Privacy Policy

Privacy Notice for Staff

Privacy Notice for the school workforce

(How we use and process workforce information)

Under UK GDPR, individuals have the right to be informed about how Pioneer Educational Trust and the schools within use any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ on a yearly basis to individuals where we are processing their personal data. The notice can also be found at: https://www.pioneereducationaltrust.org.uk/home/privacy-policy/

For the purposes of UK GDPR Pioneer Educational Trust is the ‘data controller’.

Our data protection officer is Nicola Cook, Schools DPO.

The categories of personal information that we hold and process include:

We process personal data relating to those we employ to work at, or otherwise engage to work at, our school. This is for employment purposes to assist in the running of the school or to enable individuals to be paid. Personal data that we may collect, use, store and share (where appropriate) includes, but is not restricted to:

personal information (such as name, employee or teacher number, national insurance number)
personal contact information (including contact addresses, emails and ‘phone numbers, next of kin and emergency contact details)
contract information (such as start dates, hours worked, post, roles, annual leave, pension, benefits and salary information)
work absence information (such as number of absences and reasons)
qualifications and training information (and, where relevant, subjects taught)
medical information (such as food allergies or medication needed in an emergency)
copies of relevant right to work documentation (such as passports, birth certificates and work permits)
payroll information (such as bank details, tax status, national insurance number)
performance information (including capability)
outcomes of any disciplinary, safeguarding and/or grievance procedures
photographs
CCTV images captured in school

We may also collect, store and use information about individuals that falls into ‘special categories’ of more sensitive data. This may include information about:

physical or mental health needs
racial or ethnic origin
trade union membership
criminal convictions data
civil and criminal proceedings, outcomes and sentences.

This list is not exhaustive.

Why we collect and use workforce information

We use workforce data to:

enable the development of a comprehensive picture of the workforce and how it is deployed
facilitate safe recruitment, as part of our safeguarding obligation under relevant legislation
inform and develop our recruitment and retention policies and procedures
support performance management
enable individuals to be paid
to contact you directly when you are not on the premises
to contact others known to you, where you have provided their information, in cases where it would be reasonable for us to contact that individual
to support the health and wellbeing of the workforce
to fulfil statutory obligations as required by the Department of Education (eg the submission of the annual school workforce census)

Our lawful basis for using this data

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

Fulfil a contract we have entered into with you
Comply with a legal obligation
Carry out a task in the public interest

Less commonly, we may also use personal information about you where:

You have given us consent to use it in a certain way
We have a legitimate interest
We need to protect your vital interests (or someone else’s interests)

Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so. Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the school’s use of your data.

Some personal data is considered more sensitive and requires extra protection. This is special category data and it includes race, ethnicity, religious beliefs, medical conditions, genetic information and biometric data, and also criminal convictions.

If we are processing special category data, we will identify an additional lawful condition, such as:

we have explicit consent
to meet our obligations as a data controller or your obligations
to meet our public interest task of keeping staff safe.

If we are processing criminal convictions data we rely on the lawful basis of ‘task in the public interest’, plus our ‘official authority’ as a Trust under Article 10 of the GDPR and Schedule 1 of the UK’s Data Protection Act 2018.

Collecting workforce information

We collect personal information via HR/personnel forms and via the recruitment process (eg application form and new staff appointment forms).

Workforce data is essential for the Trust’s / school’s / DfE’S / local authority’s operational use. Whilst the majority of personal information you provide to us is mandatory, some of it is requested on a voluntary basis. In order to comply with UK GDPR, we will inform you at the point of collection, whether you are required to provide certain information to us or if you have a choice in this.

Storing workforce information

We create and maintain an employment file for each staff member. The information contained in this file is kept secure and is only used for purposes directly relevant to your employment.

Once your employment with us has ended, we will retain this file and delete the information in it in accordance with the guidelines from the Information and Records Management Society (IRMS).

Who we share workforce information with

We do not share information about you with any third party without your 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 you with:

Central and local government (e.g. the Department for Education (DfE)
our HR, payroll, pensions and company benefits service providers
other supplier and service providers to enable them to provide the service we have contracted them for, such as catering, PARS
our auditors
Ofsted
health authorities
police forces, courts, tribunals
professional bodies
employment and recruitment agencies (e.g. where employment references are being sought)
our Disclosure and Barring Services Check provider

This list is not exhaustive.

