As a Trust we collect a significant amount of information about our pupils. This notice explains why we collect the information, how we use it, the type of information we collect and our lawful reasons to do so. The Alpha Academies Trust is the data controller of the personal information you provide to us. SBM Services Ltd, are The Trust’s Data Protection Officer and they oversee the Trust’s data protection procedures to ensure our compliancy.
Ownership of the Personal Data
To enable the Covid-19 testing to be completed at Alpha Academies Trust, we need to process personal data for staff and pupils taking part, including sharing of personal data where we have a legal obligation. Alpha Academies Trust is the Data Controller for the data required for processing the tests and undertaking any actions which are needed by the academy to ensure we meet our public health and safeguarding legal obligations.
· Personal data relating to tests for pupils [Section 175 of the Education Act 2002 for maintained schools OR paragraph 7 of the Schedule to the Education (Independent School Standards) Regulations 2014 applicable to academies OR paragraphs 3 and 14 of the Schedule to the Non-Maintained Special Schools (England) Regulations 2015 applicable to Non-Maintained Special Schools.
· Personal Data relating to staff is processed under the legitimate interest of data controller to ensure we can minimise the spread of COVID in a timely manner and enable us to continue to deliver education services safely and securely
The following paragraph is relevant to both pupils and staff taking tests
If you decline a test, we record your decision under the legitimate interest of academy in order to have a record of your decisions and to reduce unnecessary contact with you regarding testing.
The processing of special category personal data is processed under the provisions Section 9.2(i) of GDPR, where it is in the public interest on Public Health Grounds. This data is processed under the obligations set out in Public Health legislation (Regulations 3(1) and (4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI)) which allows the sharing of data for COVID related purposes and where it is carried out by [a health care professional OR someone who owes an equivalent duty of confidentiality to that data] Data Controllership is then passed to the Department for Health and Social Care (DHSC) for all data that we transfer about you and your test results to them. For more information about what they do with your data please see the Test and Trace Privacy Notice. The establishment remains the Data Controller for the data we retain about you.
Personal Data involved in the process
We use the following information to help us manage and process the tests:
· Date of birth (and year group)
· Home postcode
· Email address
· Mobile number
· Unique barcode assigned to each individual test and which will become the primary reference number for the tests
· Test result
· Parent/guardians contact details (if required)
We will only use information that is collected directly from you specifically for the purpose of the tests, even if you have previously provided us with this information.
How we store your personal information
The information will only be stored securely on local spreadsheets in academy whilst it is needed. It will also be entered directly onto DHSC digital services for the NHS Test and Trace purposes. The Academy will not have access to the information on the digital service once it has been entered.
Processing of Personal Data Relating to Positive test results
The member of staff, pupil, student or parent (depending on contact details provided) will be informed of the result by the academy and advised how to book a confirmatory test.
We will use this information to enact their own COVID isolation processes without telling anyone who it is that has received the positive test.
The information will be transferred to DHSC, who will share this with the NHS, GPs. PHE and the Local Government will use this information for wider test and trace activities as well as statistical and research purposes.
This information is processed and shared under obligations set out in Public Health legislation under Regulations 3(1) and (4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) which allows the sharing of data for COVID related purposes.
This information will be kept by the academy for up to 14 days and by the NHS for 8 years.
Processing of Personal Data relating to declining a test
We will record that you have declined to participate in a test and this information will not be shared with anyone.
Data Sharing Partners
The personal data associated with test results will be shared with
· DHSC, NHS, PHE – to ensure that they can undertake the necessary Test and Trace activities and to conduct research and compile statistic about Coronavirus.
· Your GP – to maintain your medical records and to offer support and guidance as necessary
· Local Government to undertake local public health duties and to record and analyse local spreads.
Requesting Access to Your Personal Data
Under data protection legislation, you have the right to request access to information about you that we hold. To make a request for your personal information, contact The Trust’s Chief Operating Officer, Mrs A Lucy, at Alpha Academies Trust, Discovery Drive, Stoke-on-Trent, ST2 0GA, telephone, 01782 882100, email address, email@example.com. The Trust’s Data Protection Officer is SBM Services.
You also have the right to:
· To ask us for access to information about you that we hold.
· 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.
· Not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you.
· To restrict our processing of your personal data (for example permitting its storage but no further processing).
· In certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed.
· Claim compensation for damages caused by a breach of the Data Protection regulations either through the ICO or the through the Courts.
If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/
Withdrawal of Consent and the Right to Lodge a Complain
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 Trust’s Operations Officer, Mrs C Owen, at Alpha Academies Trust, Discovery Drive, Stoke-on-Trent, ST2 0GA, telephone, 01782 882100, email address firstname.lastname@example.org
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 on 13th January 2021.
If you would like to discuss anything in this privacy notice, please contact:
The Trust’s Operations Officer, Mrs C Owen, at Alpha Academies Trust, Discovery Drive, Stoke-on-Trent, ST2 0GA, telephone, 01782 882100, email address cowen@asutton1alphaacademiestrust-co-uk
As a public body, the Alpha Academies Trust is required to appoint a Data Protection Officer (DPO).
The Data Protection Officer at the Alpha Academies Trust is SBM Services.
More Information about Data Protection and our Policies
How we manage the data and our responsibilities to look after and share data is explained in our Data Protection policy and connected policies which are also available on our website.