Data Protection Policy
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- Herbert Price
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1 Crfe Hills Academy Trust Limited (A Cmpany Limited by Guarantee) Statutry Plicy Dcument Data Prtectin Plicy Spnsr: Chair Deputy Learning March 2015 Plicy Review: Every 2 Years Cmpany Registratin Number: (England and Wales)
2 Intentinally left blank
3 General Statement Crfe Hills Schl adheres t the principles f data prtectin as utlined in the Data Prtectin Acts 1994 and All members f staff invlved in the cllectin, prcessing and disclsure f persnal data are aware f their duties and respnsibilities within these guidelines. Enquiries Infrmatin abut the Crfe Hills Schl Data Prtectin prcedures can be btained frm Philip Keen. Fair Obtaining and Prcessing Crfe Hills Schl undertakes t btain and prcess data fairly and lawfully by infrming all data subjects f the reasns fr data cllectin, the purpses fr which data is held, the likely recipients f the data and the data subject s right f access. Infrmatin abut the use f persnal data is printed n the apprpriate cllectin frm. If details are given verbally, the persn cllecting the data will explain the issues befre cllecting the infrmatin. Terms Prcessing: btaining, recrding r hlding the infrmatin r data r carrying ut a set f peratins n the infrmatin r data. Data subject: means an individual wh is the subject f persnal data r the persn t whm the data relates. Persnal data: means data which relates t a living individual wh can be identified. Addresses and telephne numbers are examples. Parent: refers t the meaning given in the Educatin Act 1996, and includes any persn wh has parental respnsibility fr a child. Registered Purpses The Data Prtectin Act Registratin entries fr Crfe Hills Schl are available fr inspectin by appintment at Receptin. Explanatin f any cdes and categries is available frm Philip Keen, wh is the persn nminated t deal with data prtectin issues. Registered purpses cvering the data held at the schl are listed n the schl s registratin and data cllectin dcuments. Infrmatin held fr these stated purpses will nt be used fr any ther purpse withut the data subject s cnsent. Data Integrity Crfe Hills Schl undertakes t ensure that data integrity is achieved by the fllwing methds: Data Accuracy Data will be as accurate and up-t-date as is reasnably pssible. If a data subject infrms the schl f a change f circumstances, their cmputer recrd will be updated as sn as is practicable. Cntinuus access t data recrds is prvided t data subjects thrugh the SIMs Learning Gateway. This includes a mechanism fr subjects t check data accuracy and make any amendments. Where a subject challenges the accuracy f their data, Crfe Hills Schl will immediately mark the recrd as ptentially inaccurate. In cases f dispute, we will attempt t reslve the issue infrmally, but if this prves impssible, disputes will be referred t Philip Keen fr his judgement. If the dispute cannt be reslved at this stage, either side may seek independent arbitratin. Until reslved, the infrmatin will be marked and bth versins will be saved. Data Adequacy and Relevance Data held abut peple will be adequate, relevant and nt excessive in relatin t the purpse fr which the data is held. In rder t ensure cmpliance with this principle, Crfe Hills Schl will check recrds regularly fr missing, irrelevant r seemingly excessive infrmatin and may cntact the subjects t verify certain items f data. Recrds are checked fr irrelevant data termly and the decisins abut what can be deleted is made by the SIMS data manager. Length f Time Data held abut individuals will nt be kept fr lnger than necessary fr the purpses registered. The schl will that bslete data is prperly erased.
