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Privacy Policy

How we use student information

Willingdon Community School processes personal information about its students and is a ‘data controller’ for the purposes of Data Protection legislation. We collect information from you and may receive information about you from your previous school and the Learning Records Service. If you are enrolling for post-14 qualifications, the Learning Records Service will give us your unique learner number (ULN) and may also give us details of any learning you have done in the past or any qualifications you have.

The categories of student information that we collect, hold and share include:

  • Personal information (such as name, unique student number and address)

  • Characteristics (such as ethnicity, language, nationality, country of birth and free school meal eligibility)

  • Attendance information (such as sessions attended, number of absences and absence reasons)

  • safeguarding information (such as court orders and professional involvement)

  • special educational needs (including the needs and ranking)

  • medical and administration (such as doctors information, child health, dental health, allergies, medication and dietary requirements)

  • assessment and attainment (such as post 16 courses enrolled for and any relevant results)

  • behavioural information (such as exclusions and any relevant alternative provision put in place)

  • Images (such as in photographs, video and CCTV footage)

Why we collect and use this information

We use the student data:

  • to support student learning

  • to monitor and report on student progress

  • to provide appropriate pastoral care

  • to keep students safe (food allergies, or emergency contact details)

  • to assess the quality of our services

  • to meet the statutory duties placed upon us

  • to ensure students have appropriate access to healthcare Secondary 2

  • to preserve the school’s history and collective memory

The lawful basis on which we use this information

Under the General Data Protection Regulation (GDPR), the school is required to identify a valid lawful basis for each processing activity involving personal data. We only collect and use students’ personal data when the law allows us to. Most commonly, we process it where:

  • We have to collect and process personal data to enable us to comply with a legal obligation.

  • We need it because we are acting in the public interest or exercising our official authority.

We may also process students’ personal data in situations where:

  • We have obtained consent from you to use it in a certain way.

  • We have a genuine and legitimate reason and we are not harming any of your rights and interests.

As a school, we also collect and use special category data, both to provide education and comply with our legal obligations. We have therefore identified additional lawful bases from Article 9 of the GDPR. Most commonly, we process special category data where:

  • We have gained explicit consent for the processing.

  • Processing is necessary for reasons of substantial public interest.

  • We are required to for reasons of “public health”, for example during a pandemic.

Please see the school’s Special Category Data policy for more information about how we process this type of data.

Where we keep records and information containing personal data for a longer time, we do this for archiving purposes in the public interest. We keep these records to preserve the school’s history, key events and collective memory. We will provide access to these records for research or statistical purposes, taking reasonable measures to protect the personal data they may contain.

How we collect student information

We collect student information via registration forms at the start of their school year or via secure file transfer from previous school. Student data is essential for the schools’ operational use.

Whilst the majority of student information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain student information to us or if you have a choice in this.

Storing student data

We hold pupil data securely for the length of time outlined in our school retention schedule. The school retention schedule is available upon request from the Data Protection Lead (Business Manager). We will keep a limited and reasonable amount of personal information for a longer time, where it appears in records that are of historic value or it is in the public interest to keep as part of the school’s history and collective memory. We store these records securely in our school archive for permanent preservation.

Who we share student information with

We routinely share student information with:

  • schools that the student’s attend after leaving us

  • our local authority

  • the Department for Education (DfE)

  • the NHS and school nurse

  • Youth support services (pupils aged 13+)

  • Traded services purchased through the LA (e.g. for Legal, Human Resources or Information Governance Support)

  • Learning platforms or software providers used by the school to support education provision

We only share data with organisations who have adequate security measures and protections in place.

Why we regularly share student information

We do not share information about our students with anyone without consent unless the law and our policies allow us to do so. The Department for Education (DfE) collects personal data from educational settings and local authorities via various statutory data collections. We are required to share information about our pupils with the Department for Education (DfE) either directly or via our local authority for the purpose of those data collections. We are required to share information about our students with our local authority (LA) and the Department for Education (DfE) under section 3 of The Education (Information About Individual Students) (England) Regulations 2013. All data is transferred securely and held by DfE under a combination of software and hardware controls, which meet the current government security policy framework. For more information, please see ‘How government uses your data’ section.

