Contact Details:        Ysgol Bro Sannan

Telephone: 01443 828000

        Email: ygbsa@caerphilly.gov.uk

Description of Privacy Notice:         This privacy notice will explain how Ysgol Bro Sannan will process personal information about pupils and families.

How we will use your information

Source and type of information being processed

The categories of pupil information that we collect, hold and share 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)
• behavioural information (such as exclusions and any relevant alternative provision put in place)
• safeguarding information (such as court orders and professional involvement)
• special educational needs (including the needs and ranking)
• medical and administration (such as doctors information, child health, dental health, allergies, medication and dietary requirements)
• contact details, contact preferences, date of birth, identification documents
• performance in internal and national assessments and examinations, assessment information
• pupil and curricular records
• details of any medical conditions, including physical and mental health
• details of any support received, including care packages, plans and support providers
• photographs
• CCTV images captured in school

Source of the personal data

This information has been collected from:

• Pupils/families directly, (e.g. via registration forms at the start of the school year, school trip applications, etc)
• Other schools where a pupil has previously attended
• Caerphilly County Borough Council Education Directorate
• Caerphilly County Borough Council Social Services Directorate (if applicable)
• Aneurin Bevan University Health Board School Health Service

If you would like further information on the source of this information, please contact the school.

Your Obligations

Certain pupil data is essential for the schools’ operational use. Whilst the majority of pupil information you provide to us is mandatory due to a legal or contractual obligation (please see below), some if it is optional, and if this is the case you will be asked to give your consent.

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. The school will also outline any consequences should you decide not to provide information or to subsequently withdraw consent.

Why do we collect and use your information

Ysgol Bro Sannan collects information about children and young people and their parents or legal guardians upon enrolment and at other key times during the school year. When children and young people transfer, they may receive information from other schools and early years providers.

Ysgol Bro Sannan processes the information it collects to administer the education it provides to children and young people. For example:

• the provision of educational services to individuals;
• monitoring and reporting on pupils’/children’s educational progress;
• the provision of welfare, pastoral care and health services;
• the giving of support and guidance to children and young people, their parents and legal guardians;
• the organisation of educational events and trips;

Ysgol Bro Sannan collects information about children and young people and their parents or legal guardians when they apply for admission to Ysgol Bro Sannan. This data can be accessed by Caerphilly County Borough Council for the same reasons listed above.

We collect and use pupil information under Section 537A of the Education Act 1996 and section 83 of the Children Act 1989.  We also comply with Article 6(1)(c) and Article 9 (2)(b) of the General Data Protection Regulation (GDPR).

We use 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
• to keep children safe (food allergies, or emergency contact details)
• to meet the statutory duties placed upon us for Welsh Government data collections
• to administer trips and activities, catering and free school meal management, which may include identity management/authentication using biometrics
• to support pupils to decide what they want to do after leaving school

Legal basis for processing

In order for the processing of personal data to be lawful under the General Data Protection

Regulations 2016, a valid condition from Article 6 of the Regulations must be identified.

Mandatory school processing of pupil information is covered by:

6(1)(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

The public task is provided by:

Education Act (1996/2002);

Special Educational Needs Code of Practice for Wales (2002)

Optional processing of personal data is covered by the Article 6 condition:

6(1)(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes

For instance, Ysgol Bro Sannan will ask for your consent to publish or display photographs of your son/daughter on displays around the school, in newspaper or local magazine articles, and on our website and/or social media pages. You have the right to withdraw consent at any time. Please contact the school for further information.

Data Protection legislation provides extra protection for certain classes of information called 'special categories of personal data', which includes:

• Racial or ethnic origin
• Religious or other beliefs of a similar nature
• Political opinion
• Physical or mental health or condition
• Genetic data
• Biometric data (where used for identification purposes)
• Sexual life or orientation
• Trade union membership

Data Protection legislation also provides extra protection for personal data in relation to criminal allegations, proceedings, outcomes and sentences.

If any information falls within these definitions, additional conditions are required from Article 9 for special category data and Article 10 for personal data relating to crimes, taking into account additional provisions of the Data Protection Act 2018. If you have any questions in the meantime, please contact the school.

Article 9(2)(g) for special category data –

processing is necessary for reasons of substantial public interest on the basis of Union or Member State law; and Article 10 for criminal data – when the processing is authorised by Union or Member State law.

The relevant Member State law is the Data Protection Act 2018, and this processing is covered by Schedule 1, Part II, 6(1).

This condition is met if the processing—

(a) is necessary for a purpose listed in sub-paragraph (2), and

(b) is necessary for reasons of substantial public interest.

 (2) Those purposes are—

(a) the exercise of a function conferred on a person by an enactment or rule of law;

(b) the exercise of a function of the Crown, a Minister of the Crown or a government department.

.

Who will have access to your information?