4 Subject Access The Data Prtectin Acts extend t all data subjects a right f access t their wn persnal data. In rder t ensure that peple receive nly infrmatin abut themselves, it is essential that a frmal system f requests is in place. Where a request fr subject access is received frm a student, the schl s plicy is that: Requests frm students will be prcessed as any subject access request as utlined belw and the cpy will be given directly t the student unless it is clear that the student des nt understand the nature f the request. Requests frm students wh d nt appear t understand the nature f the request will be referred t their parents r carers. Requests frm parents in respect f their wn child will be prcessed as requests made n behalf f the data subject (the child) and the cpy will be sent securely t the requesting parent r carer. Prcessing Subject Access Requests Requests fr access must be made in writing. Students, parents r staff may ask fr a Data Subject Access frm, available frm the Schl Office. Cmpleted frms shuld be submitted t the SIMS Data Manager. Prvided that there is sufficient infrmatin t prcess the request, an entry will be made in the Subject Access Lg Bk, shwing the date f receipt, the data subject s name, the name and address f requester (if different), the type f data required (e.g. Student Recrd, Persnnel Recrd), and the planned date f supplying the infrmatin (nt mre than 40 calendar days frm the request date). Shuld mre infrmatin be required t establish either the identity f the data subject (r agent) r the type f data requested, the date f entry in the lg will be the date n which sufficient infrmatin has been prvided. Authrised Disclsures Crfe Hills Schl will, in general, nly disclse data abut individuals with their cnsent. Hwever there are circumstances under which Crfe Hills Schl s authrised fficer may need t disclse data withut explicit cnsent fr that ccasin. These circumstances are strictly limited t: Student data disclsed t authrised recipients related t educatin and administratin necessary fr the schl t perfrm its statutry duties and bligatins. Student data disclsed t authrised recipients in respect f their child s health, safety and welfare. Student data disclsed t parents in respect f their child s prgress, achievements, attendance, attitude r general demeanur within the vicinity f the schl. Staff data disclsed t relevant authrities e.g. in respect f payrll and administrative matters. Unavidable disclsures, fr example t an engineer during maintenance f the cmputer system. In such circumstances the engineer wuld be required t sign a frm prmising nt t disclse the data utside the schl. Only authrised and trained staff are allwed t make external disclsures f persnal data. Data used within the schl by administrative staff, teachers and welfare fficers will nly be made available where the persn requesting the infrmatin is a prfessinal legitimately wrking within the schl, wh need t knw the infrmatin in rder t d their wrk. We will nt disclse anything n students recrds which wuld be likely t cause serius harm t their physical r mental health r that f anyne else including anything where it suggests that they are, r have been, either the subject f r at risk f child abuse.
5 A legal disclsure is the release f persnal infrmatin frm the cmputer t smene wh requires the infrmatin t d his r her jb within r fr the rganisatin, prvided that the purpse f that infrmatin has been registered. An illegal disclsure is the release f infrmatin t smene wh des nt need it, r has n right t it, r ne which falls utside the rganisatin s registered purpses. Data and Cmputer Security Crfe Hills Schl undertakes t ensure security f persnal data by the fllwing general methds (precise details cannt be revealed): Physical Security Apprpriate building security measures are in place, such as alarms, windw bars, deadlcks and cmputer hardware cable lcks. Only authrised persns are allwed in the cmputer rm. Disks, tapes and printuts are lcked away securely when nt in use. Visitrs t the schl are required t sign in and ut, t wear identificatin badges whilst in the schl and are, where apprpriate, accmpanied. Lgical Security Security sftware is installed n all cmputers cntaining persnal data. Only authrised users are allwed access t the cmputer files and passwrd changes are regularly undertaken. Cmputer files are backed up (i.e. security cpies are taken) regularly. Prcedural Security In rder t be given authrised access t the cmputer, staff will have t underg checks and will sign a cnfidentiality agreement. All staff are trained in their Data Prtectin bligatins and their knwledge updated as necessary. Cmputer printuts as well as surce dcuments are shredded befre dispsal. Overall security plicy fr data is determined by the Gverning Bdy and is mnitred and reviewed regularly, especially if a security lphle r breach becmes apparent. Crfe Hills Schl s security plicy is kept in a safe place at all times. Any queries r cncerns abut security f data in the schl shuld in the first instance be referred t Philip Keen. Individual members f staff can be persnally liable in law under the terms f the Data Prtectin Acts. They may als be subject t claims fr damages frm persns wh believe that they have been harmed as a result f inaccuracy, unauthrised use r disclsure f their data. A deliberate breach f this Data Prtectin Plicy will be treated as a disciplinary matter, and serius breaches culd lead t dismissal. Further details n any aspect f this plicy and its implementatin can be btained frm Philip Keen. Additinal advice and infrmatin can be btained frm the Infrmatin Cmmissiner s website
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