Local Authorities Secondary

We may be required to share information about our pupils with the local authority to ensure that they can conduct their statutory duties under

  • the Schools Admission Code, including conducting Fair Access Panels.

Youth support services

Students aged 13+

Once our students reach the age of 13, we also pass student information to our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 13-19 year olds under section 507B of the Education Act 1996.

This enables them to provide services as follows:

  • youth support services

  • careers advisers

The information shared is limited to the child’s name, address and date of birth. However where a parent or guardian provides their consent, other information relevant to the provision of youth support services will be shared. This right is transferred to the child / student once they reach the age 16.

Data is securely transferred to the youth support service via encrypted secure access and is stored securely and held in line with the school’s retention schedule.

Requesting access to your personal data

Under data protection legislation, parents and students have the right to request access to information about them that we hold. To make a request for your personal information, or be given access to your child’s educational record, contact School Reception via

Depending on the lawful basis above, you may also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress

  • ask us for access to information about you that we hold

  • request we restrict the processing of your personal data (i.e permitting its storage but no further processing)

  • object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics.

  • not be subject to decisions based purely on automated processing where it produces legal or similarly significant effect on you.

  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and

  • Right to seek redress, either through the ICO or through the courts.

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at

For further information on how to request access to personal information held centrally by DfE, please see the ‘How Government uses your data’ section.

Withdrawal of consent and the right to lodge a complaint

Where we are processing your personal data with your consent, you have the right to withdraw that consent. If you change your mind, or you are unhappy with our use of your personal data, please let us know by contacting the Data Protection Lead (Business Manager).

Data Protection Officer

Peter Questier (East Sussex County Council, Information Governance Team. Children’s Services) However, please contact the school in the first instance if you have a query regarding this privacy notice or how your information is used.

The National Pupil Database (NPD)

Much of the data about pupils in England goes on to be held in the National Pupil Database (NPD). The NPD is owned and managed by the Department for Education and contains information about pupils in schools in England. It provides invaluable evidence on educational performance to inform independent research, as well as studies commissioned by the Department. It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including schools, local authorities and awarding bodies. We are required by law, to provide information about our pupils to the DfE as part of statutory data collections such as the school census and early years’ census. Some of this information is then stored in the NPD. The law that allows this is the Education (Information About Individual Pupils) (England) Regulations 2013. To find out more about the NPD, go to

Sharing by the Department

The law allows the Department to share information about our pupils from the NPD with certain third parties, including:

  • schools and local authorities

  • researchers

  • organisations connected with promoting the education or wellbeing of children in England

  • other government departments and agencies

  • organisations fighting or identifying crime

For more information about the department’s NPD data sharing process, please visit: Organisations fighting or identifying crime may use their legal powers to contact DfE to request access to individual level information relevant to detecting that crime. Whilst numbers fluctuate slightly over time, DfE typically supplies data on around 600 students per year to the Home Office and roughly 1 per year to the Police. For information about which organisations the department has provided student information, (and for which project) or to access a monthly breakdown of data share volumes with home Office and the Police please visit the following website

How Government uses your data

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

  • underpins school funding, which is calculated based upon the numbers of children and their characteristics in each school.

  • informs ‘short term’ education policy monitoring and school accountability and intervention (for example, school GCSE results or Pupil Progress measures).

  • supports ‘longer term’ research and monitoring of educational policy (for example how certain subject choices go on to affect education or earnings beyond school)

Data collection requirements:

To find out more about the data collection requirements placed on us by the Department for Education (for example; via the school census) go to

Last updated

We may need to update this privacy notice periodically so we recommend that you revisit this information from time to time. This version was last updated in November 2020.

Please note a separate Privacy Notice is issued annually to our Year 11 students.

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