Castleford Academy Trust

Data Protection Policy

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Castleford Academy Trust aims to ensure that all personal data collected about staff, pupils, parents, governors, visitors and other individuals is collected, stored and processed in accordance with the General Data Protection Regulation (GDPR) and the expected provisions of the Data Protection Act 2018 (DPA 2018) as set out in the Data Protection Bill.

This policy applies to all personal data, regardless of whether it is in paper or electronic format.

Legislation and guidance

This policy meets the requirements of the:

It is based on guidance published by the Information Commissioner’s Office (ICO) on the GDPR.
It meets the requirements of the Protection of Freedoms Act 2012 when referring to our use of
biometric data.

It also reflects the ICO’s code of practice for the use of surveillance cameras and personal

In addition, this policy complies with our funding agreement and articles of association.


Personal dataAny information relating to an identified, or identifiable, individual.
This may include the individual’s:

· Name (including initials)
· Identification number
· Location data
· Online identifier, such as a username

It may also include factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural or social identity
Special categories of personal dataPersonal data which is more sensitive and so needs more protection, including information about an individual’s:

· Racial or ethnic origin
· Political opinions
· Religious or philosophical beliefs
· Trade union membership
· Genetics
· Biometrics (such as fingerprints, retina and iris patterns), where used for identification purposes
· Health – physical or mental
· Sex life or sexual orientation
ProcessingAnything done to personal data, such as collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying. Processing can be automated or manual
Data subjectThe identified or identifiable individual whose personal data is held or processed.
Data controllerA person or organisation that determines the purposes and the means of processing of personal data.
Data processorA person or other body, other than an employee of the data controller, who processes personal data on behalf of the data controller.
Personal data breachA breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

The data controller

Castleford Academy Trust processes personal data relating to parents, pupils, staff, governors, visitors
and others, and therefore is a data controller.

Castleford Academy Trust is registered as a data controller with the ICO and will renew this registration
annually or as otherwise legally required.

Roles and responsibilities

This policy applies to all staff employed by Castleford Academy Trust , and to external organisations
or individuals working on our behalf. Staff who do not comply with this policy may face disciplinary

Trust board

The Trust Board has overall responsibility for ensuring that Castleford Academy Trust complies with
all relevant data protection obligations.

Data protection officer

The data protection officer (DPO) is responsible for overseeing the implementation of this policy,
monitoring our compliance with data protection law, and developing related policies and guidelines
where applicable.

They will provide an annual report of their activities directly to the Trust Board and, where relevant,
report to the board their advice and recommendations on academy data protection issues.
The DPO is also the first point of contact for individuals whose data the Trust processes, and for the

Full details of the DPO’s responsibilities are set out in their job description.

Our DPO is Sam Stevens and is contactable via

All staff
Staff are responsible for:

Data protection principles

The GDPR is based on data protection principles that our Trust must comply with. The principles say that personal data must be:

This policy sets out how the academies within the Trust aims to comply with these principles.

Collecting personal data

Lawfulness, fairness and transparency

We will only process personal data where we have one of 6 ‘lawful bases’ (legal reasons) to do so
under data protection law:

For special categories of personal data, we will also meet one of the special category conditions for
processing under data protection law:

For criminal offence data, we will meet both a lawful basis and a condition set out under data
protection law. Conditions include:

Whenever we first collect personal data directly from individuals, we will provide them with the
relevant information required by data protection law.

We will always consider the fairness of our data processing. We will ensure we do not handle
personal data in ways that individuals would not reasonably expect, or use personal data in ways
which have unjustified adverse effects on them.

Limitation, minimisation and accuracy

We will only collect personal data for specified, explicit and legitimate reasons. We will explain these
reasons to the individuals when we first collect their data.

If we want to use personal data for reasons other than those given when we first obtained it, we will
inform the individuals concerned before we do so, and seek consent where necessary.

Staff must only process personal data where it is necessary in order to do their jobs.

We will keep data accurate and, where necessary, up-to-date. Inaccurate data will be rectified or
erased when appropriate.

When staff no longer need the personal data they hold, they must ensure it is deleted or anonymised.
This will be done in accordance with the Trust’s records management policy

Sharing personal data

We will not normally share personal data with anyone else, but may do so where:

We will also share personal data with law enforcement and government bodies where we are legally
required to do so, including for:

We will also share personal data with law enforcement and government bodies where we are legally
required to do so. We may also share personal data with emergency services and local authorities to help them to respond to an emergency situation that affects any of our pupils or staff.

Where we transfer personal data internationally, we will do so in accordance with UK data protection

Subject access requests and other rights of individuals

Subject access requests

Individuals have a right to make a ‘subject access request’ to gain access to personal information that
the Trust holds about them. This includes:

Subject access requests must be submitted in writing, either by letter or email to the DPO. They should

If staff receive a subject access request they must immediately forward it to the DPO.

Children and subject access requests

Personal data about a child belongs to that child, and not the child’s parents or carers. For a parent or
carer to make a subject access request with respect to their child, the child must either be unable to
understand their rights and the implications of a subject access request, or have given their consent.

