Privacy notice

Education & Early Years

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to services provided by EDUCATION & EARLY YEARS and tells you what we do with your personal information.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact 020 8583 2000 or via email at InformationGovernance@hounslow.gov.uk or the postal address below. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

Education Department London Borough of Hounslow Hounslow House,
7 Bath Road,
Hounslow, TW3 3EB

What type of information we have

We currently collect and process the following personal information:

• Names

• Addresses

• Dates of birth

• Unique pupil number

• Telephone numbers

• Email addresses

• GP details

As well as personal information where applicable, we may collect and share additional information known as ‘Special Categories of Personal Data’ where appropriate including:

• Gender

• Nationality

• Ethnic origin

• Religion

• Sexual orientation

• Special Educational Needs

• Health Data

How do we get your information?

Most of the personal information we process is provided to us directly by individuals, parents, carers or representatives

We may also receive personal information indirectly from:

• Health professionals such as General Practitioners and those providing therapeutic or medical care.

• Other Hounslow Council departments, such as Children’s Social Care, Housing, Benefits and Early Years provision

• Carers, advocates and family members

• Schools and Academies

• Pre-school Providers

• Government Bodies such as the Department for Education and the Department of Health and Social Care

• Other Local Authorities

We only process information from the above if it is required for us to carry out statutory functions for which we are legally responsible for.

Our Lawful basis for processing your information

The lawful basis we rely on for processing this information is

• Legal obligation – so that we comply with a common law or statutory obligation.

• Public task – so that we may perform a task in the public interest or for an official function, and the task or function has a clear basis in law.

If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on to process is

• Legal obligation – so that we comply with a common law or statutory obligation

• Substantial Public Interest – so that we comply with statutory and government purposes and equality of opportunity or treatment

The basis in law referred to above includes but is not limited to:

• Education Act 2011

• The Children Act 2004

• Childcare Act 2006

• Health and Social Care Act 2012

• Department for Education Statutory Guidance

Why we need your information (purposes of processing)

The personal data we collect will be used for the following purposes:

• To enable us to carry out statutory pre-school and educational functions for which we are legally responsible for, such as the provision of education, nursery, childcare, apprenticeships and training
• To allow us to communicate and provide services appropriate to children and young people’s needs, these may include, but are not limited to:

1. Educational assessments
2. Assessments of Special Educational Needs Assessments for an EHC Plan
3. School assessment information
4. Early Years Support
5. Access to funds
6. Safeguarding queries
7. Child protection concerns
8. Early Education provision for 2 year olds
9. Early Education provision for 3 and 4 year olds
10. Educational Psychology services
11. Schools Admission service
12. Professional’s Referrals
13. Free school meal eligibility
14. Eligible participation in the DfE Holiday and Activities Food Programme
15. To gather information which informs planning and service delivery decisions
16. Assess performance and set targets for schools
17. Where we are legally obliged to undertake data processing prevention and/or detection of fraud and crime
18. To process financial transactions or where the council is acting on behalf of other government bodies such as the Department for Work and Pensions, the Department of Education, the Department of Health and Social Care and the Ministry for Housing, Communities and Local Government
19. Where necessary, to safeguard and protect children and young people from harm or injury
20. To conduct research or statistical analysis that allows us to target and plan the provision of services for children and young people in education
21. To identify residents/users for notifying them of proposed or planned changes to services that may affect them
22. To assist the council in responding to emergencies or major incidents. This allows the council, in conjunction with the emergency services, to identify citizens who may need additional support
23. Where necessary, to safeguard children and young adults to protect them from harm or injury

Who your information may be shared with (internally and externally)

When it is necessary, we may share your information with:

• NHS England – General Practitioners and other health professionals, including hospitals, ambulance services and mental health trusts

• Commissioned Providers of care such as Hounslow and Richmond Community Health Care Trust

• Community enterprises that offer voluntary or commissioned services that support childcare, pre-school provision, education and training

