Privacy Statement
Privacy Notice - Pembrokeshire Learning Centre
This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes of Pembrokeshire Learning Centre. The ‘PLC’ is a specialist school within the Local Authority providing support to those pupils with Complex Learning Needs, Behavioural Issues and Anxious and School Phobic.
Why we need your information (purpose of processing)
We collect and use your personal information, for the following purposes:
- as part of our admissions process
- to support pupil learning
- to monitor and report on pupil attainment progress
- to provide appropriate pastoral care
- to assess the quality of our services
- to keep children safe (food allergies, or emergency contact details)
- to meet the statutory duties placed upon us for DfE data collections
- to comply with the law regarding data sharing
- to support you to decide what to do after you leave school
The information that you provide will be processed according to the UK General Data Protection Regulation, the Data Protection Act 2018 and section 537A of the Education Act 1996, and section 83 of the Children Act 1989.
We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales (Audit Wales Privacy Notice(opens in a new tab)).
We will not make any disclosures to third parties for marketing purposes.
Your data will be secure and confidential at all times and we will only collect the personal information that is required to provide you with our service.
What personal data is being collected?
The categories of personal data being collected are:
- personal identifiers and contacts (such as name, unique pupil number, date of birth, contact details and address)
- characteristics (such as ethnicity, religion, biometric-data, language, and free school meal eligibility)
- safeguarding information (such as court orders and professional involvement, criminal convictions)
- special educational needs (including the needs and ranking, assessment levels)
- medical and administration (such as doctors information, school nurse, child health, dental health, allergies, medication and dietary requirements)
- attendance (such as sessions attended, number of absences, absence reasons and any previous schools attended, school history)
- assessment and attainment (such as key stage 1 and phonics results, post 16 courses enrolled for and any relevant results)
- behavioural information (such as exclusions and any relevant alternative provision put in place)
- Contact information for school transport/trips/excursions (parent contact details, emergency contacts, passport details, health/medical information)
- Images for CCTV
What is our lawful basis for processing your personal data?
The UK General Data Protection Regulations (UK GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:
Article 6 (1)(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
Article 6 (1)(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. – This is in relation to CCTV.
Some types of personal data are more sensitive than others, and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation.
We process this type of special category data as it is necessary for reasons of:
Article 9 (2)(g) Substantial public interest in accordance with the Education Act 2011
(The relevant Data Protection Act 2018 conditions are – Schedule 1 Part 2: Safeguarding of children and individuals at risk)
Who will we share your information with?
We may need to share your personal data with internal departments, other organisations and third parties, this will include:
- schools that the pupils attend after leaving us
- our local authority, Health Board, Careers Wales & Welsh Government
- youth support services (pupils aged 13+)
- the Department for Education (DfE)
- Police
We use data processors (third parties) who provide services to us in terms of IT provision and disaster recovery. We have contracts in place with these data processors and they cannot do anything with your personal information unless we have instructed them to do it. They will hold your data securely and your personal information will only be shared in accordance with UK GDPR. When it is necessary for your personal information to be transferred outside of the UK as part of these contracts, this will only be done in accordance with the UK GDPR.
Pembrokeshire County Council has a duty to protect the public funds it manages. Therefore, the information that you have provided to us may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting CIFAS (opens in a new tab)
How long do we keep hold of your information?
Pembrokeshire County Council will only keep your information for as long as is necessary, we will retain the information provided to us for 25 years from leaving date and CCTV for 28 days and your information will be securely disposed of once it is no longer required.
Your Rights
Under the UK General Data Protection Regulation and Data Protection Act 2018, you have rights as an individual including:
- The right to Rectification – you have the right to ask to have your information corrected.
- The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
- The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to not be subject to Automated decision making and profiling.
- The right of Access – you have the right to ask us for copies of your personal data. To make a request, please contact:
Access to Records
Pembrokeshire County Council
County Hall
Haverfordwest
SA61 1TP
Email: accesstorecords@pembrokeshire.gov.uk Telephone: 01437 764551
Complaints or queries
Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate.
This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:
Data Protection Officer
Pembrokeshire County Council
County Hall
Haverfordwest
SA61 1TP
Email: dataprotection@pembrokeshire.gov.uk
Telephone: 01437 764551
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:
Information Commissioner’s Office – Wales
2nd Floor, Churchill House
Churchill Way
Cardiff
CF10 2HH
Email: wales@ico.org.uk
Telephone number: 0330 414 6421
Our contact details as Data Controller are:
Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP.
Telephone number: 01437 764551 or enquiries@pembrokeshire.gov.uk
Our Data Protection Officer’s information is detailed above in the complaints and queries section.
Changes to this privacy notice
We keep our privacy notice under regular review.