Privacy Policy

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’ to individuals where we are processing their personal data. This privacy notice explains how we collect, store and use personal data about pupils and parents and carers. We, The Consortium Multi Academy Trust are the ‘data controller’ for the purposes of data protection law. Our data protection officer is: Andrew Aalders-Dunthorne, CEO & Principal of The Consortium Multi-Academy Trust who can be contacted at 27 Norwich Road, Halesworth, Suffolk, IP19 8BX or by email at: [email protected].

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 for pupils, parents and other relations as disclosed to us;
  • 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 (where present);

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 and safeguarding
  • Assess the quality of our services
  • Administer admissions waiting lists
  • Carry out research; i.e. Parent surveys, Benchmarking etc

Special considerations for digital learning

The Trust uses google classroom to offer a remote digital learning platform including live and recorded teaching. It is noted that these lessons will capture personal data of teachers and may capture personal data of other stakeholders attending the lesson, but also potentially those that are not attending, for instance, comments made about others during the lessons.

The Consortium Trust, appreciates that additional measures are required due to the Trust’s requirement for staff and pupils to engage in our remote digital learning platform. We note that teaching and learning from home is different to attendance in the classroom, we will at all times act to protect the privacy and personal data of all stakeholders.

This Privacy notice should be read in conjunction with the following Trust Policies:

  • Online Safety;
  • Mobile Devices;
  • Safeguarding;
  • Data Protection (GDPR).

Limitation of purpose: Recorded and live online lessons will not be used to judge competence or used as part of the performance management cycle. As is the case with teaching in the classroom, the Trust cannot guarantee that parental complaints will not be made, however, the Trust will not take into account complaints based on online observations from third parties. Notwithstanding any exceptional circumstances.

Data minimisation: Any recordings should only contain what is adequate, relevant and limited to the subjectmatter being taught and should not contain unnecessary personal information, controversial opinions or comments that may cause offence. We will ensure that data held by the Trust remains professional in nature. All resources and recordings remain the intellectual property of the Trust, until a time that the Trust seeks to legally and legitimately dispose of them.

Storage: The Trust will not retain the recordings for longer than necessary. Lesson recordings that are single use will be held and then deleted within 28 days of the recording. Where a ‘teaching session’ is recorded to be part of a scheme of work may be retained indefinitely – similar to other recorded teaching resources.

Security: In line with the supporting policies as outlined above the Trust will ensure that appropriate security measures are in place to ensure confidentiality, integrity and the appropriate use of materials recorded.

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.

All pupil records are kept securely at all times. Paper records, for example, are kept in lockable storage areas with restricted access, and the contents are secure within the file. Equally, electronic records have appropriate security.

Access arrangements for pupil records ensure that confidentiality is maintained whilst equally enabling information to be shared lawfully and appropriately, and to be accessible for those authorised to see it.

Data sharing

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
  • Central and local government
  • Health authorities
  • Health and social welfare organisations
  • Police forces, courts, tribunals

We do not share information about pupils with any third party without consent unless the law and our policies allow us to do so. This may include but may not be limited to organisations such as follows:-

  • Suppliers and service providers, i.e. Cool Milk, Kittle Photography etc.
  • Financial organisations, i.e. Grant Funding etc (non identifiable data)
  • Charities and voluntary organisations, i.e. Break, Gemstones, Home Start etc
  • Professional advisers and consultants, i.e. Educational Psychologists, Speech & Language etc
  • Professional bodies, i.e. as part of University studies etc (non identifiable data)

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 (if applicable). 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.

Transferring data internationally

Where we are required to 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 anotherorganisation in certain circumstances.

If you would like to make a request please contact our data protection officer.

Academies, including free schools, and independent schools: there is no automatic parental right of access to the educational record in your setting, but you may choose to provide this. Set out your school’s approach, explain whether charges apply, and explain how parents/carers can make a request.

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;

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: Mr Andrew Aalders-Dunthorne, CEO & Prinicpal The Consortium Multi Academy Trust, 27th Norwich Road, Halesworth, Suffolk, IP19 8BX.

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.