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’ (sometimes called ‘fair processing notices’) to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about students.

We, Ysgol Penygelli, Coedpoeth, Wrexham, are the ‘data controller’ for the purposes of data protection law.

Our data protection officer is a member of her governing body (see ‘Contact us’ below).

Personal Data We Hold

Personal data that we may collect, use, store and share (when appropriate) about students includes, but is not restricted to:

• Contact details, contact preferences, date of birth, identification documents.
• Results of internal assessments and externally set tests.
• Student 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.

We may also hold data about students that we have received from other organisations, including other schools, local authorities and the Welsh Government.

Why We Use This Data

We use this data to:

• Support student learning.
• Monitor and report on student progress.
• Provide appropriate pastoral care.
• Protect student welfare.
• Assess the quality of our services.
• Administer admissions lists.
• Carry out research.
• Comply with the law regarding data sharing.

Our Legal Basis For Using This Data

We only collect and use students’ 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 students’ 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Where we have obtained consent to use students’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.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 students’ 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 students 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 students while they are attending our school. We may also keep it beyond their attendance at our school, if it is necessary, in order to comply with our legal obligations. The Local Authority's record retention schedule / records management policy sets out how long we keep information about students.

Please contact the school to request a copy of the record retention schedule / records management policy.

Data Sharing

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

• Our Local Authority (L.A.) to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions.
• The student’s family and representatives.
• Educators and examining bodies.
• Our regulator Estyn.
• Suppliers and service providers – to enable them to provide the service we have contracted them for, for example, assessment tracking.
• Financial organisations.
• Central and Local Government.
• Our auditors.
• Survey and research organisations.
• Health authorities.
• Security organisations.
• Health and social welfare organisations.
• Professional advisers and consultants.
• Charities and voluntary organisations.
• Police forces, courts, tribunals.
• Professional bodies.

Welsh Government Student Database

The Welsh Government receives information on school pupils normally as part of the Pupil Level Annual Schools Census (PLASC). The Welsh Government may receive information on children who attend L.A. funded Early Years Provision in non-maintained settings. The Welsh Government uses this personal information for research (carried out in a way that ensures individual children and young people cannot be identified) and for statistical purposes, to inform, influence and improve education policy and to monitor the performance of the education service as a whole. Examples of the sort of statistics produced can be viewed at www.wales.gov.uk/statistics

The L.A. also uses the personal information collected to do research. It uses the results of this research to make decisions on policy and the funding of schools, to calculate the performance of schools and help them to set targets. The research is carried out in a way that ensures individual children and young people cannot be identified. For more information, see the Welsh Government’s webpage.

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.

Parents and Students’ 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 another organisation in certain circumstances.

If you would like to make a request, please contact our Data Protection Officer by contacting School Reception on 01978 722160.

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 its processing.
• Claim compensation for damages caused by a breach of the data protection regulations.

To exercise any of these rights, please contact our Data Protection Officer.

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 01625 545745 or 0303123113

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 - Mrs Alison Jones.

Our Governor Data Protection Officer is contactable via School Reception.

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