Data Protection and Record-keeping Policy
Introduction:
This policy was formulated by Staff and Board of Management of St. Broghan’s National School. The purpose of the policy is to identify the records required to be retained by the school and to ensure confidentiality and manageable procedures in relation to access to such records by parents and stake holders.
Rationale:
Relationship to School Ethos:
St. Broghan’s National School promotes openness and co-operation between staff, parents and pupils as a means towards providing the caring environment through which a child can develop and grow to his/her full potential.
Aims/Objectives:
Guidelines:
The Principal assumes the function of data controller and supervises the application of the Data Protection Act within the school. The data under the control of the Principal comes under the following headings.
1. Personal Data:
This data relates to personal details of the students such as name, address, date of birth, gender, ethnic origin, nationality, religious belief, medical details, dietary information, PPSN, contact details and parents names. These are kept in the strong room.
2. Student Records:
Student records are filed and held in the strong room.
Student records may contain:
3. Staff Data
This data relates to personal and professional details of the Staff such as name, address, date of birth, contact details, payroll number, attendance records, qualifications, school records, sick leave, CPD, curriculum vitae, school returns, classes taught, seniority and supervision payments. This information may be stored securely in the staff room filing cabinet or in the strong room.
4. Administrative Data:
This information may be stored in the staff room filing cabinet or in the strong room.
Access to Records:
The following will have access where relevant and appropriate to the data listed above;
A parental authorisation form must be completed by parents in the event of data being transferred to outside agencies such as health professionals etc. Outside agencies requesting access to records must do so in writing giving seven days notice. Parents/Guardians can make such a request either by phone, email or in writing. The right to erasure or rectification is available to change any mistakes or inaccuracies by proper authorisation through the same procedures.
The school uses the recommended report format from the NCCA and a school report is issued in June of each year.
The recommendations regarding safe storage and retention periods for different types of information are (ref: David Ruddy, Leadership+ Nov 2014):
Pupils
Retention periods
School register/Roll books
Indefinitely
Enrolment forms
Hold until Pupil is 25 years
Disciplinary notes
Never destroy
Test results - Standardised
Hold until Pupil is 25 years
Psychological assessment etc.
Never destroy
SEN files/IEPs
Never destroy
Accident reports
Never destroy
Child Protection reports/records
Never destroy
Section 29 appeals
Never destroy
Interview records for staff
Retention periods
Interview Board + Marking Scheme + Board of Management notes (for unsuccessful candidates)
18 months from close of competition plus 6 months in case Equality Tribunal needs to inform school that a claim is taken
Staff records
Retention periods
Contract of Employment, Teaching Council Registration, Vetting Records, etc.; Accident/injury at work
Reports retention for duration of employment + 7 years (6 years to make a claim against the school plus 1 year for proceedings to be served on school)
Board of Management Records
Retention periods
BOM agenda and minutes
Indefinitely
Payroll & Taxation
Revenue require a 6 year period after the end of the tax year
Invoices/receipts
Retain for 7 years
Audited accounts
Indefinitely
Storage:
All records are stored in the school for a minimum of 7 years until the past pupil reaches the age of 25. These records are stored in the strong room.
All completed school roll books are stored in a similar location.
Access to these stored files is restricted to authorised personnel only.
Computerised records, systems are password protected. Records are backed up to the school network regularly.
Success Criteria:
Roles and Responsibilities:
The school staff, under the direction of the Principal will implement and monitor this policy. Individual teachers may design, administer and record all in-class testing. The Principal will ensure records are maintained and stored, particularly the records of students transferring to another school.
Implementation Data:
This new policy is effective from the date ratified by the Board of Management.
All records held from before that date will continue to be maintained in the school.
Review/Ratification/Communication:
This policy was ratified in 2016.
The policy is available to read in the school office.
It will be reviewed every 2 years and amended if necessary.
References:
Introduction:
This policy was formulated by Staff and Board of Management of St. Broghan’s National School. The purpose of the policy is to identify the records required to be retained by the school and to ensure confidentiality and manageable procedures in relation to access to such records by parents and stake holders.
Rationale:
- A policy on data protection and record keeping is necessary to ensure that the school has proper procedures in place in relation to accountability and transparency
- It is good practice to record pupil progress so as to identify learning needs
- A policy must be put in place to ensure a school complies with legislation such as;
- Education Act, Section 9g requiring a school to provide access to records to students over 18/parents
- Education Welfare Act – requiring a school to report school attendance and transfer of pupils.
Relationship to School Ethos:
St. Broghan’s National School promotes openness and co-operation between staff, parents and pupils as a means towards providing the caring environment through which a child can develop and grow to his/her full potential.
