Kineton High School
Privacy Notice for Parents and Pupils – How we use your information
Who are we?
Kineton High School is the ‘data controller’. This means we are responsible for how your personal information is processed and for what purposes.
Kineton High School is registered as the Data Controller with the Information Commissioner’s Office (ICO); Registration Number: Z9879574
You can contact the school as the Data Controller in writing at email@example.com
What is a Privacy Notice?
A Privacy Notice sets out to individuals how we use any personal information that we hold about them. We are required to publish this information by data protection legislation. This Privacy Notice explains how we process (collect, store, use and share) personal information about our pupils and parents.
What is Personal Information?
Personal information relates to a living individual who can be identified from that information. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.
‘Special category’ personal information relates to personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
What personal information do we process about pupils and parents?
The pupil and parent information that we collect, hold and share includes:
- Personal information including a pupil’s name, date of birth, unique pupil number and home address
- Characteristics such as ethnicity, language, nationality, country of birth and free school meal eligibility
- Attendance information such as sessions attended, number of absences and absence reasons.
- Educational information including records of work, assessment results, relevant medical information, details of pupils’ special educational needs, exclusions/behavioural information, post-16 learning information.
- Contact information for parents, carers and other relatives, including telephone numbers, home addresses and e-mail addresses.
- Information about a child’s home life, where required as part of necessary safeguarding and welfare processes.
Why do we use personal information?
We use pupil data:
- to support pupil learning
- to monitor and report on pupil progress
- to provide appropriate pastoral care
- to assess the quality of our services
- to comply with the law regarding data sharing
- to safeguard pupils
Collecting pupil information
Whilst the majority of pupil information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain pupil information to us or if you have a choice in this.
What are the legal reasons for us to process your personal information?
We are required to process personal information in accordance with data protection legislation and only do so when the law allows us to. The lawful reasons we have for processing personal information are as follows:
1) To comply with the law
We collect and use general purpose pupil information in order to meet certain legal requirements and legal obligations placed upon the school by law. We therefore are required to process this personal information for such purposes even if you have not consented to us doing so.
Details of the type of processing that we must undertake, the personal data that is processed, the legislation which requires us to do so and who we may share this information with is set out in Table 1.
If you would like a copy of or further information regarding the statutory authorities that underpin our legal obligations, you should contact the school in writing.
2) To protect someone’s vital interests
We are able to process personal information when there is an emergency and/or where a person’s life is in danger.
Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 2.
3) With the consent of the individual to whom that information ‘belongs’
Whilst much of the personal information processed is in accordance with a legal requirement, there is some personal information that we can only process when we have your consent to do so. In these circumstances, we will provide you with specific and explicit information regarding the reasons the data is being collected and how the data will be used.
Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 3.
4) To perform a public task
It is a day-to-day function of the school to ensure that children receive the education and support they require. Much of this work is not set out directly in any legislation but it is deemed to be necessary in order to ensure that pupils are properly educated and supported
Details of the type of processing that we may undertake on this basis and who we may share that information is set out in Table 4.
Special category personal information
In order to process ‘special category’ data, we must be able to demonstrate how the law allows us to do so. In additional to the lawful reasons above, we must also be satisfied that ONE of the following additional lawful reasons applies:
- Explicit consent of the data subject
- Processing relates to personal data which is manifestly made public by the data subject
- Necessary for establishing, exercising or defending legal claims
- Necessary for reasons of substantial public interest
- Necessary for preventive or occupational medicine, or for reasons of public interest in the area of public health
- Necessary for archiving, historical research or statistical purposes in the public interest
The lawful reasons for each type of special category personal information data that we process is set out in the tables attached.
Who might we share your information with?
We routinely share pupil information with:
- Other schools (eg when pupils move on)
- Warwickshire County Council
- Department for Education
- SEND Support-ed – special needs support
- Kerboodle – modern languages software
- www.mymaths.co.uk – Maths software
- https://integralmaths.org/ – Maths software
- https://www.mangahigh.com/en-gb/ – Maths software
- http://kinetonmathsdepartment.weebly.com/ – Maths website
- SISRA Analytics – pupil achievement analysis
- Prospects – careers advice and guidance
- CJSM – destination data – where pupils move to when they leave KHS
- Hardy’s Yearbook – leavers yearbooks
- Autolib – library software
- PIXL – classroom strategies and resources
- FFT – educational data analysis
- Parentpay – Pupil payments software
- Evolve – educational visits software
- Lifespace – pupil mentoring
- John Hasall – education consultant
- Warwickshire Police
- Vineyard – pupil support
- CLM – collaborative learning manager
- Guy’s Gift – bereavement service
- Barnardo’s – charity
- You Can Flourish – charity
- Army Cadets
- 6th form colleges
- Fostering agency
- LAC Solihull -looked after children
- Learner Registration Service – to obtain exam candidate numbers
- Examination boards
- Local press – Stratford Herald, Leamington Courier, Banbury Guardian – name and photo
- Twitter – name and photo
- Facebook – name and photo
- Webanywhere Ltd – KHS’s website
- Stratford Children’s Team
- Educational visits companies
We do not share information about our pupils or parents unless the law and our policies allow us to do so.
Please refer to the tables for information about what personal information is shared with which specific third parties.
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-collection-and-censuses-for-schools.
What do we do with your information?
All personal information is held in a manner which is compliant with data protection legislation. Personal information is only processed for the purpose it was collected The school monitors the personal information it processes and will only share personal information with a third party if it has a legal basis to do so (as set out above).
How long do we keep your information for?
