Staff Privacy Notice

Staff Privacy Notice - How we use school workforce information

This page provides insight into how we use information about school staff including supply teachers, volunteers and job applicants. For job applicants and volunteers, information will only be collected and shared as relevant to their role.

The categories of school workforce information that we collect, process, hold and share include:

  • Personal information (such as name, DOB, employee or teacher number, national insurance number, contact details, payroll/banking details for paid staff, DBS checks, passport, other documents proving identity);
  • Special categories of data including characteristics information such as gender, age, ethnic group, trade union membership (only where deductions are made directly from the payroll system);
  • Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process;
  • Qualifications (and, where relevant, subjects taught);
  • Contract information (such as start dates, hours worked, post, roles and salary information);
  • Work absence information (such as number of absences and reasons);
  • Outcomes of any disciplinary and/or grievance procedures;
  • Data about your use of the school’s information and communications systems;
  • Relevant medical information;
  • Information relating to the performance of paid staff; and
  • Declarations about suitability to work relating to the Childcare (Disqualification) Regulations.

Why we collect and use this information

We use school workforce data to:

  • Enable individuals to be paid and inform HMRC and pensions administrators;
  • Enable the development of a comprehensive picture of the workforce and how it is deployed;
  • Inform the development of recruitment and retention policies;
  • Facilitate safe recruitment, as part of our safeguarding obligations towards pupils;
  • Support effective performance management;
  • Forecast the school’s financial performance (projected salary costs); and
  • Provide information for emergencies.

The lawful basis on which we process this information

We process this information in order to comply with the Education Act 1996 and under the 2018 GDPR Articles below, as included in the Data Protection Act 2018:

  • 6(c) processing is necessary for compliance with a legal obligation to which the controller is subject;
  • 6(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and
  • 9(b) processing is necessary for the purposes of carrying out the obligations and exercising specific
    rights of the controller or of the data subject in the field of employment and social security and
    social protection law.

Collecting this information

We collect personal information generally through new starter documentation and updates provided to us throughout your employment. We also maintain payroll and contract records and update them as changes arise.
Whilst the majority of information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with data protection legislation, we will inform you whether you are required to provide certain school workforce information to us or if you have a choice.

Storing this information

We hold school workforce data on local and cloud-based computer systems, as well as on paper. There are strict controls on who can see your information. We will hold data for a long as necessary in line with our retention schedule, after which the information will be securely destroyed.

Who we share this information with

We routinely share this information with:

  • our payroll provider;
  • our supply insurance provider;
  • our online training provider;
  • our DBS check provider;
  • the Department for Education (DfE);
  • our budgeting software provider; and
  • our occupational health provider.

Why we share school workforce information

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

Department for Education (DfE)
We share personal data with the DfE on a statutory basis. This data sharing underpins workforce policy monitoring, evaluation, and links to school funding/expenditure and the assessment educational attainment.

Payroll provider
Your data will be held by our payroll provider to enable us to process payments to you.

Budgeting software provider
Your data will be held by our budgeting software provider to enable the school to forecast its future salary costs and forecast its future financial position.

Data collection requirements
The DfE collects and processes personal data relating to those employed by schools (including Academy Trusts) and Local Authorities. All state funded schools are required to make a census submission because it is a statutory return under sections 113 and 114 of the Education Act 2005.

To find out more about the data collection requirements placed on us by the DfE including the data that we share with them, go to https://www.gov.uk/guidance/school-workforce-census.

The workforce data that we lawfully share with the DfE through data collections:

  • informs departmental policy on pay and the monitoring of the effectiveness and diversity of the school workforce; 
  • links to school funding and expenditure; 
  • supports ‘longer term’ research and monitoring of educational policy.

The DfE may share information about school employees with third parties who promote the education or well-being of children or the effective deployment of school staff in England by:

  • conducting research or analysis;
  • producing statistics; and
  • providing information, advice or guidance.

The DfE has robust processes in place to ensure that the confidentiality of personal data is maintained and there are stringent controls in place regarding access to it and its use. Decisions on whether DfE releases personal data to third parties are subject to a strict approval process and based on a detailed assessment of:

  • who is requesting g the data;
  • the purpose for which it is required;
  • the level and sensitivity of data requested; and
  • the arrangements in place to securely store and handle the data.

To be granted access to school workforce information, organisations must comply with its strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the DfE data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

To contact the DfE: https://www.gov.uk/contact-dfe

Requesting access to your personal data

Under data protection legislation, you have the right to request access to information about yourself that we hold. To make a request for your personal information, please contact the school using the details at the end of this document.

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress;
  • prevent processing for the purpose of direct marketing; 
  • object to decisions being taken by automated means; 
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and 
  • claim compensation for damages caused by a breach of the Data Protection regulations, either through the ICO or through the courts.

If you have concerns about the way we are collecting or using your personal data, we ask that you raise them with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.

If you would like more information about the information that Wokingham Local Authority holds about you, please contact: Data Protection Officer, Wokingham Borough Council, Shute End, Wokingham RG40 1WH. More information and an online form are available via this link:
http://www.wokingham.gov.uk/council-and-meetings/information-and-data-protection/

Further information

If you have any questions, concerns or would like more information about anything mentioned in this Privacy Notice, please contact BPET's Data Protection Officer, Head of Operations - Jane Aust at: dataprotectionofficer@bpet.co.uk