When we share your personal data with third parties, we provide the minimum amount of information necessary for the purpose.

Why we share school workforce information

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

We are required to share information about our school employees with the Department for Education (DfE) under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and amendments.

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

How Government uses your data

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

informs departmental policy on pay and the monitoring of the effectiveness and diversity of the school workforce
links to school funding and expenditure
supports ‘longer term’ research and monitoring of educational policy

Sharing by the Department

The Department may share information about school employees with third parties who promote the education or well-being of children or the effective deployment of school staff in England by:

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

The Department has robust processes in place to ensure that the confidentiality of personal data is maintained and there are stringent controls in place regarding access to it and its use. Decisions on whether DfE releases personal 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 securely store and handle the data

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

To contact the department: https://www.gov.uk/contact-dfe

Requesting access to your personal data

Under data protection legislation, you have the right to request access to information about you that we hold, known as a ‘subject access request’. To make a request for your personal information, contact the Head’s PA in your school, or the PA to the ELT if you are a member of the central team.

If you make a subject access request, and if we do hold information about you, we will give you a copy of the information in an intelligible form.

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
a right to seek redress, either through the ICO, or through the courts

If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern with us in the first instance. Alternatively, you can contact 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 the Head’s PA in your school, or the PA to the ELT if you are a member of the central team.

If you would like to contact our data protection officer, please contact her through Mrs Bhamini Lynn, blynn@pioneereducationaltrust.org.uk

Privacy Notice for Students and Parents

Privacy Notice (How we use pupil information)

We collect and hold personal information relating to our pupils and may also receive information about them from their previous school. The school uses and processes pupil information within the remit of the Regulation (EU) 2016/679 (General Data Protection Regulation), referred to throughout this statement as the GDPR.

The categories of pupil information that we process include:

Personal information (such as name, unique pupil number and 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)
Assessment information (such as internal tests, pupils progress information and examination results)
Medical information (such as allergies to food, medication a student may require and medical incidents that have occurred inside or outside of school that may affect learning)
Special Educational Needs and Disabilities information (such as specific learning difficulties, specific medial needs and previous learning or medical needs)
Behavioural information (such as rewards, achievements, sanctions and exclusions)
Post 16 information (such as destinations data, UCAS applications and grants)
safeguarding information (such as court orders and professional involvement)

This list is not exhaustive.

Why we collect and use pupil information

We collect and use pupil information, for the following purposes:

to support pupil learning
to monitor and report on pupil attainment progress
to provide appropriate pastoral care
to assess the quality of our services
to keep children safe (food allergies, or emergency contact details)
to meet the statutory duties placed upon us for DfE data collections

We collect and use pupil information under Article 6 and Article 9 of the GDPR, this enables the school to process information such as assessments, special educational needs requests, Departmental Censuses under the Education Act 1996 and the Education Act 2005, examination results and other such data processes that relate educational data to the individual within the requirements for the school to provide education for the individual.

How we collect pupil information

We collect pupil information via admissions and registration forms, Common Transfer Files (CTF) or secure file transfers from your previous school, pupil data collection sheets, in person, via telephone calls and/or emails initiated by the child or parent.

Pupil data is essential for the schools’ operational use. Whilst the majority of pupil information you provide to us is mandatory, some of it 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.

How we store pupil data

We hold pupil data securely for the set amount of time shown in our data retention schedule which is available on request.

Who we share pupil information with

We routinely share pupil information with:

schools and other educational environments that the pupils attend after leaving us
our local authority
the Department for Education (DfE)
the Police and Law Enforcement
local School Nursing Teams
local NHS trusts
local Safeguarding agencies
Pioneer Educational Trust
our MIS, Assessment and Behaviour software providers
Examination Boards
Local Authorities
Tour operators and insurance companies
Slough Music Service
ParentPay

Why we regularly 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.

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.

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

For more information, please see ‘How Government uses your data’ section.

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 your School Office.

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
a right to seek redress, either through the ICO, or through the courts

If you have a concern or complaint 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/

Contact

If you would like to discuss anything in this privacy notice, please contact your School Office.

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)

Data collection requirements

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-pupil-database-user-guide-and-supporting-information

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-external-data-shares

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