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Privacy Policy

We take your privacy very seriously therefore we urge you to read this policy caefully because it contains imporant information about:

• Who we are
• What information is collected
• How and why we collect, store and share personal information
• Your rights in relation to your personal information
• How to contact us and supervisory authorities in the event that you have a complaint

Who we are

Ysgol Sarn Bach (‘we’ or ‘us’) collect, use and are responsible for certain personal information about you as the ‘data controller’. When we do so, we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as the ‘data controller’ of that personal information for the purposes of thoes laws.

The personal information of pupils we collect and use:

• Personal identifiers and contacts (name, date of birth, gender, address, unique pupils number (UPN), email address, emergency contact details)

• Characteristics (ethnicity, nationality, home language, free school meal eligibility)

• Dinner Money Payments and child’s meal pattern

• Safeguarding information (court orders, proffesional involvement and reports - social Services and child protection, relevant background family information)

• Special educational needs (needs and ranking including ‘More able and talented’ information)

• Attendance (sessions attended, number and reason of absences

• Medical and administration (doctors information, allergies, medication and dietary requirements)

• Assessment and attainment (results from statuory and non statuory tests,educational history, expected levels of acheivement, annual and term reports)

• Behavioural information (exclusions and any provisions put in place)

• Timetable and classes attended (including musical instrument lessons)

• Permission for school trips and published photographs (including name and date of permission giver)

• Details of person(s) permitted to collect pupil from school

We collect and use pupil data for the following purposes:

• To support pupil learning
• To monitor and report on pupil attainment progress
• To provide appropriate pastoral care
• To asses the quality of our Services
• To keep children safe (food allergies, emergency contact details, CCTV images, details of permitted collector)
• To meet statutory requirements for use with data collections

We may use your information for automated decision making, including profiling. This is where we make a decision automatically about you without human intervention

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing pupil information are:

• Processing is necessary for compliance with a legal obligation to which the controller is subject

• Processing is necessary in order to protect the vital interests of the data subject or of another natural person

• Processing is necessary for the purpose of a task caried out in the public interest or in the exercise of official authority vested in the controller

In addition, concerning any special category data

• Processing is necessary for the purpose of carrying out obligations and excersisng specific rights of the controller or of the data subject providing for appropriate safeguards for the fundamental rights and the interests of the data subject
• Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
• Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes. This shall be proportionate to the aim pursued, respect the essence of the right to data protection and safeguard the fundamental rights and interests of the data subject.

The legal obligations for processing pupil information are :

• The Education (school information) (Wales) Regulations 2011
• The Education (pupil information) (Wales) Regulations 2011
• The Education (school performance and absence targets) (Wales) Regulations 2011
• The Education (Head of Parents and Adults Report) (Wales) Report 2011
• Data Protection Act 1998
• General Data Protection Regulation and Data Protection Act 2018
• Freedom of Information act 2012
• Additional Learning needs and the Educational Tribunal (Wales) Act 2018
• The Government of Maintained Schools (Wales) Regulations 2005
• Social Services and Wellbeing Act 2014
• Equality Act 2010
• The Regulation (Fire Safety) Order 2005/ Regulatory Reform (Fire Safety) Order 2005 (PEEPS forms are completed and these include details of any disabilities that a child / staff has)

Collecting Pupil Information

We collect pupil information via registration forms when starting at the school and receive some data via a Common Transfer File (CTF) if a child is transferring to us from another school
Although most information about a pupil you provide for us is compulsory, some will be provided on a voluntary basis

In order to comply with data protection legislation, we will inform you whether you will be required to provide us with specific information about a pupil or if you have an option to do this.

