Privacy Notices

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Privacy notice for parents/carers

 

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 Clywedog, Ruthin Road, 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).

The 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 this is necessary in order to comply with our legal obligations. The Local Authorities 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 – 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. e.g Show My Homework , GCSEPod

SIMs (Student Information Management system) App – See App privacy notice here – SIMs App Lite Parent Privacy Notice

    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

We are required to provide information about students to the Welsh Government as part of statutory data collections such as the school census.

The database is held electronically so it can easily be turned into statistics. The information is securely collected from a range of sources including schools, local authorities and exam boards.

The Welsh Government may share information from their database with other organisations which promote children’s education or wellbeing in Wales. Such organisations must agree to strict terms and conditions about how they will use the data.

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.

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 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

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:

Governor DPO. Contactable via School reception or LA clerking service.

Privacy notice for students

You have a legal right to be informed about how our school uses any personal information that we hold about you. To comply with this, we provide a ‘privacy notice’ to you where we are processing your personal data.

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

We, Ysgol Clywedog, Ruthin Road, 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).

The personal data we hold

We hold some personal information about you to make sure we can help you learn and look after you at school.

For the same reasons, we get information about you from some other places too – like other schools, the local council and the government.

This information includes:

    Your contact details

    Your test results

    Your attendance records

    Your characteristics, like your ethnic background or any special educational needs

    Any medical conditions you have

    Details of any behaviour issues or exclusions

    Photographs

    CCTV images

Why we use this data

We use this data to help run the school, including to:

    Get in touch with you and your parents when we need to

    Check how you’re doing in exams and work out whether you or your teachers need any extra help

    Track how well the school as a whole is performing

    Look after your wellbeing

Our legal basis for using this data

We will only collect and use your information when the law allows us to. Most often, we will use your information where:

    We need to comply with the law

    We need to use it to carry out a task in the public interest (in order to provide you with an education)

Sometimes, we may also use your personal information where:

    You, or your parents/carers have given us permission to use it in a certain way

    We need to protect your interests (or someone else’s interest)

Where we have got permission to use your data, you or your parents/carers may withdraw this at any time. We will make this clear when we ask for permission, and explain how to go about withdrawing consent.

Some of the reasons listed above for collecting and using your information overlap, and there may be several grounds which mean we can use your data.

Collecting this information

While in most cases you, or your parents/carers, must provide the personal information we need to collect, there are some occasions when you can choose whether or not to provide the data.

We will always tell you if it’s optional. If you must provide the data, we will explain what might happen if you don’t.

How we store this data

We will keep personal information about you while you are a student at our school. We may also keep it after you have left the school, where we are required to by law.

The local authority have a record retention schedule/records management policy which sets out how long we must 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 personal information about you with anyone outside the school without permission from you or your parents/carers, unless the law and our policies allow us to do so.

Where it is legally required, or necessary for another reason allowed under data protection law, we may share personal information about you with:

    Our local authority – to meet our legal duties to share certain information with it, such as concerns about students’ safety and exclusions

    Your family and representatives

    Educators and examining bodies

    Our regulator (the organisation or “watchdog” that supervises us), Estyn.

    Suppliers and service providers – so that they can provide the services we have contracted them for

SIMs (Student Information Management system) App – See App privacy notice here – SIMs App Lite Parent Privacy Notice

    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

We are required to provide information about you to the Welsh Government as part of data collections such as the school census.

The database is held electronically so it can easily be turned into statistics. The information it holds is collected securely from schools, local authorities, exam boards and others.

The Department for Education may share information from the database with other organisations which promote children’s education or wellbeing in England. These organisations must agree to strict terms and conditions about how they will use your data.

Transferring data internationally

Where we share data with an organisation that is based outside the European Economic Area, we will protect your data by following data protection law.

Your rights

How to access personal information we hold about you

You can find out if we hold any personal information about you, and how we use it, by making a ‘subject access request’, as long as we judge that you can properly understand your rights and what they mean.

If we do hold information about you, we will:

    Give you a description of it

    Tell you why we are holding and using it, and how long we will keep it for

    Explain where we got it from, if not from you or your parents

    Tell you who it has been, or will be, shared with

    Let you know if we are using your data to make any automated decisions (decisions being taken by a computer or machine, rather than by a person)

    Give you a copy of the information

You may also ask us to send your personal information to another organisation electronically in certain circumstances.

If you want to make a request please contact our data protection officer.

Your other rights over your data

You have other rights over how your personal data is used and kept safe, including the right to:

    Say that you don’t want it to be used if this would cause, or is causing, harm or distress

    Stop it being used to send you marketing materials

    Say that you don’t want it used to make automated decisions (decisions made by a computer or machine, rather than by a person)

    Have it corrected, deleted or destroyed if it is wrong, or restrict our use of it

    Claim compensation if the data protection rules are broken and this harms you in some way

Complaints

We take any complaints about how we collect and use your personal data very seriously, so please let us know if you think we’ve done something wrong.