Aims/Objectives:
- To ensure the school complies with legislative requirements
- To clarify the types of records maintained and the procedures relating to making them available to the relevant bodies
- To put in place a proper recording and reporting framework on the educational progress of pupils
- To establish clear guidelines on making these records available to parents and past pupils who are over 18
- To stipulate the length of time records and reports will be retained.
Guidelines:
The Principal assumes the function of data controller and supervises the application of the Data Protection Act within the school. The data under the control of the Principal comes under the following headings.
1. Personal Data:
This data relates to personal details of the students such as name, address, date of birth, gender, ethnic origin, nationality, religious belief, medical details, dietary information, PPSN, contact details and parents names. These are kept in the strong room.
2. Student Records:
Student records are filed and held in the strong room.
Student records may contain:
- Personal details of the student
- Medical sensitive data
- School report cards
- Psychological/Clinical/Occupational Therapy/Speech and Language Assessments
- Standardised Test Results
- Attendance Records
- Screening Test such as MIST and NRIT
- Data Protection
- Teacher – designed tests. Each class teacher designs his/her own test template
- Diagnostic Tests Reports
- Individual Education Plans
- Learning Support/Resource Data such as records of permission/refusal to access LS/RT services in the school,
- Portfolios of student work e.g. Art
- Details of behavioural incidents or accidents.
3. Staff Data
This data relates to personal and professional details of the Staff such as name, address, date of birth, contact details, payroll number, attendance records, qualifications, school records, sick leave, CPD, curriculum vitae, school returns, classes taught, seniority and supervision payments. This information may be stored securely in the staff room filing cabinet or in the strong room.
4. Administrative Data:
- Attendance Reports, Roll Book, Registers
- Accident Report Book
- Administration of Medicines Indemnity Form
- Policies
- HSE files
- Board of Management files
- Accounts
This information may be stored in the staff room filing cabinet or in the strong room.
Access to Records:
The following will have access where relevant and appropriate to the data listed above;
- Parents/guardians – see Appendix 1 from CPMSA outlining details of access
- Past pupils over 18
- Health Service Executive
- Designated school personnel
- Department of Education & Skills
- First and second-level schools (where relevant).
A parental authorisation form must be completed by parents in the event of data being transferred to outside agencies such as health professionals etc. Outside agencies requesting access to records must do so in writing giving seven days notice. Parents/Guardians can make such a request either by phone, email or in writing. The right to erasure or rectification is available to change any mistakes or inaccuracies by proper authorisation through the same procedures.
The school uses the recommended report format from the NCCA and a school report is issued in June of each year.
The recommendations regarding safe storage and retention periods for different types of information are (ref: David Ruddy, Leadership+ Nov 2014):
Pupils
Retention periods
School register/Roll books
Indefinitely
Enrolment forms
Hold until Pupil is 25 years
Disciplinary notes
Never destroy
Test results - Standardised
Hold until Pupil is 25 years
Psychological assessment etc.
Never destroy
SEN files/IEPs
Never destroy
Accident reports
Never destroy
Child Protection reports/records
Never destroy
Section 29 appeals
Never destroy
Interview records for staff
Retention periods
Interview Board + Marking Scheme + Board of Management notes (for unsuccessful candidates)
18 months from close of competition plus 6 months in case Equality Tribunal needs to inform school that a claim is taken
Staff records
Retention periods
Contract of Employment, Teaching Council Registration, Vetting Records, etc.; Accident/injury at work
Reports retention for duration of employment + 7 years (6 years to make a claim against the school plus 1 year for proceedings to be served on school)
Board of Management Records
Retention periods
BOM agenda and minutes
Indefinitely
Payroll & Taxation
Revenue require a 6 year period after the end of the tax year
Invoices/receipts
Retain for 7 years
Audited accounts
Indefinitely
Storage:
All records are stored in the school for a minimum of 7 years until the past pupil reaches the age of 25. These records are stored in the strong room.
All completed school roll books are stored in a similar location.
Access to these stored files is restricted to authorised personnel only.
Computerised records, systems are password protected. Records are backed up to the school network regularly.
Success Criteria:
- Compliance with Data Protection Act and Statute of Limitations Act
- Easy access to records
- Framework in place for ease of compilation and reporting
- Manageable storage of records.
Roles and Responsibilities:
The school staff, under the direction of the Principal will implement and monitor this policy. Individual teachers may design, administer and record all in-class testing. The Principal will ensure records are maintained and stored, particularly the records of students transferring to another school.
Implementation Data:
This new policy is effective from the date ratified by the Board of Management.
All records held from before that date will continue to be maintained in the school.
Review/Ratification/Communication:
This policy was ratified in 2016.
The policy is available to read in the school office.
It will be reviewed every 2 years and amended if necessary.
References:
- Solas (CPSMA) May-June 2001
- Education Act 1998
- Education Welfare Act 2000
- Date Protection Act 2003
- Freedom of Information Act