Data Protection Policy

Ravenswell Primary School

Data Protection Privacy Statement for Parents, Guardians and Pupils

Effective from May 10th 2022

Policy Ratified This plan was updated and ratified by the Board of Management at its meeting on: May 9th 2022 and is subject to change, in light of any necessary updates. Signed: (Ann Quinlan, Chairperson, Ravenswell Primary School)

Individuals have a number of rights in relation to their personal information – i.e. personal data – and these rights have been enhanced by the General Data Protection Regulation (GDPR).This Data Protection Statement describes how we at Ravenswell Primary School collect and process personal data, in accordance with the GDPR and the school’s legal obligations generally in relation to the provision of education.  Processing is the legal term used to describe various acts including – the collection, recording, organisation, structuring, storage, alteration, use of, retrieval, disclosure or transmission of information.

This Statement applies to all school staff, the Board of Management, pupils, parents/ guardians and others (including prospective or potential students and their parents/guardians and applicants for staff positions within the school). By enrolling your child in and/or by attending Ravenswell Primary School you acknowledge and agree to the collection and processing of personal information by the school. 

For your information this Statement outlines:

  • Who we are and how to contact us;
  • What information we collect, process and retain;
  • How information is collected and processed and the purpose and legal basis for so doing;
  • Sharing information with third parties;
  • Individual legal rights.

1.                   WHO WE ARE AND HOW TO CONTACT US

Ravenswell Primary School is a data controller responsible for personal data – i.e. information relating to an identified or identifiable natural person. Ravenswell Primary School processes personal data, i.e. the school collects, records, stores, retains and uses personal data. Ravenswell Primary School will respond to your questions in relation to this data protection statement and our approach to privacy.

If you have any questions about this data protection statement, including any request to exercise your legal rights, please contact us using this email: office@ravenswell.ie    

2.                   INFORMATION COLLECTED

Ravenswell Primary School may collect the following personal information on pupils and parents/guardians:

(i)             Pupil Information

  • Personal details such as name, address, date of birth, gender, PPS number, nationality, emergency contact information and information in relation to the pupil’s family as may be required,
  • Any Special Education Needs (SEN),
  • Any Child Protection information,
  • Academic records, school reports, pupil learning needs, pupil behaviour needs, permission for access to educational reports, individual education and learning support plans, Standardised Test Results
  • Personal pupil profiles (including whether English is the pupil’s first language or if exempt from any subjects e.g. Irish or religion),  Psychological referral/assessment documentation and permission for access to   psychological reports,
  • Information for the Primary Online Database (POD),
  • Information for Special Educational Needs Organiser (SENO),
  • Information for TUSLA (the Child and Family Agency) and/or the Health Service Executive (HSE),
  •  Attendance records and explanatory notes in relation to absences,
  • Incident logs that may be posted by teacher(s) on Aladdin, incident and accident reports, investigations and sanctions if imposed,
  • Permission notes in respect of school activities e.g. school tours/trips and outings, extra-curricular activities such as swimming at Shoreline Swimming Pool,
  • Photographs and recorded images of pupil(s) (including at school events),
  • CCTV footage and other information obtained through electronic means. To note: Facilities Management CCTV at main door and reception only. (Reviewed and managed by FM). Additional cameras at the school gate entrance were installed in late 2021 (Managed by FM and Coláiste Ráithín). Ravenswell Board of Management installed 11 additional cameras in early 2022 (managed by BOM and Custodian Security. Facilities Management have access to the cameras also)
  • HSCL, Headlamps project,  School Completion Programme and Summer Camps,
  • Information about pupil’s health, medical certificates, medical needs, allergies and consent for administration of medicine,
  • Religious belief,
  • Membership of the Traveller Community, Racial or Ethnic origin,
  • Languages spoken at home

The information on students is stored in two formats: both manual files containing hard copy of forms signed etc. and on computer files backed up and stored via the Aladdin system or on the office administration computers.

