Primary Advantage Federation Privacy Notice
Under The General Data Protection Regulation (GDPR) we are obliged to inform you of the information we hold on and your child(ren), what we use it for, who we share it with, and for how long we keep it. This privacy notice (also known as a fair processing notice) aims to provide you with this information. If any information linked to is unclear, please contact the school office, or the school’s Data Proection Officer. Contact details for both are available at the end of this privacy notice.
We, Primary Advantage, are the Data Controller for the purposes of data protection law.
As a public body as we have appointed the London Diocesan Board for Schools as our Data Protection Officer (DPO), they can be contacted via:
Post: Hassan Muzammal, London Diocesan House, 36 Causton Street, London, SW1P 4AU
We may also hold data about pupils that we have received from other organisations, including other schools, local authorities and the Department for Education.
We use the pupil and parent data:
Our lawful basis for collecting and processing pupil information information is defined under Article 6, and the following sub-paragraphs in the GDPR apply:
Our lawful basis for collecting and processing pupil information information is also further defined under Article 9, in that some of the information we process is demed to be sensitive, or special, information and the following sub-paragraphs in the GDPR apply:
Please see our record of processing for further Information.
Where we have obtained consent to use pupils’ personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.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.
The submission of the school census returns, including a set of named pupil records, is a statutory requirement on schools under Section 537A of the Education Act 1996.
Putting the school census on a statutory basis:
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. Where we have obtained consent to use pupils’ personal data, this consent can be withdrawn at any time.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.
We hold pupil data whilst the child remains at a Primary Advantage Federation School. The file will follow the pupil when he/she leaves the school. However where there is a legal obligation to retain the information beyond that period, it will be retained in line with our retention policy.
Please refer to our Records Management Policy for further information.
We have data protection policies and procedures in place, including strong organisational and technical meansures,which are regularly reviewed. Further information can be found on our website.
We routinely share pupil information with appropriate third parties, including:
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.
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 our local authority (LA) and the Department for Education (DfE) under section 3 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.
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 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:
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:
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
Under data protection legislation, parents and pupils have the right to request access to information about them that we hold, through a Subject Access Request.
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:
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 (see section 12 below).
Parents/carers also have a legal right to access to their child’s educational record. To request access, please contact Serap Ciftci (Data Officer)
You also have the right to:
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 (see section 12 below).
Alternatively, you can make a complaint to the Information Commissioner’s Office:
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Data Protection Officer.
David Coy, London Diocesan Board for Schools – Data Protection Officer (DPO)
Post: London Diocesan House, 36 Causton Street, London, SW1P 4AU
Tel: 020 7932 1161