You can make a complaint at any time by contacting our data protection officer.

You can also complain to the Information Commissioner’s Office in one of the following ways:

    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

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:

Governor DPO. Contactable via School reception or LA clerking service.

Privacy notice for staff

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 individuals we employ, or otherwise engage, to work at our school.

We, Ysgol Clywedog, Ruthin Road, 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).

The personal data we hold

We process data relating to those we employ, or otherwise engage, to work at our school. Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

    Contact details

    Date of birth, marital status and gender

    Next of kin and emergency contact numbers

    Salary, annual leave, pension and benefits information

    Bank account details, payroll records, National Insurance number and tax status information

    Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process

    Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships

    Performance information

    Outcomes of any disciplinary and/or grievance procedures

    Absence data

    Copy of driving licence

    Photographs

    CCTV footage

    Data about your use of the school’s information and communications system

We may also collect, store and use information about you that falls into “special categories” of more sensitive personal data. This includes information about (where applicable):

    Race, ethnicity, religious beliefs, sexual orientation and political opinions

    Trade union membership

    Health, including any medical conditions, and sickness records

Why we use this data

The purpose of processing this data is to help us run the school, including to:

    Enable you to be paid

    Facilitate safe recruitment, as part of our safeguarding obligations towards students

    Support effective performance management

    Inform our recruitment and retention policies

    Allow better financial modelling and planning

    Enable ethnicity and disability monitoring

    Improve the management of workforce data across the sector

    Support the work of the EWC

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 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.

Collecting this information

While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us.

Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.

How we store this data

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 Local Authorities’ record retention schedule/records management policy.

Data sharing

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:

    Our local authority – to meet our legal obligations to share certain information with it, such as safeguarding concerns and [maintained schools only] information about headteacher performance and staff dismissals

    Your family or representatives

    Educators and examining bodies

    Our regulator, Estyn.

    Suppliers and service providers – to enable them to provide the service we have contracted them for, such as payroll

    Financial organisations

    Central and local government

    Our auditors

    Survey and research organisations

    Trade unions and associations

    Health authorities

    Security organisations

    Health and social welfare organisations

    Professional advisers and consultants

    Charities and voluntary organisations

    Police forces, courts, tribunals

    Professional bodies

    Employment and recruitment agencies

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.

Your rights

How to access personal information we hold about you

Individuals have a right to make a ‘subject access request’ to gain access to personal information that the school holds about them.

If you make a subject access request, and if we do hold information about you, 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

    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

You may also have the right for your 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.

Your other rights regarding your data

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:

    Object to the use of your personal data if it would cause, or is causing, damage or distress

    Prevent your data being used to send direct marketing

    Object to the use of your personal data for 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 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

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:

Governor DPO. Contactable via School reception or LA clerking service.

Welsh Government privacy notice for staff associated with the School Workforce Annual Census.
In accordance with General Data Protection Regulation (GDPR), this notice sets out what the Welsh Government does with the information that it receives from schools and local authorities about the school workforce in Wales.
The information in this notice will be kept under review to incorporate any further changes communicated by the Information Commissioner’s Office (ICO). The information in the notice should contribute to wider notices issued by the school and local authority.

1. Background
The School Workforce Annual Census (SWAC) is an annual statutory data collection of information about the workforce in maintained schools in Wales.
The Welsh Government receives information on the school workforce directly from schools and local authorities as part of the SWAC. In accordance with the Education (Supply of Information about the School Workforce) (Wales) Regulations 2017, made under section 113(2) and (3) of the Education Act 2005.
The SWAC covers all maintained school settings in Wales, including:
 maintained nursery schools;
 maintained primary schools;
 maintained middle schools (through age schools);
 maintained secondary schools;
 maintained special schools; and
 pupil referral units (PRUs).

Upon receipt of the information from the school and local authority, the Welsh
Government becomes the data controller.
2. What information is received by the Welsh Government?

1 Data items collected in the School Workforce Annual Census (SWAC): https://gov.wales/schoolworkforce-annual-census-swac-privacy-notice
2 Personal data is defined under the General Data Protection Regulation (GDPR) as
‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’
The categories of school workforce information that will be collected and held include:
 Personal and special category information about you, such as:
 Teacher reference number (TRN);
 First name;
 Middle name(s);
 Surname;
 Date of birth;
 Sex;
 Ethnic group;
 Disability status; and
 National insurance number.
 Information on your pay and contracts (such as pay scales, allowances,
remuneration, and reason for leaving).
 Information on your absences (including absence length and type)
 Information on Welsh language skills
 Information on the subjects you teach, post type and associated roles.
3. What is the lawful basis for using your data?
The lawful basis for processing information in this data collection exercise is in our public task; that is, exercising our official authority to undertake the core role and functions of the Welsh Government. Some of the data we are collecting are called ‘special category data’ (in this case ethnicity and disability) and the lawful basis for processing this information is that it is for statistical or research purposes.
4. What is the Welsh Government doing with your information?
As data controller, the Welsh Government uses the information received to carry out data processing necessary for the performance of tasks carried out in the public interest and in the exercise of official authority.