Purposes: The purpose for keeping student records includes the following:

  • to enable each student to develop his/her full potential.
  • to comply with legislative and administrative requirements.
  • to ensure that eligible students can benefit from the relevant additional teaching/ resource/ other supports.
  • to support the provision of support teaching.
  • to support the provision of religious instruction and sacramental preparation.
  • to ensure that the student fulfils the criteria for the exemption from Irish.
  • to enable parents/guardians to be contacted in the case of emergency/ school closure etc.
  • to ensure that the pupil meets the school’s admission criteria.
  • to maintain a record of the student’s progress through school.
  • to maintain accurate accident/incident reports.
  • to communicate clearly with all educational partners.
  • to support medical/special needs conditions within the school environment.
  • photographs and recorded images of students are taken to celebrate school achievements, compile yearbooks, establish a school website, record school events, and to keep a record of the history of the school. Such records are taken and used in accordance with the school’s Acceptable Usage Policy ie: parents need to give consent for photographs to be used.
  • to furnish documentation/ information about the student to the Department of Education and Skills, the National Council for Special Education, TUSLA, Health Services, and other Schools etc. in compliance with law and directions issued by government departments.

Location:

Records are kept in a secure locked room in a locked filing cabinet that only personnel who are authorised to use the data can access. Additional Information is also stored on the Aladdin data system. Administrators have access to the full school data. Teachers have access via Aladdin to their own class data only. Employees are required to maintain the confidentiality of any data to which they have access. Confidential reports, child protection report forms, Continuum of Support documents are password controlled within the Aladdin system.

(ii)            Parent / Guardian Information

Ravenswell Primary School may collect and process the following personal information from parents/guardians such as:

  • Contact details of parent / guardian e.g. name, address, email address, telephone number(s)
  • Information regarding legal orders in respect of any family law disputes in respect of guardianship, custody or access,
  • Nationality, racial or ethnic origin
  • Consent in respect of medical/other emergencies,
  • Consent in respect of school activities e.g. school tours/trips and outings, extra-curricular activities,
  • Consent to publish photographs and schoolwork of pupils on school website / print media etc.,
  • Records, correspondence or notes arising from interaction with Parents / Guardians.

Purpose:

  • to furnish documentation/ information about the student to the Department of Education and Skills, the National Council for Special Education, TUSLA, Health Services, and other Schools etc. in compliance with law and directions issued by government departments.
  • to comply with legislative and administrative requirements.
  • to ensure that eligible students can benefit from the relevant additional teaching / resource/ other supports i.e. The Book Grant Scheme/ Lunch scheme
  • to enable parents/guardians to be contacted in the case of emergency/ school closure etc.
  • to ensure that the pupil meets the school’s admission criteria.
  • to communicate with all educational partners.
  • to support medical/special needs conditions within the school environment.
  • to gain permission for photographs and recorded images of students taken to celebrate school achievements, compile yearbooks, establish a school website, record school events, and to keep a record of the history of the school. Such records are taken and used in accordance with the school’s Acceptable Usage Policy ie: parents need to give consent for photographs to be used.

Location:

Hard copy records are kept in a secure locked room in a locked filing cabinet that only personnel who are authorised to use the data can access. Additional soft copy information is also stored on the Aladdin data system. Administrators have access to the full school data. Teachers have access via Aladdin to their own class data only. Employees are required to maintain the confidentiality of any data to which they have access. Confidential reports, child protection report forms, Continuum of Support documents are password controlled within the Aladdin system or management files.

(iii)       Staff Records

Ravenswell Primary School may collect and process the following personal information from staff such as:

  • Name, address and contact details, PPS number, Teacher Number, Teaching Council Number.
  • Name and contact details of next-of-kin in case of emergency.
  • Original records of application and appointment to promotion posts
  • Details of approved absences (career breaks, parental leave, study leave, etc.)
  • Details of work record (qualifications, classes taught, subjects, etc.)
  • Details of any accidents/injuries sustained on school property or in connection with the staff member carrying out their school duties
  • Records of any reports the school (or its employees) have made in respect of the staff member to State departments and/or other agencies under Children First Act 2015
  • Special Needs Assistants’ Incidents Logs
  • School Diaries

Purposes: Staff records are kept for the following purposes:

  • The management and administration of school business (now and in the future).
  • to facilitate the payment of staff, and calculate other benefits/ entitlements (including reckonable service for the purpose of calculation of pension payments, entitlements and/or redundancy payments where relevant).
  • human resources management.
  • recording promotions made (documentation relating to promotions applied for) and changes in responsibilities etc.
  • to enable the school to comply with its obligations as an employer including the preservation of a safe, efficient working and teaching environment (including complying with its responsibilities under the Safety, Health and Welfare At Work Act. 2005).
  • to enable the school to comply with requirements set down by the Department of Education and Skills, the Revenue Commissioners, the National Council for Special Education, TUSLA, the HSE, and any other governmental, statutory and/or regulatory departments and/or agencies for compliance with legislation relevant to the school.

Location: These records are kept as manual records in a secure/lockable filing cabinet in the Principal’s office that only personnel who are authorised to use the data can access. After a period highlighted in the Retention Schedule as part of this policy, these records are moved to a locked data room. After a further period, some data is destroyed, as noted in the Retention Schedule. Employees are required to maintain the confidentiality of any data to which they have access. Some information is also stored on the office computers which are password protected and have firewall software such as Bull installed or downloaded. Such protective software is regularly updated. Information is also regularly backed up.

Each staff member’s information such as Personal Contact details, PPS numbers, Teacher Number, Teaching Council Number, class records, duty lists and reports are kept recorded in the office or on Aladdin. Online banking system is used to facilitate the payments for extracurricular activities.

Records of promotions, career breaks, leave taken, illness etc., is available through the Department of Education and Skills Online Claims System (OLCS/ESINET).

(iv)       Board of Management

Board of Management records maintained include:

  • Name, address and contact details of each member of the Board of Management.
  • Records in relation to appointments to the board.
  • Minutes of board of management meetings.
  • Financial statements/ audits and certification of accounts.
  • Record of how funding from the DES is managed.
  • Correspondence to the board.

Purpose: The purpose for keeping Board of Management records include:

  • A record of board appointments
  • A record of how legislative requirements are carried out
  • A record of staff appointments
  • Documenting decisions made by the board.
  • A record of how enrolment to the school is managed
  • A record of the financial management of the school
  • A record of the development of the school
  • A record of how health and safety issues within the school are managed
  • A record of policy development within the school
  • A record of insurance cover and related issues
  • A record of capital development and building/grounds maintenance
  • Documentation relating to grievance and disciplinary procedures

Location:

Records are kept in folders in a secure locked room in a locked filing cabinet that only personnel who are authorised to use the data can access. Soft Copies are in a safe password file on the principal’s computer.

3.         PURPOSE & LEGAL BASIS FOR COLLECTING & PROCESSING INFORMATION

Ravenswell Primary School collects and processes personal information (as listed above) about pupils and parents / guardians for a variety of purposes and relies on a number of legal grounds to do so. Ravenswell Primary School requires this information to perform our duties and responsibilities and to comply with our legal and statutory obligations. 

In addition, Ravenswell Primary School requires this personal information to pursue the legitimate interests of the school and our dealings with relevant third parties (see below). The legitimate interests upon which we rely is the effective operation and management of Ravenswell Primary School and managing the education and welfare needs of our pupils. Ravenswell Primary School processes personal data on the basis of the following lawful purposes:

a)   Legal Obligation

Ravenswell Primary School collects and processes personal information to comply with our legal and statutory obligations, including, but not limited to those under the Education Act 1998 (as Amended), the Education (Welfare) Act 2000, the Education for Persons with Special Needs (EPSEN) Act 2004, the Health Act 1947, the Children First Act 2015, the Child Protection Procedures for Primary and Post-Primary Schools 2017, the Teaching Council Acts 2001-2015 and Safety Health and Welfare at Work legislation.

b)   Legitimate Interests

Ravenswell Primary School may also process personal information to:

  • Enable Pupils to develop to their full potential and meet the educational, social, physical and emotional requirements of the pupil,
  • Enable Parents and Guardians to be contacted in the case of emergency, school closures and to inform Parents and Guardians of their child’s educational progress,
  • Secure and benefit from the support and services of relevant third parties.

c)   Consent

Ravenswell Primary School sometimes processes some pupils’ personal information with consent e.g. photograph which may be displayed on the school’s website or on social media platforms or in the print media. Please note that consent can be withdrawn at any time by contacting the school. This is highlighted in the Acceptable Usage Policy.

