Guardians in Google Classroom GDPR Considerations?

[BFCIT]

Hello all,

 

After a bit of GDPR advice. We are keen to press forward with the addition of guardian email address to our Google Classroom provision.

What concerns me is what lawful bases other schools are using to input parents email address information onto the google classroom platform in the first place.

Have you argued public task? Have you gone out to parents and asked for consent to add them as a guardian? Can or should we change our data protection policy/privacy notice to state the use of parents contact details for educational platforms?

 

Thanks

[paulkerton]

Public task. Required to report these things to parents, after all.

And, they can reject the invite at the point of it being sent to them too.

[Ditto]

You might have tried this, but if not it might be worth a go - https://ico.org.uk/for-organisations/resources-and-support/lawful-basis-interactive-guidance-tool/

I suspect you'll end up with an inconclusive answer. Perhaps you could call ICO and see what they think - or see if your DPO has any advice.

 

I would recommend your data policies at the very least notify of this use of data.

 

Whilst Public task is an appealing basis, I'm not sure it can be fully justified - they key wording is whether it is legally necessary. For me, I suspect legitimate interest would be a stronger basis - see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/legitimate-interests/when-can-we-rely-on-legitimate-interests/#legitimate_appropriate - the following bullets from ICO look to fit the scenario well

the processing is not required by law but is of a clear benefit to you or others;

• there’s a limited privacy impact on the individual;
  
• the individual should reasonably expect you to use their data in that way;
  
• you cannot, or do not want to, give the individual full upfront control (ie consent) or bother them with disruptive consent requests when they are unlikely to object to the processing.