Data will be used for:
1, Statistical and research purposes to support the formation of education policy, through the building of a comprehensive evidence base to inform, influence and improve the planning of services for people in Wales.

2, Data items collected in the School Workforce Annual Census (SWAC): https://gov.wales/schoolworkforce-annual-census-swac-privacy-notice
3, Supporting robust forecasting of teachers’ pay in Wales, informing negotiations and decisions on pay and conditions and providing greater evidence to support future workforce planning.
 The production of school and local authority level analysis for schools, local authorities and regional consortia.
 Identifying and reducing causes of employment, skills and pay inequalities related to gender, ethnicity, age and disability.
 Linking with other data sets, in order to inform wider education, health and social policies. Examples of data sets that we may link include student and graduate data from the Higher Education Statistics Agency (HESA) or employment and welfare data from The Department of Work and Pensions (DWP). We will only link data sets where the law allows us to do so.
In addition to data protection legislation, our use of data for statistical purposes is also managed in accordance with the Code of Practice for Statistics (“the Code”).

Principle T6 of the Code covers data governance.
Information derived from the data is published as anonymous official statistics and in many accessible formats for use by a wide range of organisations and individuals (including, academic researchers, private companies, professional bodies and the media). Any statistics published or responses to requests for analysis are anonymised and non-disclosive, meaning that individuals cannot be identified.
Results from analyses carried out using the data will be made available at an aggregated level in statistical or research publications via the Welsh Government website and also via data placed on the StatsWales website.
External users such as schools, local authorities, the Office of National Statistics (ONS), the media and the wider public will be able to use this published information for their own purposes, such as workforce management and planning; to improve practice and to hold government to account.

5. Who does the Welsh Government share your information with?
Organisations the Welsh Government may share your personal information with include:
 Her Majesty’s Chief Inspector of Education and Training in Wales (Estyn);
 the Secretary of State in England;
 the administrator of the Teacher’s Pension Scheme;
 local authorities in Wales;
 the Education Workforce Council (EWC);
 the governing body of a maintained school in Wales; and
 the office of manpower economics.

Accredited researchers, such as academics and educational researchers, and other  public sector bodies in Wales may request access to data. These requests are scrutinised by the Welsh Government’s Chief Statistician and – if approved – are governed by Data Access Agreements issued by the Welsh Government. These formal agreements set out strict requirements for the processing and safekeeping of personal data, including:
 ensuring the secure transfer, storage and eventual destruction of the data;
 only including personal information if there is a clear requirement, legal basis and significant justification;
 limiting the use to the specific requirement identified, ensuring that no
individual can be identified in any published reports; and

 only allowing the data to be stored for the duration of the research project, requiring the data to be destroyed after that period.
Data from SWAC will be matched over time to allow for longitudinal analysis or linked to other data sources using a trusted third party for non commercial research purposes. Linked and matched data doesn’t provide identifiable information to researchers. We do not share or use your information for commercial or marketing purposes.

6. How long will we keep this data?
Personal data will be held for a minimum of seven years from first collection to allow for the statistical analysis of trends over a standard five year period. After this point, the data will be periodically reviewed and anonymised in line with best practices and used only for statistical and research purposes.
Regarding the retention of data, Article 5 of the GDPR “Principles relating to
processing of personal data” states personal data may be stored for longer periods if for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes. The data will be processed in line with this legislation.
Data that are shared with third parties for research purposes will only allow the data to be shared for the duration of the project, and will require the data to be destroyed after that period.
For more information on our data retention schedule and how we keep your data safe, please visit the Welsh Government’s Information Management and Governance Policy website.

7. Individual Rights
Under GDPR, you have the following rights in relation to the personal information provided as part of SWAC.
Specifically, you have the right to:

 access a copy of your own data;
 request that we rectify inaccuracies in that data;
 object to or restrict processing (in certain circumstances);
 request that your data be ‘erased’ (in certain circumstances); and
 lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection.
More guidance on these rights can be found on the ICO’s website.

8. Further Information
For queries in relation to the SWAC please contact the Welsh Government
Education Workforce Data team:
Email address: SWAC.CBGY@gov.wales
Telephone: 0300 025 6367

For further information about the information which the Welsh Governments holds and its use, or if you wish to exercise your rights under the GDPR, please see contact details below:
Data Protection Officer: Welsh Government
Cathays Park
CARDIFF
CF10 3NQ
Email address: Data.ProtectionOfficer@gov.wales

To contact the ICO, please see details below:
Address: Wycliffe House Water Lane
Wilmslow Cheshire SK9 5AF
Telephone – Helpline: 029 2067 8400 (Wales helpline) or
0303 123 1113 (UK helpline)
Website: www.ico.org.uk


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