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Privacy Notice


Dear Parent/Carer


As you know, SATS Week is fast approaching and we wanted to get in touch with you to let you know how your children’s data and information will be used. This is called a Privacy Notice.


Privacy Notice (How we use pupil information)

Who is responsible for this information?

Comber Grove Primary School is the Data Controller for the use of personal data in this privacy notice The categories of pupil information that we process include:

• personal identifiers and contacts (such as name, unique pupil number, contact details and address)

• characteristics (such as ethnicity, language, and free school meal eligibility)

• 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)

• attendance (such as sessions attended, number of absences, absence reasons and any previous schools attended)

• 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)


This list is not exhaustive, to access the current list of categories of information we process please see


Why we collect and use pupil information

The personal data collected is essential, for the school to fulfil their official functions and meet legal requirements.

We collect and use pupil information, for the following purposes:

a) to support pupil learning

b) to monitor and report on pupil attainment progress

c) to provide appropriate pastoral care

d) to assess the quality of our services

e) to keep children safe (food allergies, or emergency contact details)

f) to meet the statutory duties placed upon us by the department for education


Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing pupil information are:

• for the purposes of (a), (b), (c) & (d) in accordance with the legal basis of Public task: collecting the data is necessary to perform tasks that schools are required to perform as part of their statutory function

• for the purposes of (e) in accordance with the legal basis of Vital interests: to keep children safe (food allergies, or medical conditions)

• for the purposes of (f) in accordance with the legal basis of Legal obligation: data collected for DfE census information

o Section 537A of the Education Act 1996 o the Education Act 1996 s29(3)

o the Education (School Performance Information)(England) Regulations 2007

o regulations 5 and 8 School Information (England) Regulations 2008

o the Education (Pupil Registration) (England) (Amendment) Regulations 2013


In addition, concerning any special category data:

• In the case of ethnicity and fingerprint information: condition a: the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject.


Collecting pupil information

We obtain pupil information via registration forms at the start of each academic year. In addition, when a child joins us from another school, we are sent a secure file containing relevant information.


Pupil data is essential for the schools’ operational use. Whilst most of the pupil information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with UK GDPR we will inform you at the point of collection, whether you are required to provide certain pupil information to us or if you have a choice in this and we will tell you what you need to do if you do not want to share this information with us

Storing pupil data

We hold pupil data securely for the set amount of time shown in our data retention schedule. For more information regarding our data retention schedule and how we keep your data safe, please visit [link to website]

Who we share pupil information with

We routinely share pupil information with:

• school that the pupil attends after leaving us

• our local authority

• the Department for Education (DfE) • Local Authorities

Why we routinely share pupil information

We do not share information about our pupils with anyone without consent unless the law and our policies allow us to do so.


Department for Education

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 data collections, under:

• Section 537A of the Education Act 1996

• the Education Act 1996 s29(3)

• the Education (School Performance Information)(England) Regulations 2007

• regulations 5 and 8 School Information (England) Regulations 2008

• the Education (Pupil Registration) (England) (Amendment) 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

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. Requesting access to your personal data Under UK GDPR, parents and pupils 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 the school office on 020 7703 4168 or email

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 • prevent processing for the purpose of direct marketing

• object to decisions being taken by automated means

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

• a 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, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at

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 school office on 020 7703 4168 or email

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 on 26th April 2022


If you would like to discuss anything in this privacy notice, please contact:

• the school office on 020 7703 4168 or email

• Our local authority, Southwark Council ( )


How Government uses your data

The pupil 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 (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

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.

To find out more about the NPD, go to Sharing The law allows the Department to share pupils’ personal data with certain third parties, including:

• schools

• 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.

For information about which organisations the Department has provided pupil 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 to find out what personal information DfE hold about you

Under the terms of the Data Protection Act 2018, you are entitled to ask the Department:

• if they are processing your personal data

• for a description of the data they hold about you

• the reasons they’re holding it and any recipient it may be disclosed to

• for a copy of your personal data and any details of its source If you want to see the personal data held about you by the Department, you should make a ‘subject access request’. Further information on how to do this can be found within the Department’s personal information charter that is published at the address below:

To contact DfE: