Data Protection Policy
Ysgol Coed-Y-Gof collects and uses personal information about staff, pupils, parents and other individuals who come into contact with the school. This information is gathered in order to enable it to provide Education and other associated functions. In addition, there may be a legal requirement to collect and use information to ensure that the School complies with its statutory obligations.
Schools have a duty to inform individuals including parents and pupils of the information that it holds. This information should summarise why it is held and any other parties to whom this may be passed on to. Schools will advise individuals through Fair Processing in concise, transparent, plain language and free of charge.
This policy is intended to ensure that personal information is dealt with correctly and securely and in accordance with the General Data Protection Regulation (GDPR), and other related legislation. It will apply to information regardless of the way it is collected, used, recorded, stored and destroyed, and irrespective of whether it is held in paper files or electronically.
All staff involved with the collection, processing and disclosure of personal data will be aware of their duties and responsibilities by adhering to these guidelines.
What is Personal Information?
Personal information or data is defined as data that relates to a living individual who can be identified from that data, or other information held as defined within the GDPR.
General Data Protection Regulation (GDPR) Principles:
The GDPR establishes six enforceable principles that must be adhered to at all times in that information must be:
The School is committed to maintaining the above principles at all times. Therefore, the school will:
Appropriately and securely
Rights of access to information
There are two distinct rights of access to information held by Schools about pupils:
1. Under the GDPR any individual has the right to make a request to access the personal information held about them.
2. The right of those entitled to have access to curricular and educational records as defined within the Education Pupil Information (Wales) Regulations 2004.
The GDPR provides the following rights for individuals:
The school will provide concise, transparent, intelligible and easily accessible information about the processing of personal data to individuals via the Privacy Notice. This will be written in clear plain language and will clearly set out how personal data is processed within the school
The school will provide individuals with access to their personal data and supplementary information; this will be processed as a subject access request. Subject Access Requests will be free of charge and processed in line with the statutory requirements and timeframes.
The school is committed to rectifying personal data if inaccurate or incomplete and notifying any relevant third parties of this.
The school will respond to a request for rectification within one month of receiving the request, if the request for rectification is deemed complex this will be responded to within two months.
If the school cannot take action in response to a request for rectification we will provide a written explanation of this, an individual will then have a right to complain to the schools data protection officer.
The school will consider individual requests for deletion or removal of personal data where there is no compelling reason for its continued processing.
Schools will inform relevant third parties of erasure of personal data; unless it is impossible, r involves disproportionate effort to do so.
The school will ensure that data processing is restricted in any of the following circumstances:
If data processing is restricted, the school will notify any relevant third parties.
The school will comply with individual requests to data portability free of charge and within one month of receiving the request.
The school will comply with individuals right to object and will stop processing personal data unless there are compelling legitimate grounds for processing or the processing is in relation to a legal claim.
The school will inform individuals of their right to object at the point of first communication in the schools Privacy Notice.
The school will not use automated decision making nor profile any individuals.
The school clearly sets out within its Privacy Notice what information we collect/use and why this is relevant.
Subject Access Requests
The school will process all subject access requests and provide a copy of the information free of charge and within one month of receipt.
The school will charge a fee when a request is manifestly unfounded or excessive, particularly if it is repetitive,
Further copies of the information can be provided at a reasonable charge,
If requests are complex or numerous the school has the right to extend the period of compliance by a further two months. The school will notify individuals if this occurs.
If a request is manifestly unfounded or excessive the school has the right to refuse this request, the school will notify the individual and explain why they cannot comply with the request and inform them of their right to complain to the schools data protection officer.
The school will verify the identity of the individual making the request using reasonable means.
Complaints in relation to processing of personal data should be addressed to the schools data protection officer.
This policy will be reviewed on an annual basis. The policy review will be undertaken by the Headteacher, or nominated representative.
If you have any enquires in relation to this policy, please contact Aled Williams on 02920564585 who will also act as the contact point for any requests for personal data.
Further advice and information is available from the Information Commissioner’s Office:
The Information Commissioners Office
Telephone: 0303 123 1113 – Helpline is open from 9am to 5pm, Monday to Friday