GDPR & UPN use - Statement from Groupcall

[GrumbleDook]

There is no 'official guidance' from DfE other than that which was published nationally in 2013. It is explicit: Quote page 7 of 19 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/270560/Unique_Pupil_Numbers_-_guidance.pdf [my underlining]

 

"The UPN must be a ‘blind number’ not an automatic adjunct to a pupil’s name. It must be held electronically and only output when required to provide information to the LA, central government or another school/academy to which the pupil is transferring."

 

What has been explained to participants on the forum differs between who you speak to at DfE, and the ICO. It seems sensible that the ICO and DfE need to agree a position in light of the questions raised, and we are recommending to them both, that the DfE guidance is updated accordingly with regard to GDPR.

 

That is, when the DfE even acknowledge that they *need* to update things!

[EdWhittaker]

There is no 'official guidance' from DfE other than that which was published nationally in 2013.

 

No, indeed that is true. However, what we have received from the DFE is a very clear clarification of that guidance. If anyone chooses to disregard that clarification, which to my mind is unequivocal, then that is of course their prerogative.

[GrumbleDook]

No, indeed that is true. However, what we have received from the DFE is a very clear clarification of that guidance. If anyone chooses to disregard that clarification, which to my mind is unequivocal, then that is of course their prerogative.

 

Ed, to some extent, until that response is made in a public arena (or released via FoI) there will always be some who question it. Would you be able to respond back Gary and ask him if this can be published as an article or clarification somewhere? It would simplify matters for many out there. I know that they are working on things, but every little helps.

[EdWhittaker]

okay, will do

(not holding breath waiting for reply!)

[elsiegee40]

That is, when the DfE even acknowledge that they *need* to update things!

@jenatddm @GrumbleDook Your wish is their command... DfE Guidance on UPNs revised 23/8/17!

DfE Guidance - Unique Pupil Numbers

 

Haven't read it yet, so can't be sure it's not just the generator that's updated

Edited August 27, 2017 by elsiegee40

[GREED]

The guidance document is still 2013

[GrumbleDook]

I saw, but a quick scan didn't show me what was updated.

 

Will review properly week after next.

[gh5000]

Nothing has been updated on the guidance document.

 

Revision notes for that webpage.

23 August 2017

Updated the UPN (unique pupil number) generator.

25 September 2015

Updated the UPN (unique pupil number) generator for the 2015 to 2016 academic year.

3 September 2014

Updated UPN generator for 2014 to 2015 academic year.

13 September 2013

First published.

[GrumbleDook]

So the latest we have is still the details posted by @EdWhittaker then, it seems.

[EdWhittaker]

I emailed Gary Connell at the DFE a week ago asking if he could make his clarification more widely available through, say, an update on the DFE website or something. No response so far.

[EdWhittaker]

@GrumbleDook @GREED and everyone

 

Ha, Sod's law in action. Shortly after I posted the above comment, I received this from DFE:

 

"Thanks Ed and your comments below are useful. We are hopefully that an amended UPN guide will be made available on GOV.UK shortly and this should hopefully contain the clarification you request. The guidance has been updated and is currently undergoing final review and sign-off before publication."

 

I have asked if they would be kind enough to give us a heads up when it's live.

Hopefully can put this thread to bed, one way or another, soon.