Is your school GDPR compliant? I reached out to a school governor in the local area. My interest was focused on comprehending the influence of data protection on education. Our conversation revolved around the school’s efforts to ensure compliance, even though I won’t mention the school or governor’s identity to maintain confidentiality. With this in consideration, I will rightfully attribute the insights I’m about to present, all of which originated from our fruitful exchange.
Data Protection In Schools: Chapter 1
What are the key areas that effect the education sector in light of current data protection regulations? Having strong rules and regulations are only effective if people and organisations adhere to them. For the education system it has been somewhat of a rude awakening. Some institutions have struggled to update their archaic processes and bring them to the 21st century. Giving rise to a large catchment of schools and colleges who are now non-compliant and traditionally unaware of security by design or best practice.
Data Protection In Schools: Chapter 2
It’s important to note that not all schools are facing this situation. Many have actively embraced these regulations since their inception. One pivotal strategy for achieving compliance has been the appointment of internal data protection officers or outsourcing the DPO role, which has helped mitigate disruptions. To put it simply, the path forward involves sustaining compliance annually through the implementation of solutions and the conduct of yearly compliance reports. The majority of schools have taken initial steps toward achieving GDPR compliance, including providing training to their front-line staff on workplace best practices. However, a bottleneck does exist, turning this process into a lengthy and intricate journey fraught with challenging tasks and complex literature.
After the meeting I walked away with one gut feeling. It seemed clear to me that under resourced and underfunded schools were most at risk of creating the environment where breaches are likely to happen.
“Updating our information security practices to comply with the regulations requires either a budget for external support or an abundance of internal expertise and, well, many schools in the UK have neither”Governor & Safeguarding Lead
Data Protection In schools: Chapter 3
This is a nationwide issue, and for that reason we have decided to start the blog and discussion in this space. Personal data comprises of any information that can help identify a person or their family, whereas special category of data touch on more sensitive topics. A key piece of information to remember here is that both staff and pupils are in scope. This is because equally they have the right to know how the information you hold about them is being used. There are several methods of data discovery and you can do the most of them in house. A simple data mapping exercise will allow you to highlight the data centric areas of the school and from there it’s a case of understanding how to process that data in a complaint and demonstrable way.
One key strategy that should be implemented here is creating a monthly steering group committee. The group is responsible for the overall implementation of the regulations, but it allows you to break the process down in to small bite size tasks. Get a member of staff from each department so you have an appropriate representation of the data areas in the school and build out your case of work from there.
What is Personal Data In Schools:
Is your school GDPR compliant?
- Personal Identifiable Information such as names of Governors, staff, pupils and parents. (Past and present)
- Dates of birth & addresses.
- National insurance numbers.
- Financial information
- Biometric Data, Such as facial Recognition or finger ID, CCTV
- Religious affiliation, Exam Results & Behavioural Records.
- Recruitment data
- Safeguarding information
- Medical information, such as medical conditions, sexual health records and GP names.
- Dietary Requirements, Such as vegan, vegetarian, halal or kosher.
What to Consider when implementing GDPR:
- Create a steering group
- Conduct annual external consultant led gap analysis reports
- Outsourced data protection officer.
- Annual compliance audits or remediation work to maintain your position or achieve compliance.
- Annual penetration testing of your networks
Data security breaches often stem from human error. Many breaches occur due to factors like losing a device at work or having it stolen during the commute. This scenario might sound all too familiar. During my discussion, a valuable suggestion arose. All staff members should exclusively store sensitive student personal data on school equipment. This equipment appropriately encrypted and password-protected. Additionally, they should adopt robust passwords and update them regularly. This might seem like a simple and straightforward practice. However it’s astonishing how basic some passwords still.
school GDPR check List? Is your school GDPR compliant?
Is your school GDPR compliant?
Appoint a Data Protection Officer:
Designate a knowledgeable individual or hire a DPO.
Data Mapping and Inventory:
Conduct a comprehensive audit of all personal data processing activities within the school. Create a detailed inventory of the data collected, stored, and processed, including its purpose and legal basis.
Obtain explicit and informed consent from individuals before collecting and processing their personal data. Clearly communicate the purpose and scope of data usage to parents, students, and staff, and allow them to easily withdraw consent if needed.
Privacy Policies and Notices:
Develop clear and concise privacy policies and notices that outline how personal data is collected, processed, and protected. These documents should be easily accessible on the school’s website and in relevant communications.
Data Security Measures:
Implement robust security measures to protect personal data from unauthorised access, breaches, or loss. This includes encryption, regular security assessments, and staff training on data security best practices.
Data Retention and Deletion:
Define specific retention periods for different types of data and regularly review whether data should be retained or deleted once it’s no longer necessary for the intended purpose.
Data Subject Rights:
Educate staff, students, and parents about their rights under GDPR, including the right to access, rectify, erase, and restrict the processing of their personal data. Develop processes to handle data subject requests efficiently.
Breach Response Plan:
Create a detailed plan to respond to data breaches, including identifying and notifying affected individuals and authorities within the required timeframe.
Training and Awareness:
Provide regular training sessions to staff members who handle personal data, ensuring they are aware of GDPR regulations and best practices for data protection.
Regular Audits and Assessments:
Conduct periodic audits and assessments of data processing activities to identify and rectify any compliance gaps.
Maintain thorough documentation of all GDPR-related activities, including policies, procedures, assessments, and breach response records
Is your school GDPR compliant?
In conclusion, a Data Protection Officer (DPO) plays a crucial role in ensuring a school’s compliance with GDPR. They provide expertise, guidance, and oversight to guarantee that personal data is processed lawfully, transparently, and securely. By implementing the outlined measures and emphasising the role of a DPO, schools can establish a strong foundation for GDPR compliance and protect the privacy rights of their community members.
Data Protection Guidance For Schools: https://compliancedirectsolutions.com/data-protection-guidance-toolkit-for-schools/