Identity of Data Controller and Data Protection Officer

The Data Controller for your information is Ysgol Bro Sannan.

The Data Protection Officer is contracted by the school to Caerphilly County Borough Council. You can contact the school Data Protection Officer on 01443 864049, or by email at dataprotection@caerphilly.gov.uk 

Details of main users of your information

The main users of your information will be Ysgol Bro Sannan.

Details of sharing your information with other organisations

We may be required to share certain pupil information with specific organisations, but only with a clearly defined reason and an appropriate legal basis under data protection law.

We always ensure that the sharing of personal information is securely undertaken.

Sharing information with Welsh Government

In addition, the Welsh Government receives information on pupils directly from schools normally as part of statutory data collections which consists of the following:

• Pupil Level Annual School Census (PLASC)
• National data collection (NDC)
• Attendance collection
• Welsh National Tests (WNT) data collection

In addition to the data collected as part of PLASC, the Welsh Government and Local Authorities also receive information regarding National Curriculum assessments, public examination results, and attendance data at individual pupil level which comes from Schools or Awarding Bodies (e.g. WJEC).

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.  Further information is on the Welsh Government’s use of personal data is set out within the Welsh Government’s Privacy Policy which is available here.    

Details of any external data processors

A number of the apps or online services we use process data on Ysgol Bro Sannan’s behalf, including:

Details of transfers to any countries outside of the European Economic Area

Pupils and staff at Ysgol Bro Sannan use G Suite for Education to create and store work and data. This data is stored at data centers both inside and outside the EEC. Parental consent is obtained for pupil accounts and there are provisions in our agreement with Google to ensure the data is processed in accordance with UK regulations (eg GDPR).

Requests for information

All recorded information held by the school may be subject to requests under the Freedom of Information Act 2000, Environmental Information Regulations 2004 and Data Protection legislation (General Data Protection Regulations 2016 and Data Protection Act 2018).

If the information you provide is subject to such a request, where possible, the school will consult with you on its release. If you object to the release of your information, we will withhold your information if the relevant legislation allows.

How long will we retain your information?

Details of retention period

We hold pupil data securely for the set amount of time documented in our data retention schedule. Ysgol Bro Sannan will retain information for the duration the child remains at the primary school, and securely transfer the information to the secondary school or alternative provision when the child moves on.

Your Rights (including Complaints Procedure)

Your rights under data protection law

Data Protection laws give data subjects (those who the information is about) a number of rights, which include:

• Right to be informed how personal data is collected, stored, managed, protected, and processed.
• Right of access to request a copy of personal information held of yourself. However, please be aware that information can sometimes be legitimately withheld.
• Right to rectification of inaccurate or incomplete personal data.
• Right to erasure where you have the right to have your personal data erased in certain circumstances. This does not include any personal data that must be retained by law.
• Right to restriction, which allows you to limit the way we use your personal data in some circumstances.
• Right to portability gives an individual the right the receive copies of data provided to a controller in a portable format.
• Right to object to the processing of ones personal data; and the final one is the
• Rights in relation to automated decision making and profiling.

Children and young people have certain rights under data protection legislation, including a general right to be given access to personal data held about them by an organisation. The UK Data Protection Act 2018 allows that, by the age of 13, children and young people have sufficient maturity to understand their rights and to make an information request themselves if they so wish. A parent would be entitled to make a request on a child’s behalf if the child is younger and would need to provide proof of ID and Parental Responsibility.

To enact your rights, please contact Ysgol Bro Sannan as detailed at the top of this document. A copy of any individual right request and your response will be kept for 3 years.

Complaints Procedure

If you are unhappy with the way that the school has handled your request / information, you have the right of complaint. Please contact Ysgol Bro Sannan outlining your concerns in the first instance.

If you remain unhappy, you can contact the schools Data Protection Officer on 01443 864322 / dataprotection@caerphilly.gov.uk 

You also have the right to ask the Information Commissioner, who enforces and oversees the Data Protection Act in the UK, to assess whether or not the processing of personal information is likely to comply with the provisions of our legislative responsibilities. Further information on your rights is available from: www.ico.org.uk.

How we will use your information

Ysgol Bro Sannan processes personal information about pupils and their families to support pupil learning and monitor attainment, to provide pastoral care, and to keep children safe. We also process personal information to meet the statutory duties placed upon us by Welsh Government, to administer optional school trips and activities, and to deliver the school catering service.

The school takes its responsibilities under data protection law very seriously, and will store and use all personal information securely, disposing of it when no longer required. Personal information may be shared securely for clear purposes with other organisations such as Caerphilly County Borough Council, Welsh Government, or other external partners (e.g. other Local Authorities, Health Boards, and Special Educational Needs Tribunal Wales) that provide a service to pupils/families. You have a number of rights in relation to your personal information, including the right of access to information and the right of complaint.

For further information on how we process your information and your rights please click the following link: www.ysgolbrosannan.org