• Other commissioned services such as transport providers to enable children and young people to be transported to educational establishments, day service provision and commissioned activity sessions

• Internal departments within the London Borough of Hounslow such as the School Effectiveness Service and Children’s Social Care

• Government Bodies such as the Department for Education and the Department of Health and Social Care

• Youth support services

• Schools and academies

• Post-16 education and training providers

• Careers advisors

• Ofsted

• KS1 and KS2 Moderators

• Public Health

• UK Health Security Agency

• Other Local Authorities (for example Children and Adult Social Care and Education Departments)

• The Metropolitan Police or other Police services

• London Fire Brigade and other Fire Services

• Family members, carers and advocates

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

We keep records containing personal information for specific periods depending on the type of record – these can be found in Appendix A of this document.

We will then dispose of your information in the most secure manner possible.

Business Intelligence, Profiling and Analysis

We may analyse your personal information to improve the council’s services for the following purposes:

• undertake statutory functions efficiently and effectively
• service planning by understanding your needs and your community's needs and to provide the services that you or your community request
• understanding what we can do for you and your community and inform you of other relevant services and benefits
• help us to build up a picture of how we are performing at delivering services to you and what services the people of Hounslow need
• analysis of costs and spend of services we provide so that we can ensure better and efficient use of public funds

The council is committed to using pseudonymised or anonymised information where practical, and in many cases this will be the default position.

Pseudonymisation is a procedure by which the most identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. An example of this is your National Insurance number or Council Tax Reference number.

Anonymisation is the process of removing identifying particulars or details. This means that the data cannot be linked back to identify you.

Data Matching and Auditing

We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Education and Skills Funding Agency and the Department for Education.

The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.

As part of the council's fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office.
More information about this is available online.

The national data opt out

The national data opt out was introduced on 25 May 2018 to allow you to opt out from the use of your data for anything other than your individual care and treatment. This will prevent it being used for research or planning purposes as listed above. The opt out is in line with the recommendations of the National Data Guardian in the Review of Data Security, Consent and Opt-outs.

The national data opt out applies to the NHS and some of the activities of the council. Further information and details about how you can opt out if you choose to do so is available online. 

Your data protection rights

The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’

Your right to make a complaint

The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

If you want to make a complaint you can contact us as follows:

Complaints Team
London Borough of Hounslow Hounslow House,
7 Bath Road,
TW3 3EB

Email: complaints.crt@hounslow.gov.uk

Telephone: 020 8583 5211

Data Protection Officer

The Council’s Data Protection Officer can be contacted as follows:

Information Governance Team London Borough of Hounslow Hounslow House,
7 Bath Road,

TW3 3EB

Email: InformationGovernance@hounslow.gov.uk

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: Information Commissioner's Office (ICO)

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:
Information Commissioner's Office
Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Email: casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.

