ryoung Posted July 4, 2017 Posted July 4, 2017 Dear colleagues. me again :-) One of the GDPR rights is the right to be informed. This means the school must provide ‘fair processing information’, typically through a privacy notice. Our school's current privacy notice is based on a template supplied by the LEA: http://wgswitney.org.uk/perch/resources/wgs-privacy-notice-2017.pdf Clearly the GDPR written for parents is going to need an update to be GDPR compliant. However my understanding is that we also need to generate a privacy notice which is appropriate for students. This requires generating accessible text for an 11 year old. Are there any colleagues out there who are ahead of the game and have already created GDPR compliant privacy notice is aimed at adults, and separately for children? if so please do share :-) Many thanks in advance. Richard Young
synaesthesia Posted July 4, 2017 Posted July 4, 2017 Surely that doesn't apply to the pupils until they're 16? In which case the one you already have would suffice.
ryoung Posted July 4, 2017 Author Posted July 4, 2017 Here is the ICO on this topic The GDPR contains new provisions intended to enhance the protection of children’s personal data: a. A privacy notice is written in a clear, plain way that a child will understand. b. Any online service offered to children need consent from a parent or guardian to process the child’s data. If the basis processing the child’s personal data is consent, then consent is required from the parent or guardian Source: Overview of the General Data Protection Regulation (GDPR) P11 https://ico.org.uk/media/for-organisations/data-protection-reform/overview-of-the-gdpr-1-11.pdf so in my view, the ICO require us to create a separate accessible privacy notice for students
TechMonkey Posted July 4, 2017 Posted July 4, 2017 Here is the ICO on this topic The GDPR contains new provisions intended to enhance the protection of children’s personal data: a. A privacy notice is written in a clear, plain way that a child will understand. b. Any online service offered to children need consent from a parent or guardian to process the child’s data. If the basis processing the child’s personal data is consent, then consent is required from the parent or guardian Source: Overview of the General Data Protection Regulation (GDPR) P11 https://ico.org.uk/media/for-organisations/data-protection-reform/overview-of-the-gdpr-1-11.pdf so in my view, the ICO require us to create a separate accessible privacy notice for students My interpretation of that is that your privacy notice, singular, is written in a simple way so that even a child could understand it. Not that you need two.
ryoung Posted July 4, 2017 Author Posted July 4, 2017 Good point. My action point becomes to rewrite our privacy notice in plain and simple English. I have looked hard but all I can find is LEA based templates adopted by schools which I am not sure pass the accessibility test
enjay Posted July 5, 2017 Posted July 5, 2017 Good point. My action point becomes to rewrite our privacy notice in plain and simple English. I have looked hard but all I can find is LEA based templates adopted by schools which I am not sure pass the accessibility test Can you test it? Show some Year 7s your current privacy/DP policy and ask them questions about it.
kennysarmy Posted January 23, 2018 Posted January 23, 2018 I've just been tasked with finding a template or draft or other Fair Processing Notice or Privacy Notice that we could use to base our student and staff ones on. Has anyone found such a thing or is happy to share theirs?
mwnci Posted February 1, 2018 Posted February 1, 2018 The dfe have produced privacy notice templates which seem like a good starting point for anyone: https://www.gov.uk/government/publications/data-protection-and-privacy-privacy-notices 1
mikkidoo Posted March 15, 2018 Posted March 15, 2018 The DFE PNs are aimed at LAs. We are using the templates from CEFM that are incredibly comprehensive, aimed at 10-13 yr olds. I'm struggling to make them accessible to 3-7 year olds which we ARE required to do. Anyone had any success in this?
Narwhal Posted March 15, 2018 Posted March 15, 2018 I think the the purpose of making privacy notices that are written for children is for services that are aimed at, or can be used by, children. We will not be asking for the children's consent for the processing of their data for the most part. Parents will be providing consent for those elements that require it (biometrics, use of images). Maybe at a later date students may have to re-affirm their consent to those elements and those parts may have to be written in terms that they can understand but the majority of the notice is aimed at adults.
GrumbleDook Posted March 15, 2018 Posted March 15, 2018 The right to be informed should not be confused with the lawful basis for processing. They should be informed no matter what lawful basis you use. The language should be age appropriate. 1
jonathan.lees Posted March 16, 2018 Posted March 16, 2018 I have one I worked on with our student council, we're a secondary. I'd prefer not to post it publically, pm me if you'd like to see it.
Narwhal Posted March 16, 2018 Posted March 16, 2018 The right to be informed should not be confused with the lawful basis for processing. They should be informed no matter what lawful basis you use. The language should be age appropriate. So what language would you use to inform a 4 year old starting primary school about the processing of their data? I don't mean to be flippant but there has to be a point at which you decide "this is the age at which the student needs to know about the processing of their data". I believe that GDPR (or the new Data Protection Act which will actually be the law in this country) will state that 13 is the age at which children can make informed decisions on this matter, therefore a privacy policy accessible by 13 year olds would be the lowest we would have to go.
korifugi Posted March 16, 2018 Posted March 16, 2018 The language should be age appropriate. Can you test it? Show some P.E. Teachers your current privacy/DP policy and ask them questions about it. Like this?
GrumbleDook Posted March 16, 2018 Posted March 16, 2018 (As a voice over on a video with relevant play-based graphics) “Schools can be fun but they have lots of things to remember and help you understand. You see lots of signs up in the school and lots of rules, and teachers and your parents try to help you understand what they mean. There is one called Privacy Notice, which is all about how things stay private on computers. It is how the school helps you understand what the school knows about you, why it needs to know it, who it will get to help with it and how they also talk to your parents about what it knows.” And you then go one from there?
enjay Posted March 19, 2018 Posted March 19, 2018 Like this? @korifugi That was not the original text of my post so please don't alter it to make it look like I said that, even if you only meant it as a joke.
korifugi Posted March 19, 2018 Posted March 19, 2018 @korifugi That was not the original text of my post so please don't alter it to make it look like I said that, even if you only meant it as a joke. Apologies
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