Privacy Notice

Copnor Primary School Privacy Notice (How we use pupil information)

Under the General Data Protection Regulations Copnor Primary School is the data controller for any personal information held by us.   This Privacy Notice explains why we collect this information, how we process the information and informs you about the decisions you can make concerning any personal data we hold relating to pupils and their families.

We collect personal data on the following legal basis (Article 6, GDPR):

            Compliance with a legal obligation
            Protection of vital interests
            Public Task

We collect Special Category Data on the following legal basis (Article 9, GDPR):

           To protect vital interests of the data subject and if consent is not feasible

What is personal information?

Information that identifies you as an individual and relates to you is personal information.  This can include but is not limited to contact details, photos, financial information and CCTV recordings.

Why do we collect and use pupil information?

We use the 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 and how well our school is doing
• to comply with the law regarding data sharing
• to safeguard children
• to verify parental responsibility
• to support teaching and learning
• to communicate with parents

The lawful basis on which we use this information

Personal information will only be collected and used with your consent or where it is needed by the school or the local authority to comply with a legal obligation. For example, the Education Act 1999, which requires the collection of pupil data for school census purposes.  Copnor Primary School also process personal information under the following:

Article 6 (GDPR): Processing is necessary for compliance with a legal obligation to which the data controller is subject.

Article 9 (GDPR): For substantial public interest on legal basis.

The Children’s Act 1989

Education Act 1996, 2002 and 2011

Equality Act 2010

Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.

The categories of pupil information that we collect, hold and share include:

• Personal information (such as name, unique pupil number, address, photographs)
• Characteristics (such as ethnicity, language, free school meal eligibility)
• Attendance information (such as sessions attended, number of absences and absence reasons)
• Exclusions information (such as start date, number of days, category, reason and correspondence to parents)
• Assessment information (in year and end of key stage assessment scores/grades for each subject)
• Special Educational Need information (such as provision, needs, placements, payments, medical information, care information)
• Medical information (such as medical need, GP contact data, specialist contact details, dietary requirements)
• School history (such as previous school name, dates attended)
• Contact information (Address, Telephone number, email address)
• Parent/Carer information (such as name, address, contact details)
• Emergency contact information (such as name, address, contact details)
• Birth Certificate (verification of parental responsibility under GDPR)
• CCTV (images processed for safeguarding purposes)

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.

Storing pupil data

In accordance with GDPR, the school does not store personal data indefinitely;  we hold pupil data for as long as is necessary and in order to complete the task for which it was originally collected and in keeping with our retention schedule.

Who do we share pupil information with?

We routinely share pupil information with:

• Schools that the pupil’s attend after leaving us
• Our local authority
• Other local authorities if they have responsibility for a child such as SEN/LAC
• the Department for Education (DfE) 
• Daily attendance will be shared with the Portsmouth Local Authority's commissioned service called 'Welfare Call Ltd' for all Portsmouth Looked After Children attending this school.
• The School Nursing Team
• NHS (Occupational Therapist, SALT, Physiotherapy)
• Health Professionals (CAMHS, Children’s Therapy Service, MABS, Educational Psychologist)
• Pupil and family support services (MASH, Young Carers, EMAS)

We also share personal information for administrative/research purposes with third parties:

• Teachers2parents (providing text/email communication service)
• Rocket (IT support and safety)
• Vis-IT Ed (our visitor/pupil/staff entry system)
• Tucasi (financial management of payments for visits/trips)
• ISS (Feeding Hungry Minds - online catering company)
• 3BM (support the school’s information management system)
• Cool Milk (supply Reception children with milk only with parental consent)
• Yellow Photographers ( to process the photographing of pupils)
• Bikeability (Year 5/6 study funded by Department for Transport with parental consent)

Online/additional services to support your child’s learning:

• 2 Simple/Purple Mash
• Tapestry (Reception children only with parental consent)
• Times Table Rockstars
• Third Space Learning (with parental consent)
• Portsmouth in the Community
• Libresoft Library Management (Harrap Computer Systems Ltd)
• MarvellousMe

Libresoft Library Management is used within school to enable children to issue and return library books through scanning barcodes on school books.  The school will provide Libresoft with the minimal amount of personal data needed to operate this system (pupil’s surname, forename, registration group, year group). This data will be provided once consent has been received by the person with parental responsibility, and parents may opt out of this agreement at any time by contacting the school office.

Pupil’s personal details may be edited or deleted by the School Librarian, and Harrap Computer Systems Ltd will permanently delete all leavers upon request from the school. Harrap are registered with the ICO.  For further information please click on the following link http://libresoft.co.uk/privacy/

MarvellousMe is a web based app that will allow teachers to communicate with parents. It will not go in to any detail but will permit teachers to send an icon, or an icon with a very short text message with information regarding pupils’ achievements.  The school will provide MarvellousMe with the minimal amount of personal data needed for parents’ to access the app (pupil’s first and last name, UPN, registration groups, curriculum year)  .   This data will only be given once parental consent has been received.  Parents may opt out of this service at any time by contacting the school office.

Data is retained for the minimum duration necessary and will be destroyed within 90 days at the end of the contract. Upon request, personal details may be edited or deleted by the school administrator or MarvellousMe.  You can find out more about the app at https://marvellousme.com/privacy-policy/

If you wish to opt out of any of the services or require further information, please contact Mrs A Newsham, Office Manager, Copnor Primary School,  Tel: 023 9266191.

Why we share pupil information

Copnor Primary School will 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 our local authority (LA) and the Department for Education (DfE) under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013.

Under the public duties of the Portsmouth Local Authority for improving education standards in Portsmouth, relevant personal information (name and address) will be passed to the Library Service to enable them to issue all Reception year pupils with their own library card.

Under the public duties of the Portsmouth Local Authority for moderating teacher assessments in Portsmouth, relevant personal information (UPN, name, subject and result) will be passed to our moderators from Southampton City Council in order for them to carry out their contracted dues on behalf of Portsmouth Local Authority.

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.

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.

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 and early years’ census. Some of this information is then stored in the NPD. The law that allows this is the Education (Information About Individual Pupils) (England) Regulations 2013.

To find out more about the pupil information we share with the department, for the purpose of data collections, go to https://www.gov.uk/education/data-collection-and-censuses-for-schools.

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

The department may share information about our pupils from the NPD with third parties who promote the education or well-being of children in England by:

• conducting research or analysis
• producing statistics
• providing information, advice or guidance

The Department has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. Decisions on whether DfE releases data to third parties are subject to a strict approval process and based on a detailed assessment of:

• who is requesting the data
• the purpose for which it is required
• the level and sensitivity of data requested: and
• the arrangements in place to store and handle the data

To be granted access to pupil information, organisations must comply with strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the department’s data sharing process, please visit:

https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

For information about which organisations the department has provided pupil information, (and for which project), please visit the following website: https://www.gov.uk/government/publications/national-pupil-database-requests-received

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

Requesting access to your personal data

Under data protection legislation, 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 be given access to your child’s educational record, contact Mrs A Newsham, Office Manager, Copnor Primary School.

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 Copnor Primary School 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/

Contact:

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

• Mrs A Newsham, Office Manager, Copnor Primary School

If you need more information about how our local authority and/or DfE collect and use your information, please see the Portsmouth City Council Data Protection Privacy Notice

Or visit:

• the DfE website at https://www.gov.uk/data-protection-how-we-collect-and-share-research-data