If you provide information on a voluntary basis, we will ask you to give specific permission and give you the option to withdraw the permission at any time

Storing Pupil Data

We hold pupil data securely for the set amount of time as shown in our data retention schedule. For more information on our data retention schedule please visit the data protection policy on our website www.ysgolsarnbach.org

Who we share pupil information with

We routinely share pupil information with:

• Schools attended by the pupils when they leave us
• Gwynedd Council, Local Authority - School Counselor, Welfare Officer, Social Services, Leisure, Transport, Finance, Derwen, GwE, Additional Learning Needs and Inclusion,
• Betsi Cadwalader University Healthboard – School nurse, dentist, Camhs,
• Police and the youth offending team
• Language Centres and/or therapists (where necessary)
• Welsh Assembly Government
• School Governors (only as applicable)
• Cynnal –via SIMS (school information managemnet system)

Agencies we commission to provide Services on our behalf

• Llywodraeth Cymru (via HwB)
• GwE
• Cynnal
• Capita – SIMS
• Capita – SchoolComms
• Capita – SchoolGateway
• Incerts
• FischerFamilyTrust (FFT)
• Antur Waunfawr(disposing of confidential waste)
• Edufocus trwy Evolve
• Boxall
• Google Drive
• My Concern
• Delwedd
• Tempest(school photographs)

Relevant Companies that promote the administration and learning experiences of our pupils

• Llywodraeth Cymru - via HwB
• GwE
• Further Education Colleges - Coleg Menai, Coleg Meirion Dwyfor, Coleg Llandrillo
• Plas Menai
• Purple Mash
• Seesaw
• Urdd Gobaith Cymru
• Google Classrooms
• William Mathias

COVID-19 Pandemic 2020

It may not always be possibe to reflect all the new or changed uses of personal data that may happen as a response to the COVID-19 Pandemic.

The personal data that may be shared includes:

• Name
• Email Address
• Telephone Number

Legal Basis for processing your personal data

• Processing is necessary for the performance of a task caried out in the Public interest or in the exercise of official authority vested in the controller (Article 6(1) GDPR)
• Regulation 12 of the Health Protection (Coronavirus Restrictions)(no 2)(Wales) Regulations 2020 requires reasonable measures to be taken to minimise the risk of exposure to coronavirus on premises open to the public and on any premises where work takes place.

Sharing your personal data

During the COVID-19 Pandemic, we may need to share your information with:
The Cyngor Gwynedd ‘Track and Trace’ team for the purposes of contacting persons who may have been exposed to Coranvirus.
This will be done in a way that complies with the data protection legislation.

Why we regularly share pupil information

We do not share information about our pupils with anyone without consent unless the law and our policies allow us to do so.

We share data about pupils with the Welsh Assembly Government on a statuory basis. Sharing data in this way underpins school funding and monitors educational attainment.

We are required to collect data under The Education (Pupil Information) (Wales) Regulations 2011 and The Education (School Performance and Absence Targets) (Wales) Regulations 2011.

We are required to share information about our pupils with our Local Authority of Gwynedd Council and the Assembly Government under The Education (Pupil Information) (Wales) Regulations 2011

Request to Access your personal data

Under the Data protection legislation, parents and pupils have the right to request Access to the information we hold about them. To apply for your personal information, or request Access to your child’s educational record, please contact either of the following:

Headteacher Schools Data Protection Officer Ysgol Sarn Bach Cyngor Gwynedd Council
Sarn Bach Castle Street
Abersoch Caernarfon
Gwynedd Gwynedd
LL53 6EA LL55 1SH

You also have the right to:

• Object to personal data being processed that is likely to cause, or causes damage or distress
• Preventing anything from being processed for direct marketing purposes
• Oppose decisions that are made by automated methods
• Correct, Obstruct, eliminate or destroy incorrect personal data in certain circumstances
• Claim compensation for the damage caused as a result of breach of Data Protection

Regulations

If you have concerns about the way we collect or use your personal data, we ask you to raise your concern with us in the first instance. Alternatively, you can contact the information Commissioner’s Office (ICO) through https://ico.org.uk/concerns

Updating this privacy notice

We may need to update this privacy notice periodically so we recommend that you revisit this information from time to time. This version was last updated January 2021

Contact

If you would like to discuss anything in this privacy notice, please contact either of the following: