DATA PROTECTION POLICY 2018
INTRODUCTORY STATEMENTThe school’s Data Protection Policy applies to the personal data held by the school’s Board of Management (BoM), which is protected by the Data Protection Acts 1988 to 2018 and the EU General Data Personal Regulation (GDPR)
The policy applies to all school staff, the Board of Management, parents/guardians, pupils and others (including prospective or potential pupils and their parents/guardians and applicants for staff positions within the school) insofar as the measures under the policy relate to them. Data will be stored securely, so that confidential information is protected in compliance with relevant legislation. This policy sets out the manner in which personal data and special categories of personal data will be protected by the school
OLOM operates a “Privacy by Design” method in relation to Data Protection. This means we plan carefully when gathering personal data so that we build in the data protection principles as integral elements of all data operations in advance. We audit the personal data we hold in order to:
1. Obtain and process Personal Data fairlyInformation on pupils is gathered with the help of parents/guardians and staff. Information is also transferred from their previous schools. In relation to information the school holds on other individuals (members of staff, individuals applying for positions within the School, parents/guardians of pupils, etc.), the information is generally furnished by the individuals themselves with full and informed consent and compiled during the course of their employment or contact with the School. All such data is treated in accordance with the Data Protection legislation and the terms of this Data Protection Policy. The information will be obtained and processed fairly
2.ConsentWhere consent is the basis for provision of personal data, (e.g. data required to join sports team/ after-school activity or any other optional school activity) the consent must be a freely-given, specific, informed and unambiguous indication of the data subject’s wishes. Our Lady of Mercy will require a clear, affirmative action e.g. ticking of a box/signing a document to indicate consent. Consent can be withdrawn by data subjects in these situations
3. Keep it only for one or more specified and explicit lawful purposesThe BoM will inform individuals of the reasons they collect their data and the uses to which their data will be put. All information is kept with the best interest of the individual in mind at all times
4. Process it only in ways compatible with the purposes for which it was given initiallyData relating to individuals will only be processed in a manner consistent with the purposes for which it was gathered. Information will only be disclosed on a ‘need to know’ basis, and access to it will be strictly controlled
5. Keep Personal Data safe and secureOnly those with a genuine reason for doing so may gain access to the information. Personal Data is securely stored under lock and key in the case of manual records and protected with computer software and password protection in the case of electronically stored data. Portable devices storing personal data (such as laptops) are encrypted and password-protected.
6. Keep Personal Data accurate, complete and up-to-datePupils, parents/guardians, and/or staff should inform the school of any change which the school should make to their personal data and/or sensitive personal data to ensure that the individual’s data is accurate, complete and up-to-date. Once informed, the school will make all necessary changes to the relevant records. Records must not be altered or destroyed without proper authorisation. If alteration/correction is required, then a note of the fact of such authorisation and the alteration(s) to be made to any original record/documentation should be dated and signed by the person making that change
7. Ensure that it is adequate, relevant and not excessive
Only the necessary amount of information required to provide an adequate service will be gathered and stored
8. Retain it no longer than is necessary for the specified purpose or purposes for which it was givenAs a general rule, the information will be kept for the duration of the individual’s time in the school. Thereafter, the school will comply with DES guidelines on the storage of Personal Data relating to a student. In the case of members of staff, the school will comply with both DES guidelines and the requirements of the Revenue Commissioners with regard to the retention of records relating to employees. The school may also retain the data relating to an individual for a longer length of time for the purposes of complying with relevant provisions of law and or/defending a claim under employment legislation and/or contract and/or civil law. See School Record Retention table
9. Provide a copy of their personal data to any individual on requestIndividuals have a right to know and have access to a copy of personal data held about them, by whom, and the purpose for which it is held
SCOPE The Data Protection legislation applies to the keeping and processing of Personal Data. The purpose of this policy is to assist the school to meet its statutory obligations, to explain those obligations to School staff, and to inform staff, pupils and their parents/guardians how their data will be treated
The policy applies to all school staff, the Board of Management, parents/guardians, pupils and others (including prospective or potential pupils and their parents/guardians, and applicants for staff positions within the school) insofar as the school handles or processes their Personal Data in the course of their dealings with the school
Definition of Data Protection TermsIn order to properly understand the school’s obligations, there are some key terms, which should be understood by all relevant school staff:
Personal Data means any data relating to an identified or identifiable natural person i.e. a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller (BoM)
Data Controller is the Board of Management of the school
Data Subject - is an individual who is the subject of personal data
Data Processing - performing any operation or set of operations on data, including:
Special categories of Personal Data refer to Personal Data regarding a person’s
RATIONALEIn addition to its legal obligations under the broad remit of educational legislation, the school has a legal responsibility to comply with the Data Protection Acts 1988 to 2018 and the GDPR
This policy explains what sort of data is collected, why it is collected, for how long it will be stored and with whom it will be shared. The school takes its responsibilities under data protection law very seriously and wishes to put in place safe practices to safeguard individual’s personal data. It is also recognised that recording factual information accurately and storing it safely facilitates an evaluation of the information, enabling the Principal and Board of Management to make decisions in respect of the efficient running of the School. The efficient handling of data is also essential to ensure that there is consistency and continuity where there are changes of personnel within the school and Board of Management
OTHER LEGAL OBLIGATIONSImplementation of this policy takes into account the school’s other legal obligations and responsibilities. Some of these are directly relevant to data protection. For example:
Under Section 9(g) of the Education Act, 1998, the parents of a student, or a student who has reached the age of 18 years, must be given access to records kept by the school relating to the progress of the student in their education
Under Section 20 of the Education (Welfare) Act, 2000, the school must maintain a register of all pupils attending the
School
Under Section 20(5) of the Education (Welfare) Act, 2000, a Principal is obliged to notify certain information relating to the child’s attendance in school and other matters relating to the child’s educational progress to the Principal of another school to which a student is transferring. Our Lady of Mercy sends, by post, a copy of a child’s Passport, as provided by the National Council for Curriculum and Assessment, to the Principal of the Post-Primary School in which the pupil has been enrolled
Where reports on pupils which have been completed by professionals, apart from Our Lady of Mercy staff, are included in current pupil files, such reports are only passed to the Post-Primary school following express written permission having been sought and received from the parents of the said pupils
Under Section 21 of the Education (Welfare) Act, 2000, the school must record the attendance or non-attendance of pupils registered at the school on each school day
Under Section 28 of the Education (Welfare) Act, 2000, the School may supply Personal Data kept by it to certain prescribed bodies (the Department of Education and Skills, TUSLA, the National Council for Special Education and other schools). The BoM must be satisfied that it will be used for a ‘relevant purpose’ (which includes recording a person’s educational or training history or monitoring their educational or training progress; or for carrying out research into examinations, participation in education and the general effectiveness of education or training)
Under Section 14 of the Education for Persons with Special Educational Needs Act, 2004, the school is required to furnish to the National Council for Special Education (and its employees, which would include Special Educational Needs Organisers) such information as the Council may from time to time reasonably request
The Freedom of Information Act 1997 provides a qualified right to access to information held by public bodies which does not necessarily have to be “personal data”, as with data protection legislation. While most schools are not currently subject to freedom of information legislation, (with the exception of schools under the direction of Education and Training Boards), if a school has furnished information to a body covered by the Freedom of Information Act (such as the
Department of Education and Skills, etc.) these records could be disclosed by that body if a request is made to that body Under Section 26(4) of the Health Act, 1947 a School shall cause all reasonable facilities (including facilities for obtaining names and addresses of pupils attending the school) to be given to a health authority who has served a notice on it of medical inspection, e.g. a dental inspection
Under Children First Act 2015, mandated persons in schools have responsibilities to report child welfare concerns to
TUSLA- Child and Family Agency (or in the event of an emergency and the unavailability of TUSLA, to An Garda Síochána)
RELATIONSHIP TO CHARACTERISTIC SPIRIT OF THE SCHOOL:
Our Lady of Mercy School seeks to:
PERSONAL DATAThe Personal Data records held by the school may include:
Purposes:
The main purpose for which these examination results are held is to monitor a student’s progress and to provide a sound basis for advising them and their parents or guardian about educational attainment levels and recommendations for the future. The data may also be aggregated for statistical/reporting purposes, such as to compile results tables. The data may be transferred to the Department of Education and Skills, the National Council for Curriculum and Assessment and other schools to which pupils move.
Location and Security procedures As above
LINKS TO OTHER POLICIES AND TO CURRICULUM DELIVERYOur school policies need to be consistent with one another, within the framework of the overall School Plan. Relevant school policies already in place or being developed or reviewed, shall be examined with reference to the Data Protection Policy and any implications which it has for them shall be addressed.
The following policies may be among those considered:
Personal Data BreachesAll incidents in which personal data has been put at risk must be reported to the Office of the Data Protection Commissioner within 72 hours
When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the BoM must communicate the personal data breach to the data subject without undue delay
If a data processor becomes aware of a personal data breach, it must bring this to the attention of the data controller (BoM) without undue delay.
Dealing with a data access requestIndividuals are entitled to a copy of their personal data on written request
The individual is entitled to a copy of their personal data
Request must be responded to within one month. An extension may be required, for example, over holiday periods
No fee may be charged except in exceptional circumstances where the requests are repetitive or manifestly unfounded or excessive
No personal data can be supplied relating to another individual apart from the data subject
PROVIDING INFORMATION OVER THE PHONEAn employee dealing with telephone enquiries should be careful about disclosing any personal information held by the school over the phone. In particular, the employee should:
The following personnel have responsibility for implementing the Data Protection Policy:
Name Responsibility
Board of Management: Data Controller
Principal: Implementation of Policy
RATIFICATION & COMMUNICATIONRatified at the BoM meeting on [Date] and signed by Chairperson. Secretary recorded the ratification in the Minutes of the meeting
MONITORING THE IMPLEMENTATION OF THE POLICY
The implementation of the policy shall be monitored by the Principal, staff and the Board of Management
REVIEWING AND EVALUATING THE POLICYThe policy will be reviewed and evaluated after 2 years. On-going review and evaluation will take cognisance of changing information or guidelines (e.g. from the Data Protection Commissioner, Department of Education and Skills or TUSLA), legislation and feedback from parents/guardians, pupils, school staff and others. The policy will be revised as necessary in the light of such review and evaluation and within the framework of school planning
Signed: …………………………………………………….
For and behalf of Board of Management
Date: Ratified: 20/6/2018
INTRODUCTORY STATEMENTThe school’s Data Protection Policy applies to the personal data held by the school’s Board of Management (BoM), which is protected by the Data Protection Acts 1988 to 2018 and the EU General Data Personal Regulation (GDPR)
The policy applies to all school staff, the Board of Management, parents/guardians, pupils and others (including prospective or potential pupils and their parents/guardians and applicants for staff positions within the school) insofar as the measures under the policy relate to them. Data will be stored securely, so that confidential information is protected in compliance with relevant legislation. This policy sets out the manner in which personal data and special categories of personal data will be protected by the school
OLOM operates a “Privacy by Design” method in relation to Data Protection. This means we plan carefully when gathering personal data so that we build in the data protection principles as integral elements of all data operations in advance. We audit the personal data we hold in order to:
- be able to provide access to individuals to their data
- ensure it is held securely
- document our data protection procedures
- enhance accountability and transparency
1. Obtain and process Personal Data fairlyInformation on pupils is gathered with the help of parents/guardians and staff. Information is also transferred from their previous schools. In relation to information the school holds on other individuals (members of staff, individuals applying for positions within the School, parents/guardians of pupils, etc.), the information is generally furnished by the individuals themselves with full and informed consent and compiled during the course of their employment or contact with the School. All such data is treated in accordance with the Data Protection legislation and the terms of this Data Protection Policy. The information will be obtained and processed fairly
2.ConsentWhere consent is the basis for provision of personal data, (e.g. data required to join sports team/ after-school activity or any other optional school activity) the consent must be a freely-given, specific, informed and unambiguous indication of the data subject’s wishes. Our Lady of Mercy will require a clear, affirmative action e.g. ticking of a box/signing a document to indicate consent. Consent can be withdrawn by data subjects in these situations
3. Keep it only for one or more specified and explicit lawful purposesThe BoM will inform individuals of the reasons they collect their data and the uses to which their data will be put. All information is kept with the best interest of the individual in mind at all times
4. Process it only in ways compatible with the purposes for which it was given initiallyData relating to individuals will only be processed in a manner consistent with the purposes for which it was gathered. Information will only be disclosed on a ‘need to know’ basis, and access to it will be strictly controlled
5. Keep Personal Data safe and secureOnly those with a genuine reason for doing so may gain access to the information. Personal Data is securely stored under lock and key in the case of manual records and protected with computer software and password protection in the case of electronically stored data. Portable devices storing personal data (such as laptops) are encrypted and password-protected.
