Revised February 2022 and based on KCC model document.

This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.

Who are we?

Dane Court Grammar School collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer for the Coastal Academies Trust is Ms Judy Brace.

The personal information we collect and use

Information collected by us

In the course of providing education we collect the following personal information when you provide it to us:

• Personal information (such as name, date of birth, unique pupil number, contact details, language, nationality, country of birth, and free school meal eligibility)
• Image of the student, taken by a third-party photographer, used to identify them for their own safety and security.
• Special category characteristics
  • Ethnicity
  • Special educational needs (SEN) information
  • Relevant medical information
• Attendance information (such as sessions attended, number of absences and absence reasons)
• National curriculum assessment results
• Post 16 learning information
• Disciplinary and behaviour records

We also obtain personal information from other sources as follows:

• Personal information, special category information, assessment results and SEN information from schools that you previously attended
• Service support and involvement information from KCC teams working to improve outcomes for children and young people (such as SEND, Early Help, Free School Meals, Admissions)

How we use your personal information

We use your personal information to:

• Support pupil learning
• Monitor and report on pupil progress
• Moderate teacher assessment judgements
• Provide appropriate pastoral care and support services
• Assess the quality of our services
• Comply with the law regarding data sharing
• Support you to decide what to do after you leave school
• Support or improve educational provision
• Ensure no children are missing education
• Support children at risk of permanent exclusion
• Support the primary, secondary and in-year admissions process
• Safeguard children and young people
• Improve the education and services we provide

How long your personal data will be kept

We will hold your personal information securely and retain it from the child/young person’s date of birth until they reach the age of 25, after which the information is archived or securely destroyed.

Reasons we can collect and use your personal information

We collect and use pupil information under section 537A of the Education Act 1996, section 83 of the Children Act 1989, and to carry out tasks in the public interest. If we need to collect special category (sensitive) personal information, we rely upon reasons of substantial public interest (equality of opportunity or treatment).

If there is processing or sharing that relies on your consent, we will make this clear to you and ensure we seek your consent.

Who we share your personal information with

• Department for Education (DfE) (statutory for school funding and educational attainment policy and monitoring) and other government agencies and local authorities as required (e.g. to resolve funding queries)
• Kent County Council teams working to improve outcomes for children and young people
• Commissioned providers of local authority services (such as education services)
• Schools or colleges that you attend after leaving us
• Local forums with schools and KCC representatives which support in-year fair access processes and support managed moves between schools
• Local multi-agency forums which provide SEND advice, support and guidance (such as Local Inclusion Forum Team (LIFT))
• Partner organisations signed up to the Kent & Medway Information Sharing Agreement, where necessary, which may include Police, school nurses, doctors and mental health workers and Kent Community Health NHS Foundation Trust
• Schools in our local collaboration, to enable the moderation of pupil assessment outcomes, to support collaborative working through joint analysis, and ensure children continue to receive appropriate education provision
• KCC has to share information with external moderators (teachers with recent relevant experience) of end of key stage assessments, to meet statutory requirements from the Standards & Testing Agency (STA)
• Third-party providers of information services (such as student apps).
• Contracted providers of school photographs
  Usually a photograph will be taken of your child for the purposes of education, welfare and child protection in the public interest. This will be taken by a contracted provider of photography services, who will not retain the photograph or any other data. The photograph will not be used for any marketing or communication purposes unless consent has been given.
• Contracted providers of services (such as school photographers, Tempest and catering providers, Harrison Catering Services, Biostore Identity Management).
• Prospective employers
• Residential school trip organisations
• Google classrooms
• Wisepay
• Wonde

We will share personal information with law enforcement or other authorities if required by applicable law.

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. We are required to submit end of key stage assessment data to KCC, as the statutory collection agency for the DfE.

Aged 14+ qualifications

For pupils enrolling for post-14 qualifications, the Learning Records Service will give us a pupil’s unique learner number (ULN) and may also give us details about the pupil’s learning or qualifications

Our pupils in Year 11

We also provide additional pupil information to KCC to fulfil their responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996:

• Intended destinations of pupils in Year 11 moving into Year 12
• Course offers for pupils in Year 11 moving into Year 12 (September Guarantee)
• Information for Kent Choices4U (careers advice and course application website)

Our pupils aged 13+

We will share information about pupils aged 13+ with our local authority as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.

KCC has a legal responsibility to track all young people up to the age of 19 (and young adults with learning difficulties or disabilities up to the age of 25). The purpose of collecting this information is to assist the planning of education and training for young people and the support services they require. KCC will inform us of your current activity once you have left the school. This is in relation to education, training, employment with training you may be undertaking and whether you are NEET (not in Education, Employment or Training). Some of this information is then shared with the DfE who use the information to plan at a national level.

This information enables KCC to provide and arrange:

• post-16 education and training provision
• youth support services
• careers advice and guidance

Parents/carers, or pupils once they are 16, can contact our data protection officer to ask us to only pass name, address and date of birth to the Local Authority.

The National Pupil Database (NPD)

The NPD is owned and managed by the DfE 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 DfE. 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.

The DfE 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 DfE 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.

Your Rights

Under the GDPR you have rights which you can exercise free of charge which allow you to:

• Know what we are doing with your information and why we are doing it
• Ask to see what information we hold about you (Subject Access Requests)
• Ask us to correct any mistakes in the information we hold about you
• Object to direct marketing
• Make a complaint to the Information Commissioners Office
• Withdraw consent (if applicable)

Depending on our reason for using your information you may also be entitled to:

• Ask us to delete information we hold about you
• Have your information transferred electronically to yourself or to another organisation
• Object to decisions being made that significantly affect you
• Object to how we are using your information
• Stop us using your information in certain ways

We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note: your request may delay or prevent us delivering a service to you.

For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioners Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise a right, please contact Ms Judy Brace, King Ethelbert School 01843 831999, Data Protection Officer

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Who to Contact and Where to go for Further Information

Please contact Ms Judy Brace, King Ethelbert School 01843 831999, Data Protection Officer to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

If you would like to get a copy of the information about you that KCC shares with the DfE or post-16 providers or how they use your information, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.

For more information about services for children and young people, please go to: http://www.kent.gov.uk/education-and-children or the KCC website at www.kent.gov.uk

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 03031 231113.

For further information visit https://www.kent.gov.uk/about-the-council/about-the- website/privacy-statement

For further information about how the Department for Education uses your information:

To find out more about the pupil information we share with the DfE, 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.

For more information about the DfE’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