4.         HOW PERSONAL INFORMATION IS COLLECTED

(i)           Pupils

Ravenswell Primary School collects personal information about pupils through the enrolment process. Additional information is collected from third parties, including former schools and through school activities, assessments and general interaction(s) during the course of the pupil’s time at Ravenswell Primary School.

(ii)            Parents and Guardians

Ravenswell Primary School collects personal information about parents and guardians through the enrolment process. We collect additional personal information through general interaction during the course of the pupil’s time at Ravenswell Primary School.

(iii)         Staff

Ravenswell Primary School collects personal information about staff through the application and appointment process. We collect additional personal information through general interaction during the course of the employee’s time at Ravenswell Primary School.

(iv)          Board of Management

Ravenswell Primary School collects personal information about The Board of Management members through the appointment process.

 5.         INFORMATION AND THIRD PARTIES

Ravenswell Primary School may receive from, share and/or transfer information to a range of third parties such as the following:

  • The Department of Education (DES)
  • TUSLA – the Child and Family Agency & TUSLA Education Support Service (TESS)
  • Health Service Executive (HSE)
  • The National Council for Special Education (NCSE)
  • National Educational Psychological Service (NEPS)
  • Department of Social Protection and/or other state benefit providers
  • An Garda Síochána
  • School Insurance Provider
  • PPP co. /NDFA and Sensori Co.
  • Third Party Service Providers: We may share personal information with third party service providers that perform services and functions at our direction and on our behalf such as our accountants, IT service providers including, printers, lawyers and other advisors, and providers of security and administrative services, including data processing / cloud storage service providers e.g. Aladdin being our administrative system.
  • Other schools (School Transfers)
  • Headlamps Project, School Completion Programme, Burns By Your Side Reading Dog Programme, External Sports coaches or teachers.
  • Universities, Colleges of Further Education etc.

6.         DATA RETENTION

We will only retain personal information for as long as it is necessary to fulfil the purposes the information was collected for, including any legal, accounting or reporting requirements.

  • –       See Records Retention Schedule

7.         TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EUROPEAN UNION

Ravenswell Primary School may transfer the personal information we collect to countries outside the EU.  Where there is no adequacy decision by the European Commission in respect of any such country that means that that country is deemed not to provide an adequate level of protection for your data.  However, to ensure personal information does receive an adequate level of protection we will in such circumstances put in place appropriate measures such as the use of model contractual clauses as approved by the European Commission to ensure personal information is treated by those third parties in ways that are consistent with respect to EU and Irish Laws on Data Protection.

8.          INDIVIDUAL RIGHTS

Individuals have several rights under GDPR which in certain circumstances are limited and/or constrained. These individual rights include the right (free of charge and subject to any limitations as may apply) to:

  1. Request a copy of the personal information held about the individual;
  2. Rectify any inaccurate personal data held about the individual;
  3. Erase personal information held about the individual;
  4. Restrict the processing of individual personal information;
  5. Object to the use of individual personal information for our legitimate interests;
  6. Receive individual personal information in a structured commonly used and machine-readable format and to have that data transmitted to another data controller.

If you wish to exercise any of these rights please contact us at the school as outlined office@ravenswell.ie  with Request for Data in the subject line.

Ravenswell Primary School will endeavour to respond to your request within a month.  If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why.

You also have the right to lodge a complaint to the office of the Data Protection Commission.

 9.        UPDATES

We will update this data protection statement as necessary. Any updates will be made available and, where appropriate, notified to you.