6. Keep Personal Data accurate, complete and up-to-datePupils, parents/guardians, and/or staff should inform the school of any change which the school should make to their personal data and/or sensitive personal data to ensure that the individual’s data is accurate, complete and up-to-date. Once informed, the school will make all necessary changes to the relevant records. Records must not be altered or destroyed without proper authorisation. If alteration/correction is required, then a note of the fact of such authorisation and the alteration(s) to be made to any original record/documentation should be dated and signed by the person making that change
7. Ensure that it is adequate, relevant and not excessive
Only the necessary amount of information required to provide an adequate service will be gathered and stored
8. Retain it no longer than is necessary for the specified purpose or purposes for which it was givenAs a general rule, the information will be kept for the duration of the individual’s time in the school. Thereafter, the school will comply with DES guidelines on the storage of Personal Data relating to a student. In the case of members of staff, the school will comply with both DES guidelines and the requirements of the Revenue Commissioners with regard to the retention of records relating to employees. The school may also retain the data relating to an individual for a longer length of time for the purposes of complying with relevant provisions of law and or/defending a claim under employment legislation and/or contract and/or civil law. See School Record Retention table
9. Provide a copy of their personal data to any individual on requestIndividuals have a right to know and have access to a copy of personal data held about them, by whom, and the purpose for which it is held
SCOPE The Data Protection legislation applies to the keeping and processing of Personal Data. The purpose of this policy is to assist the school to meet its statutory obligations, to explain those obligations to School staff, and to inform staff, pupils and their parents/guardians how their data will be treated
The policy applies to all school staff, the Board of Management, parents/guardians, pupils and others (including prospective or potential pupils and their parents/guardians, and applicants for staff positions within the school) insofar as the school handles or processes their Personal Data in the course of their dealings with the school
Definition of Data Protection TermsIn order to properly understand the school’s obligations, there are some key terms, which should be understood by all relevant school staff:
Personal Data means any data relating to an identified or identifiable natural person i.e. a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller (BoM)
Data Controller is the Board of Management of the school
Data Subject - is an individual who is the subject of personal data
Data Processing - performing any operation or set of operations on data, including:
- Obtaining, recording or keeping the data,
- Collecting, organising, storing, altering or adapting the data
- Retrieving, consulting or using the data
- Disclosing the data by transmitting, disseminating or otherwise making it available
- Aligning, combining, blocking, erasing or destroying the data
Special categories of Personal Data refer to Personal Data regarding a person’s
- racial or ethnic origin
- political opinions or religious or philosophical beliefs
- physical or mental health
- sexual life and sexual orientation
- genetic and biometric data
- criminal convictions or the alleged commission of an offence
- trade union membership
RATIONALEIn addition to its legal obligations under the broad remit of educational legislation, the school has a legal responsibility to comply with the Data Protection Acts 1988 to 2018 and the GDPR
This policy explains what sort of data is collected, why it is collected, for how long it will be stored and with whom it will be shared. The school takes its responsibilities under data protection law very seriously and wishes to put in place safe practices to safeguard individual’s personal data. It is also recognised that recording factual information accurately and storing it safely facilitates an evaluation of the information, enabling the Principal and Board of Management to make decisions in respect of the efficient running of the School. The efficient handling of data is also essential to ensure that there is consistency and continuity where there are changes of personnel within the school and Board of Management
OTHER LEGAL OBLIGATIONSImplementation of this policy takes into account the school’s other legal obligations and responsibilities. Some of these are directly relevant to data protection. For example:
Under Section 9(g) of the Education Act, 1998, the parents of a student, or a student who has reached the age of 18 years, must be given access to records kept by the school relating to the progress of the student in their education
Under Section 20 of the Education (Welfare) Act, 2000, the school must maintain a register of all pupils attending the
School
Under Section 20(5) of the Education (Welfare) Act, 2000, a Principal is obliged to notify certain information relating to the child’s attendance in school and other matters relating to the child’s educational progress to the Principal of another school to which a student is transferring. Our Lady of Mercy sends, by post, a copy of a child’s Passport, as provided by the National Council for Curriculum and Assessment, to the Principal of the Post-Primary School in which the pupil has been enrolled
Where reports on pupils which have been completed by professionals, apart from Our Lady of Mercy staff, are included in current pupil files, such reports are only passed to the Post-Primary school following express written permission having been sought and received from the parents of the said pupils
Under Section 21 of the Education (Welfare) Act, 2000, the school must record the attendance or non-attendance of pupils registered at the school on each school day
Under Section 28 of the Education (Welfare) Act, 2000, the School may supply Personal Data kept by it to certain prescribed bodies (the Department of Education and Skills, TUSLA, the National Council for Special Education and other schools). The BoM must be satisfied that it will be used for a ‘relevant purpose’ (which includes recording a person’s educational or training history or monitoring their educational or training progress; or for carrying out research into examinations, participation in education and the general effectiveness of education or training)
Under Section 14 of the Education for Persons with Special Educational Needs Act, 2004, the school is required to furnish to the National Council for Special Education (and its employees, which would include Special Educational Needs Organisers) such information as the Council may from time to time reasonably request
The Freedom of Information Act 1997 provides a qualified right to access to information held by public bodies which does not necessarily have to be “personal data”, as with data protection legislation. While most schools are not currently subject to freedom of information legislation, (with the exception of schools under the direction of Education and Training Boards), if a school has furnished information to a body covered by the Freedom of Information Act (such as the
Department of Education and Skills, etc.) these records could be disclosed by that body if a request is made to that body Under Section 26(4) of the Health Act, 1947 a School shall cause all reasonable facilities (including facilities for obtaining names and addresses of pupils attending the school) to be given to a health authority who has served a notice on it of medical inspection, e.g. a dental inspection
Under Children First Act 2015, mandated persons in schools have responsibilities to report child welfare concerns to
TUSLA- Child and Family Agency (or in the event of an emergency and the unavailability of TUSLA, to An Garda Síochána)
RELATIONSHIP TO CHARACTERISTIC SPIRIT OF THE SCHOOL:
Our Lady of Mercy School seeks to:
- enable pupils to develop their full potential
- provide a safe and secure environment for learning
- promote respect for the diversity of values, beliefs, traditions, languages and ways of life in society
PERSONAL DATAThe Personal Data records held by the school may include:
- Staff records:
- Categories of staff data:
- Name, address and contact details, PPS 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
- 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) to facilitate pension payments in the future
- 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 and for compliance with legislation relevant to the school.
- Location and Security procedures of Our Lady of Mercy:
- Manual records are kept in a secure, locked filing cabinet in a locked administration office only accessible to personnel who are authorised to use the data. Employees are required to maintain the confidentiality of any data to which they have access.
- Digital records are stored on password-protected computer with adequate encryption and firewall software in a locked office.
- Student records:
- Categories of student data:
- Information which may be sought and recorded at enrolment and may be collated and compiled during the course of the student’s time in the school. These records may include:
- name, address and contact details, PPS number, date and place of birth
- names and addresses of parents/guardians and their contact details (including any special arrangements with regard to guardianship, custody or access)
- religious belief racial or ethnic origin
- membership of the Traveller community, where relevant o whether they (or their parents) are medical card holders
- whether English is the student’s first language and/or whether the student requires English language support
- any relevant special conditions (e.g. special educational needs, health issues, etc.) which may apply
- Information on previous academic record (including reports, references, assessments and other records from any previous school(s) attended by the student
- Psychological, psychiatric and/or medical assessments
- Attendance records
- Photographs and recorded images of pupils (including at school events and noting achievements) are managed in line with the accompanying policy on school photography.
- Academic record – subjects studied, class assignments, examination results as recorded on official School reports
- Records of significant achievements
- Whether the student is exempt from studying Irish
- Records of disciplinary issues/investigations and/or sanctions imposed
- Other records e.g. records of any serious injuries/accidents, etc. (Note: it is advisable to inform parents that a particular incident is being recorded).
- Records of any reports the school (or its employees) have made in respect of the student to State Departments and/or other agencies under Children First Act 2015.
- Purposes: The purposes for keeping student records include:
- to enable each student to develop to his full potential
- to comply with legislative or administrative requirements
- to ensure that eligible pupils can benefit from the relevant additional teaching or financial supports
- to support the provision of religious instruction
- to enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or to inform parents of school events, etc.
- to meet the educational, social, physical and emotional requirements of the student
- photographs and recorded images of pupils are taken to celebrate school achievements, e.g. 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 Photography Policy’ and ‘School Website Privacy Statement’.
- to ensure that the student meets the school’s admission criteria
- to ensure that pupils meet the minimum age requirement for attendance at Primary School.
- to ensure that any student seeking an exemption from Irish meets the criteria in order to obtain such an exemption from the authorities
- to furnish documentation/information about the student to the Department of Education and Skills, the National Council for Special Education, TUSLA, and other schools, etc. in compliance with law and directions issued by government departments
- to furnish, when requested by the student (or their parents/guardians in the case of a student under 18 years) documentation/information/references to second-level educational institutions.
- (Location and Security procedures as above):
- Board of Management records:
- Categories of Board of Management data:
- Name, address and contact details of each member of the Board of Management (including former members of the Board of Management)
- Records in relation to appointments to the Board
- Minutes of Board of Management meetings and correspondence to the Board which may include references to individuals.
- Purposes:
- Categories of Board of Management data:
- (Location and Security procedures as above):
- Categories of Board of Management data:
- name
- address
- contact details
- PPS number
- tax details
- bank details and amount paid
- Purposes: The purposes for keeping creditor records are:
- (Location and Security procedures as above):
- Categories of Board of Management data:
- name
- address
- telephone number
- PPS number
- tax rate
- signature and
- the gross amount of the donation.
- Purposes: The purposes for keeping creditor records are:
- (Location and Security procedures as above):
Purposes:
The main purpose for which these examination results are held is to monitor a student’s progress and to provide a sound basis for advising them and their parents or guardian about educational attainment levels and recommendations for the future. The data may also be aggregated for statistical/reporting purposes, such as to compile results tables. The data may be transferred to the Department of Education and Skills, the National Council for Curriculum and Assessment and other schools to which pupils move.
Location and Security procedures As above
LINKS TO OTHER POLICIES AND TO CURRICULUM DELIVERYOur school policies need to be consistent with one another, within the framework of the overall School Plan. Relevant school policies already in place or being developed or reviewed, shall be examined with reference to the Data Protection Policy and any implications which it has for them shall be addressed.
The following policies may be among those considered:
- Pupil Online Database (POD): Collection of the data for the purposes of complying with the Department of Education and Skills’ pupil online database.
- Child Protection Procedures
- Anti-Bullying Procedures
- Code of Behaviour
- Enrolment Policy
- ICT Acceptable Usage Policy
- Assessment Policy
- Special Educational Needs Policy
- Library Policy
- Book-Rental Policy
- Critical Incident Policy
- Student Council Policy
- Attendance Policy
- Know what personal data the school is keeping on them
- Request access to any data held about them by a data controller
- Prevent the processing of their data for direct-marketing purposes
- Ask to have inaccurate data amended
- Ask to have data erased once it is no longer necessary or irrelevant.
Personal Data BreachesAll incidents in which personal data has been put at risk must be reported to the Office of the Data Protection Commissioner within 72 hours
When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the BoM must communicate the personal data breach to the data subject without undue delay
If a data processor becomes aware of a personal data breach, it must bring this to the attention of the data controller (BoM) without undue delay.
Dealing with a data access requestIndividuals are entitled to a copy of their personal data on written request
The individual is entitled to a copy of their personal data
Request must be responded to within one month. An extension may be required, for example, over holiday periods
No fee may be charged except in exceptional circumstances where the requests are repetitive or manifestly unfounded or excessive
No personal data can be supplied relating to another individual apart from the data subject
PROVIDING INFORMATION OVER THE PHONEAn employee dealing with telephone enquiries should be careful about disclosing any personal information held by the school over the phone. In particular, the employee should:
- Ask that the caller put their request in writing
- Refer the request to the Principal for assistance in difficult situations
- Not feel forced into disclosing personal information
The following personnel have responsibility for implementing the Data Protection Policy:
Name Responsibility
Board of Management: Data Controller
Principal: Implementation of Policy
RATIFICATION & COMMUNICATIONRatified at the BoM meeting on [Date] and signed by Chairperson. Secretary recorded the ratification in the Minutes of the meeting
MONITORING THE IMPLEMENTATION OF THE POLICY
The implementation of the policy shall be monitored by the Principal, staff and the Board of Management
REVIEWING AND EVALUATING THE POLICYThe policy will be reviewed and evaluated after 2 years. On-going review and evaluation will take cognisance of changing information or guidelines (e.g. from the Data Protection Commissioner, Department of Education and Skills or TUSLA), legislation and feedback from parents/guardians, pupils, school staff and others. The policy will be revised as necessary in the light of such review and evaluation and within the framework of school planning
Signed: …………………………………………………….
For and behalf of Board of Management
Date: Ratified: 20/6/2018