In retaining personal information, the school complies with the Retention Schedules provided by the Information Record Management Society. The schedules set out the Statutory Provisions under which the school are required to retain the information.
A copy of those schedules can be located using the following link:
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.
What are your rights with respect of your personal information?
Under data protection law, parents and pupils have the right to request access to information about them that we hold. To make a request for your personal information, or to have access to your child’s educational record, contact the School Data Protection Officer at Warwickshire Legal Services via email at firstname.lastname@example.org or alternatively;
School Data Protection Officer
Warwickshire Legal Services
Warwickshire County Council
**Please ensure you specify which school your request relates to.
You also have the right to:
- object to processing of personal data that is likely to cause, or is causing, damage or distress;
- prevent processing for the purpose of direct marketing;
- object to decisions being taken by automated means;
- in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
- claim compensation for damages caused by a breach of the Data Protection regulations
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 or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/
The content of this Privacy Notice will be reviewed May 2019.
Table 1 – Personal information we are required to process to comply with the law:
|Relevant legislation||Special Category– additional lawful reason||Third Parties with whom we share the information||Lawful reason for sharing|
|Admissions Information||Education (Pupil Registration)(England) Regulations 2006, Regulation 4, 10, 11, 14 and 15||OFSTED, Local Authority||Legal Obligation|
|Assessment and achievement data||Education (Pupil Information) (England)Regulations 2005, Regulation 4||OFSTED, schools, colleges, Local Authority||Legal Obligation|
|Attendance records||Education (Pupil Registration)(England) Regulations 2006, Regulation 4, 10, 11 and 12||OFSTED, Local Authority, schools, colleges||Legal Obligation|
|Educational records||Education (Pupil Information) (England)Regulations 2005, Regulation 5 and 6||Parents, schools, colleges||Legal Obligation|
|Medical / dietary / allergies||Necessary for preventative or occupational medicine||Department of Education – school census, schools, colleges||Legal Obligation|
|Pupil information i.e. name, age address, emergency contact details||Education (Information About Individual Pupils) (England) Regulations 2013, Regulation 3 and 5||Department of Education – school census, schools, colleges, Warwickshire Police||Legal Obligation|
|Safeguarding information||Education Act 2002, section 175
Children’s Act 1989, Section 17, 47, 83.
Children’s Act 2004, Section 11
|Local Authority, NHS||Legal Obligation|
|School census||Education Act 1996, Sections 537 & 537A, and accompanying regulations||Department of Education||Legal Obligation|
|SEN information||Children’s and Families Act 2014, section 69||Local Authority, NHS||Legal Obligation|
Table 2 – Personal information we are required to process as it is necessary to protect someone’s vital interests
|Special Category – additional lawful reason||Third Parties with whom we share the information||Lawful reason for sharing|
|Personal, characteristics, attendance, educational, parental contacts, home life
|For preventive or occupational medicine, or for reasons of public interest in the area of public health||NHS
|Religious belief||Necessary to protect vital interests of the data subject or another person where the data subject is physically or legally incapable of giving consent’||NHS
Table 3 – Personal information we are required to process with the consent of the individual to whom that information ‘belongs’
|Information Type||Special Category – additional lawful reason||Third Parties with whom we share the information||Lawful reason for sharing|
|Photographs||Twitter, Facebook, Webanywhere, local press, internal use, Hardy’s Yearbook||Consent – image consent form|
Table 4 – Personal information we are required to process because it is necessary to do so in order to perform a public task
|Information Type||Special Category – additional lawful reason||Third Parties with whom we share the information||Lawful reason for sharing|
|Personal||Educational visits companies(for specific pupils only)||Performing a public task|
|Stratford Children’s Team(for specific pupils only)||Performing a public task|
|Personal||Examination boards||Performing a public task|
|Personal||Learner Registration Service||Performing a public task|
|Personal||LAC Solihull (for specific pupils only)||Performing a public task|
|Fostering agency (for specific pupils only)||Performing a public task|
|Personal||Army Cadets (for specific pupils only)||Performing a public task|
|Personal, parental contacts||You Can Flourish (for specific pupils only)||Performing a public task|
|Personal, attendance, parental contacts||Barnardo’s (for specific pupils only)||Performing a public task|
|Personal, parental contacts||Guy’s Gift – Bereavement service (for specific pupils only)||Performing a public task|
|Personal, educational, attendance, parental contacts||CLM – Collaborative Learning Manager||Performing a public task|
|Personal, attendance, educational||Vineyard (for specific pupils only)||Performing a public task|
|Personal||Kerboodle||Performing a public task|
|Personal||www.mymaths.co.uk||Performing a public task|
|Personal||https://integralmaths.org/||Performing a public task|
|Personal||https://www.mangahigh.com/en-gb/||Performing a public task|
|Personal||http://kinetonmathsdepartment.weebly.com/||Performing a public task|
|Personal, characteristics, educational, attendance||Substantial public interest (equality of opportunity)||SISRA Analytics||Performing a public task|
|Personal, parental contacts, educational||Prospects – Careers Advice and Guidance||Performing a public task|
|Personal, parental contact
|CJSM||Performing a public task|
|Personal||Autolib||Performing a public task|
|Personal||PIXL||Performing a public task|
|Substantial public interest (equality of opportunity)||FFT||Performing a public task|
|Personal, parental contacts||Parentpay||Performing a public task|
|Personal||Evolve||Performing a public task|
|Personal, attendance, educational||Lifespace||Performing a public task|
|Personal, educational, parental contacts||PFM||Performing a public task|