Lists of pupil names on the wall

[Jamman960]

Where do we stand with having pupil lists pinned up in classrooms/offices either as an entire form list or a shorter list detailing club assignments or music lesson timetables? in the past most of these only included first initial and surnames under form headings but some more recent lists tend to contain full names

 

I'm sure we can't continue with publishing full names but would limiting it to a combination of initials/first or surnames be sufficient under GDPR?

Edited February 20, 2018 by Jamman960

[GrumbleDook]

Think about why you are publishing them and who they are used by ... then think about what impact there is of others seeing it.

 

Let’s all do it as a general exercise and then round up at the end of the day.

[fiza]

We have a photo,name and form for "subject stars" for each subject outside the subject classroom.

[speckytecky]

So, a birthday board with names and months defo wouldn't be a good idea anymore - if ever it was, then!

[witch]

We have weekly achievers - name on a board with photo

[GrumbleDook]

Ok, let’s get some more examples in before we start looking at them.

[Fazza]

We go one step further - our Maths department tweets a photo (along with the name) of a student demonstrating good work so not on the wall, but on the internet if that counts?!

[Rob_D]

We have lists (with photos), of epipen users in the medical office.

[jmak]

All our classrooms have birthday lists (and our staffroom has one for staff too!). The reason: we celebrate birthdays.

 

We also have a complete list of pupils by class on the wall in the office. Reason: to quickly find pupils. It sounds like it shouldn't be necessary, but it's very heavily used by lots of staff.

[Jamman960]

I did a data protection walk last week and found a few more examples:

 

Pictures of pupils faces in balloons with their full dob & name underneath as part of a display (going to suggest year of birth is removed)

Photo board in kitchen(well hidden) with food allergy/requirements listed (ok? - access is controlled and its in the pupils interest to ensure we don't accidentally give them something they're allergic to)

Pupil house point/merit charts (going to suggest pupil names are shortened to first name only as its only used within the class)

SEND/EAL register in staffroom(strictly no pupils)

[pete]

Heads of Year have a board in their office with photo + full name for all the kids in their year. This is mainly for "what does Fred look like" purposes. HOY offices are locked when unoccupied.

 

Lists for clubs / expeditions / sports fixtures often have a list of names pinned up on a noticeboard somewhere. This is so the kids and staff know who's participating / supposed to be participating.

 

Kids with severe allergies have their name and photos on an under-counter board in the canteen where the checkout operator / catering staff can see but customers can't. This also appears on the till (cashless catering with allergy indicator) during purchases.

[hardtailstar]

We have up on walls

 

SEN unit - Photos and names of students

HOY offices - Photos and names of students

Department offices - Photos and names of students

Subject boards - High achievers/best homework/events - Photos and names

Medical room - All students with allergies/medical problems - Photos and names of students

Behavior unit - Photos and names of students

Reception - HB/HG/Student buddies - Photos and names of students

PE - Stars of sports - Photos and names of students

Display boards - trips/events/students in the news (all good stories!) - Photos and names of students

 

Those are the ones I can list off the top of my head.

 

In my opinion there is a need for photos and names in some instances but it is the content that needs to be addressed and the question asked on whether it needs to be up with photos and names and where it is placed.

 

For ones like in the SEN unit and the medical room, Photos and names plus information needs to be up somewhere but in a place not accessible to visitors.

 

Some of our offices have blinds over boards so that content like this can be hidden from view if the meeting rooms are all in use.

[Jamman960]

Why we publish form lists: it enables staff to identify what form group a pupil is in quickly, they are used by staff often to check pupils have been accounted for or to find spellings(?) - thinking about this many of our in-classroom uses are better covered by Sims

 

Impact of others seeing it: on the whole there is no impact however the list confirms the listed pupils attend the school and give an idea of age. If we were to have a celebrity's child on roll(we're an independent school) this info could be passed on to interested parties, in the case of looked after children or in some cases parents with court orders against them we'd actively not want to reveal the child's presence.

 

Right now neither of these scenarios affect us so I'm leaning towards stripping back the info presented to reduce its usefulness for non school employee's, maybe having two versions of the list generated - one for day to day use(checking pupils in/out) and another for display with less info presented if really needed.

[GrumbleDook]

Some good responses so far ...

 

We have use for internal reward / motivation, internal publicity, external publicity, identification, medical support, safeguarding.

 

We know that some of these will refer to name, age, medical need, educational needs, educational specialisms, personal interests.

 

We've had some risks covered so far, but based on the above put together some scenarios and try to explain the risks involved.

[mikeprice]

As parents/carers come into school and classroom - e.g. for parents evenings - this info is being displayed to the general public - so surely things like reading progress, medical conditions, images with full names - can all be a problem

 

the school that I recently left has some kids from a refuge and some others whose carers don't want their name of images on web, media etc - but their names (and one of them is unusual) are on display in the classroom and in the corridors

 

always seemed like a problem to me but maybe even more so

[elsiegee40]

I have seen exam battle boards up in the staff room and on a Head's office wall ... and wondered where they stand with visitors and cleaners being in those places.

 

Does the school talk to the cleaners about data protection and confidentiality? What about other people who use the staff room who are not employed by the school (for example interview candidates)? Should the parents of $student brought in because of his misbehaviour be able to see RAGged photos and names of the whole of year 11 on the wall?

[jmak]

Slightly different but related: we have photos of parents who are NOT allowed to collect their children behind the reception desk. From a privacy point of view I can see this as problematic - cleaners and other "non-authorised" people can see them - but it is obviously critical that they can be quickly identified. Do we need to document a risk assessment justifying our position, or even come up with another solution? Some cases require us to call the police if they come on site.

[GREED]

Saw a school recently I visited where they had students names, photos and their GCSE results (a promotional type thing it was) - thoughts?

[witch]

The "awards" board is visible from reception so any visitor could see it. Also we have the staff pictures and names - is that an issue or not?

I never thought about cleaners - I dont know if they are spoken to. The main one is also our caretaker but I dont think anyone has spoken to her either.

[Mako]

As parents/carers come into school and classroom - e.g. for parents evenings - this info is being displayed to the general public - so surely things like reading progress, medical conditions, images with full names - can all be a problem

 

Unless you can justify that the use of the data is necessary. If someone has a life threatening condition and they were to suffer a medical emergency and if having their photo up (possibly with the known condition) could save their life (i.e a visitor sees them in distress) then the use of the data in this way could be justified. It is, of course, a very risky scenario. The subject could request that their image not be displayed and such, which may increase the risk to their wellbeing.

 

If Little Jimmy has hayfever and doesn't suffer anaphylaxis as a result then I would consider the display of Little Jimmy's photo and medical condition to be unjustified.

 

We routinely get told of students with medical conditions yet I wouldn't know them from Adam if I walked past them, which does potentially jeopardise their safety. Their photos are in the staff room and the main office, nowhere else. I'm on the other side of the building.

[enjay]

Heads of Year have a board in their office with photo + full name for all the kids in their year. This is mainly for "what does Fred look like" purposes. HOY offices are locked when unoccupied.

 

What about when the room is occupied by visitors? Our Heads of Year routinely have parent meetings in their offices.

 

If we were to have a celebrity's child on roll(we're an independent school)

 

Not just an independent school problem. We're state and have/had notable families in the school community.

 

Does the school talk to the cleaners about data protection and confidentiality?

 

You should talk to all staff, but cleaners are often overlooked in that. Possibly complicated if they're contractors not school staff.

 

Medical room - All students with allergies/medical problems - Photos and names of students

 

That information needs to be quickly accessible but doesn't need to be on display - ours have a cover sheet saying "critical medical details" on them, so people walking past or sitting in the room can't see anything, but first aiders still have rapid access.

 

Saw a school recently I visited where they had students names, photos and their GCSE results (a promotional type thing it was) - thoughts?

 

In fairness, that information is probably on most of our websites, too.

[GREED]

In fairness, that information is probably on most of our websites, too.

 

Oh I know it is, I remember when I got my GCSEs they were posted in the local newspaper (not just mine, I am not that self-centred!).

 

My question is, assuming there is no active consent - should they be? On the wall, on the website, anywhere?

[enjay]

My question is, assuming there is no active consent - should they be? On the wall, on the website, anywhere?

 

No, probably not! Without active consent, I can't imagine under what legal basis we'd be posting that on our website. In fact, I struggle to think of a legal basis under which we would post any PII on our website or Twitter, so that includes the reports from sports fixtures too - we probably shouldn't name who scored the goal or won the 100 metres either (unless those events were accessible to the general public / parents, at which point we're just facilitating people finding information which is in the public domain)

[GREED]

No, probably not! Without active consent, I can't imagine under what legal basis we'd be posting that on our website. In fact, I struggle to think of a legal basis under which we would post any PII on our website or Twitter, so that includes the reports from sports fixtures too - we probably shouldn't name who scored the goal or won the 100 metres either (unless those events were accessible to the general public / parents, at which point we're just facilitating people finding information which is in the public domain)

 

Well, I guess if there was a child protection issue surrounding the kid who scored the winning goal (say dad is not to know where the kids are), then no. That is not a GDPR thing, this is a lot older than this.

 

However that aside, the GCSE results are personal data items, whereas the sports results (one could argue) is public information? Give it is being played in public?

[enjay]

whereas the sports results (one could argue) is public information? Give it is being played in public?

 

I don't think it is. If we played an after-school match with another school and members of the public turned up to watch, I think we'd send them away. That said, if they were parents of students in the opposing school, we'd probably allow it, at which point it has become sort-of-public, as we don't know who they are and (possible but unlikely) whether there is a court order in force with regards to one of our students.

 

It is questions like that which make me glad I'm not the DPO!