- To ensure the safety and security of any personal data belonging to either staff or students.
- To ensure the safety of any data and information assets (data, stored in any manner, which is recognised as important or ‘valuable’ – not just in financial terms) that is important to the secure running of the school.
- To ensure the minimisation of security risks and that any loss of data is appropriately logged and dealt with.
This policy complies with the terms of the 1998 Data Protection Act, and any subsequent relevant legislation, to ensure personal data is treated in a manner that is fair and lawful.
This policy is to be used in conjunction with the school’s Internet Use Policy.
1. Data Gathering
- All personal data relating to staff, pupils or other people with whom we have contact, whether held on computer or in paper files, are covered by the Act.
- Only relevant personal data may be collected and the person from whom it is collected should be informed of the data’s intended use and any possible disclosures of the information that may be made.
2. Data Storage
- Personal data will be stored in a secure and safe manner.
- All data on the server is password protected.
- Electronic data will be protected by standard password and firewall systems operated by the school.
- Computer workstations in administrative areas will be positioned so that they are not visible to casual observers waiting either in the office or at the reception hatch.
- Manual data will be stored where it not accessible to anyone who does not have a legitimate reason to view or process that data.
- Particular attention will be paid to the need for security of sensitive personal data.
- Server back-up discs are kept securely in a locked filing cabinet.
3. Data encryption
- Portable and mobile devices (including media) used to store and transmit data protected information, should be protected using approved encryption software.
- When sensitive or personal data is required by an authorised user from outside the school’s premises (for example, by a member of staff to work from their home), they should have secure remote access to the management information system or learning platform
- If secure remote access is not possible, users must only remove or copy personal or sensitive data from the organisation or authorised premises if the storage media, portable or mobile device (e.g. laptop, memory stick) is encrypted and is transported securely for storage in a secure location
- Users must securely delete personal or sensitive data when it is no longer required.
- The school will also encrypt personal data that is transmitted between systems, applications or locations (known as data in transit). Secure transmission of data relies on encryption, authorisation and authentication.
4. Potential security risks and logging of data loss
- Only named staff have access to protected data
- Class registers taken through SIMs – staff have limited access to data
- SIMs and other data are backed up by the server
- Computers in school will be kept up to date with the latest security software. Computers and systems at teachers’ homes also requires security software for them to use remote access or work or use encrypted information on mobile, media and portable devices.
- Server password is protected – only named staff have access to it.
- Security incidents will be logged
5. Data Checking
- The school will issue regular reminders to staff and parents to ensure that personal data held is up-to-date and accurate.
- Any errors discovered would be rectified and, if the incorrect information has been disclosed to a third party, any recipients informed of the corrected data.
6. Data Disclosures
- Personal data will only be disclosed to organisations or individuals for whom consent has been given to receive the data, or organisations that have a legal right to receive the data without consent being given.
7. Responsibility for Data Protection
- The Senior Information Risk Owner (SIRO) has the following responsibilities:They own the information risk policy and risk assessment; They appoint the Information Asset Owners (IAOs); They act as an advocate for information risk management.The named SIRO is Julie Petty.
- The Information Asset Owner (IAO) has the following responsibilities: to know what information is held, and for what purposes; know how information will be amended or added to over time; know who has access to the data and why; know how information is retained and disposed off. The named IAO is Fiona Wilson.
- When requests to disclose personal data are received by telephone it is the responsibility of the school to ensure the caller is entitled to receive the data and that they are who they say they are. It is advisable to call them back, preferably via a switchboard, to ensure the possibility of fraud is minimised.
- If a personal request is made for personal data to be disclosed it is again the responsibility of the school to ensure the caller is entitled to receive the data and that they are who they say they are. If the person is not known personally, proof of identity should be requested.
- Requests from parents or children for printed lists of the names of children in particular classes, which are occasionally sought at Christmas, should be politely refused as permission would be needed from all the data subjects contained in the list. (Note: A suggestion that the child makes a list of names when all the pupils are present in class will resolve the problem.)
- Personal data will not be used in newsletters, websites or other media without the consent of the data subject.
- Routine consent issues will be incorporated into the school’s pupil data gathering sheets, to avoid the need for frequent, similar requests for consent being made by the school.
- Personal data will only be disclosed to Police Officers if they are able to supply a WA170 form which notifies of a specific, legitimate need to have access to specific personal data.
- A record should be kept of any personal data disclosed so that the recipient can be informed if the data is later found to be inaccurate.
- Consent to take photos or display an individual’s likeness (inc. on the school’s web-site) is sought by the individual or parent if that individual is a student. These consent forms are collated and stored centrally.
8. Subject Access Requests
- If the school receives a written request from a data subject to see any or all personal data that the school holds about them this will be treated as a Subject Access Request and the school will respond within the 40 day deadline.
- Informal requests to view or have copies or personal data will be dealt with wherever possible at a mutually convenient time but, in the event of any disagreement over this, the person requesting the data will be instructed to make their application in writing and the school will comply with its duty to respond within the 40 day time limit.