Children aged 12 and above are generally regarded to be mature enough to understand their rights
and the implications of a subject access request. Therefore, most subject access requests from parents
or carers of pupils within the Trust may not be granted without the express permission of the pupil. This is not a rule and a pupil’s ability to understand their rights will always be judged on a case-by-case basis.

Responding to subject access requests

When responding to requests, we:

We will not disclose information if it:

If the request is unfounded or excessive, we may refuse to act on it, or charge a reasonable fee which
takes into account administrative costs.

A request will be deemed to be unfounded or excessive if it is repetitive, or asks for further copies of
the same information.

When we refuse a request, we will tell the individual why, and tell them they have the right to
complain to the ICO.

Other data protection rights of the individual

In addition to the right to make a subject access request (see above), and to receive information when
we are collecting their data about how we use and process it (see section 7), individuals also have the
right to:

Individuals should submit any request to exercise these rights to the DPO. If staff receive such a
request, they must immediately forward it to the DPO.

Parental requests to see the educational record

Parents, or those with parental responsibility, have a right to free access to their child’s educational
record (which includes most information about a pupil) within 15 school days of receipt of a written

Biometric recognition systems

Where we use pupils’ biometric data as part of an automated biometric recognition system (for
example, pupils use fingerprints to receive school dinners instead of paying with cash, we will comply
with the requirements of the Protection of Freedoms Act 2012.

Parents/carers will be notified before any biometric recognition system is put in place or before their
child first takes part in it. The Trust will get written consent from at least one parent or carer before
we take any biometric data from their child and first process it.

Parents/carers and pupils have the right to choose not to use an academy’s biometric system(s). We
will provide alternative means of accessing the relevant services for those pupils. For example, pupils
can use a unique pin number at each transaction if they wish.

Parents/carers and pupils can object to participation in any biometric recognition system(s), or
withdraw consent, at any time, and we will make sure that any relevant data already captured is

As required by law, if a pupil refuses to participate in, or continue to participate in, the processing of
their biometric data, we will not process that data irrespective of any consent given by the pupil’s

Where staff members or other adults use the academy’s biometric system(s), we will also obtain their
consent before they first take part in it, and provide alternative means of accessing the relevant
service if they object. Staff and other adults can also withdraw consent at any time, and the academy
will delete any relevant data already captured.


We use CCTV in various locations around the Trust sites to ensure it remains safe. We will adhere to
the ICO’s code of practice for the use of CCTV (see Castleford Academy Trust CCTV Policy for further

We do not need to ask individuals’ permission to use CCTV, but we make it clear where individuals are
being recorded. Security cameras are clearly visible and accompanied by prominent signs explaining
that CCTV is in use.

Photographs and videos

As part of our Trust activities, we may take photographs and record images of individuals within our
academies. We will obtain written consent from parents/carers, or pupils aged 18 and over, for photographs and videos to be taken of pupils for communication, marketing and promotional materials.
Where we need parental consent, we will clearly explain how the photograph and/or video will be
used to both the parent/carer and pupil. Where we don’t need parental consent, we will clearly
explain to the pupil how the photograph and/or video will be used.
Uses may include:

Consent can be refused or withdrawn at any time. If consent is withdrawn, we will delete the
photograph or video and not distribute it further. When using photographs and videos in this way we will not accompany them with any other personal information about the child, to ensure they cannot be identified.

See our safeguarding policy for more information on our use of photographs and videos.

Data protection by design and default

We will put measures in place to show that we have integrated data protection into all of our data
processing activities, including:

Data security and storage of records

We will protect personal data and keep it safe from unauthorised or unlawful access, alteration,
processing or disclosure, and against accidental or unlawful loss, destruction or damage.
In particular:

Disposal of records

Personal data that is no longer needed will be disposed of securely. Personal data that has become
inaccurate or out of date will also be disposed of securely, where we cannot or do not need to rectify
or update it.

For example, we will shred or incinerate paper-based records, and overwrite or delete electronic files.
We may also use a third party to safely dispose of records on behalf of the Trust or individual academy
within the Trust. If we do so, we will require the third party to provide sufficient guarantees that it
complies with data protection law.

Personal data breaches

The Trust and each academy within the Trust will make all reasonable endeavors to ensure that there
are no personal data breaches.

In the unlikely event of a suspected data breach, we will follow the procedure set out in appendix 1.

When appropriate, we will report the data breach to the ICO within 72 hours. Such breaches in a
academy context may include, but are not limited to:


All staff, trustees and governors are provided with data protection training as part of their induction
process. Data protection will also form part of continuing professional development, where changes to
legislation, guidance or the Trust’s processes make it necessary.

Monitoring arrangements

The DPO is responsible for monitoring and reviewing this policy. This policy will be reviewed annually.

Appendix 1: Personal data breach procedure

This procedure is based on guidance on personal data breaches produced by the ICO.

If it’s likely that there will be a risk to people’s rights and freedoms, the DPO must notify the ICO.

Records of all breaches will be stored on the academy’s computer system

Actions to minimise the impact of data breaches

We will take the actions set out below to mitigate the impact of different types of data breach,
focusing especially on breaches involving particularly risky or sensitive information. We will review the
effectiveness of these actions and amend them as necessary after any data breach.

Sensitive information being disclosed via email (including safeguarding records)