GrumbleDook

I'm speaking so can't do my tiger face

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Posh ....

ICO Advisory visits have been really good in many respects but you have to remember that they have a consistent approach and language no matter if you are a school, a charity, a large company with a turnover of £12m, someone with 300 employees and 20000 customers ... for some schools it becomes very scary, very quickly and some schools will need reassuring. ICO do their best with this from what we have seen but schools tend to have a very worried approach to anyone coming in to audit things. Sometimes having people who know schools better, are more aware of the language in place, the context and issues ... they are valuable and worth the time and money. Also, they can be constructive about options as well ... ICO cannot advise on specific technologies really, only say where there are gaps, where improvement is needed, where you meet the requirements ... It really does depend on what you are getting from the service.

I’ll be travelling up in the morning, but might see about popping over the day before for a bit, work permitting!

neighbours

You can have two arms of a company work independently of each other so that one provides a service and then recommends others. It is a fine line but possible. To some extent it comes down to how much you trust the company and their ethics. We tend to veer towards self assessment and where that has gaps then address as needed, including using independent services. To some extent, this is the model for Cyber Essentials too. It may be that the DPO has already identified a need to review something and this is part of the process. As I’ve said though ... it is a fine line.

Brothers ;-)

And breathe and relax .... Do you mind if I share this example with others about buggered up comms are when doing things like this? The UNi are acting as Data Controllers, and from the looks of it as sole Data Controllers (no mention of others involved in the gathering0 ... and you are just promoting taking part in the research. If everyone is *told* that they have to do it then Consent is not the lawful basis. Before the survey is filled in, all of the subjects should have had chance to see the Privacy Notice you linked to and the information sheet. At this point I would strongly advise you to speak to your DPO and talk to the ICO helpline.

Actually, the move away from Arbour is also relevent. When moving to any technology you *have* to consider the exit strategy. Failing to do this could mean serious problems further down the line, so I would consider the mention of Bromcom within the boundaries of relevance for others reading this thread over time.

I am close enough not to stay over now, but will stay on after the day for a catch up and some food.

How on earth would anyone consider this as anonymous? Is this general research or something specific the school has commissioned? If the request is for research purposes then there should be a clear outline of how data will be processed, any future sharing, etc. It may be that the analysis is done on an anonmyous basis (i.e. the team working on it has no idea what school that data set is from or the name of individuals, but other relevant details of age and linked group as what is used within the analysis. If this is research being done for the benefit of the wider education community, then the university leading the research will give guidance on how you allow this data to be shared. There needs to be a data sharing agreement in place and there needs to be an agreed lawful basis. Transparency would require sharing what is happening with staff, pupils and parents ... depending on the lawful basis used you may end up using Consent or if using a different lawful basis then you need to check how you are allowing the right to object. If this is school commissioned work, then a Data Processing Agreement will set out the terms. Forward sharing of data is something to look at here and this might be where they agree to anonymise (if forward sharing is allowed). If in doubt, approach British Education Research Agency for guidance on how research agencies should work with you. [edit - the presumption that you are doing a DPIA either way is a given]

Sisters

Line ....

Chocolate!

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DEATH ...

Japan ...

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Sheet ...