfE through data collections:

  • underpins school funding, which is calculated based upon the numbers of children and their characteristics in each school.
  • informs ‘short term’ education policy monitoring and school accountability and intervention (for example, school GCSE results or Pupil Progress measures).
  • supports ‘longer term’ research and monitoring of educational policy (for example how certain subject choices go on to affect education or earnings beyond school).


11.1 Data collection requirements

To find out more about the data collection requirements placed on us by the Department for Education (for example; via the school census) go to https://www.gov.uk/education/data-collectionand-censuses-for-schools  

11.2 The National Pupil Database (NPD)

Much of the data about pupils in England goes on to be held in the National Pupil Database (NPD).

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. 

To find out more about the NPD, go to https://www.gov.uk/government/publications/national-pupildatabase-user-guide-and-supporting-information


11.3. Sharing by the Department

The law allows the Department to share pupils’ personal data with certain third parties, including:

  • schools
  • local authorities
  • researchers
  • organisations connected with promoting the education or wellbeing of children in England
  • other government departments and agencies
  • organisations fighting or identifying crime


For more information about the Department’s NPD data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data 

Organisations fighting or identifying crime may use their legal powers to contact DfE to request access to individual level information relevant to detecting that crime. Whilst numbers fluctuate slightly over time, DfE typically supplies data on around 600 pupils per year to the Home Office and roughly 1 per year to the Police.

For information about which organisations the Department has provided pupil information, (and for which project) or to access a monthly breakdown of data share volumes with Home Office and the Police please visit the following website: https://www.gov.uk/government/publications/dfe-externaldata-shares


11.4 How to find out what personal information DfE hold about you

Under the terms of the Data Protection Act 2018, you are entitled to ask the Department:

  • if they are processing your personal data
  • for a description of the data they hold about you
  • the reasons they’re holding it and any recipient it may be disclosed to
  • for a copy of your personal data and any details of its source


If you want to see the personal data held about you by the Department, you should make a ‘subject access request’.  Further information on how to do this can be found within the Department’s personal information charter that is published at the address: https://www.gov.uk/government/organisations/department-for-education/about/personalinformation-charter

To contact DfE: https://www.gov.uk/contact-dfe 

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