APPENDIX A - RECORDS RETENTION SCHEDULE: EDUCATION SERVICES PROVIDED BY THE LOCAL AUTHORITY

Ref No	Records Description	Retention Period	Trigger	Legal Basis for Retention or Justification	Action at the End of Retention Period	Contains Personal Information	Protective Marking
EDU001	School Admissions - records related to successful admission	25 years	From DOB of pupil	School Admissions Code 2021	Secure Disposal	Yes (Y/N)	Official Sensitive (Personal)
EDU002	School Admissions - if the Appeal is unsuccessful	1 year	From resolution of the case	School Admissions Appeal Code 2021	Secure Disposal	Yes	Official Sensitive (Personal)
EDU003	Admissions policies	6 years	From date of policy	School Admissions Code 2021	Secure Disposal	Yes	Official Sensitive (Personal)
EDU004	School Admissions Appeals	2 years	From date the Appeal process is resolved	School Admissions Code 2021	Secure Disposal	Yes	Official Sensitive (Personal)
EDU005	Pupil Educational Record	25 years	From DOB of pupil	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU006	Early Years & Childcare Settings - Attendance records, accident record books, contractual documentation, parental permission forms	6 years	From date the child has left the setting	Statutory Framework for the Early Years Foundation Stage, 2021.	Secure Disposal	Yes	Official Sensitive (Personal)
EDU007	Early Years - Local Authority funded nursery and childcare placements	6 years - standard cases	From date the child has left the setting	Statutory Framework for the Early Years Foundation Stage, 2021.	Secure Disposal	Yes	Official Sensitive (Personal)
EDU008	Early Years - Local Authority funded nursery and childcare placements	40 years - in cases of Child Protection	From child's DOB	Arrangements for the Placement of Children (General) Regulations 1991	Secure Disposal	Yes	Official Sensitive (Personal)
EDU009	Early Years - Local Authority funded nursery and childcare placements	75 years - in cases of Looked After Children	From child's DOB	Children's Homes Regulations 2001 reg. 28	Secure Disposal	Yes	Official Sensitive (Personal)
EDU010	Attendance and Educational Welfare - records related to individual pupils including record of exclusions	25 years	From child's DOB	RGLA 3.19 (Retention Guidelines for Local Authorities, produced by LG Group of Records Management Society)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU011	Closed Schools - records related to pupil files held by the Local Authority	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU012	Educational Psychology Services - records related to the provision of educational psychology where provision is made only up to the age of 18	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU013	Educational Psychology Services - records related to the provision of educational psychology where provision is made up to the age of 25 years	6 years	From date of last contact	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU014	Educational Psychology Services - records related to the provision of educational psychology where provision is made up to the age of 25 years	40 years - in cases of Child Protection	From child's DOB	Arrangements for the Placement of Children (General) Regulations 1991	Secure Disposal	Yes	Official Sensitive (Personal)
EDU015	Special Educational Needs: Educational arrangements for those who have a learning difficulty and or a disability.	35 years	From date of last contact	RGLA 3.13 (Retention Guidelines for Local Authorities)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU016	Educational Support - Language and cultural support for children who do not have English as their first language.	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU017	Educational Support - records related to the management of pupils who are home schooled	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)

Ref No	Records Description	Retention Period	Trigger	Legal Basis for Retention or Justification	Action at the End of Retention Period	Contains Personal Information	Protective Marking
EDU018	Educational Support - records related to support given to traveller children	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes (Y/N)	Official Sensitive (Personal)
EDU019	Educational Support - all records related to educational support for Looked After Children including psychology services, attendance and welfare, SEN and results	75 years - records to be placed on child's social care file	From child's DOB	Arrangements for the Placement of Children (General) Regulations 1991	Secure Disposal	Yes	Official Sensitive (Personal)
EDU020	Educational Records - results achieved by primary, junior and secondary schools	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU021	Child Employment (children of compulsory school age) - records related to to the management of employment licences for children	25 years	From child's DOB	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU022	Careers Advice - records relating to careers advice given to pupils	10 years	From date the record is last modified	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive
EDU023	School Development Plans - the strategic plan for the development and improvements in schools	6 years	From the date the plan is superseded	Common Practice	Secure Disposal	Yes	Official Commercial
EDU024	School Transport - Records related to applications and receipt of School Travel Assistance.	6 years	From the date transport ceases	Common Practice	Secure Disposal	Yes	Official Sensitive
EDU025	School Transport - Records related to applications where School Travel Assistance has not been provided.	1 year	From completion of Appeals process	Common Practice	Secure Disposal	Yes	Official Sensitive
EDU026	Teacher Development & Mentoring - records related to support for teachers	10 years	From date the record is last modified	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU027	School Govenors - records related to governing body minutes	10 years	From date of meeting	School Governance (England) Regulations (2013)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU028	School Govenors - records related to complaints dealt with by the governing body	10 years	From date of resolution	Limitation Act 1980 (S2)	Secure Disposal	Yes	Official Sensitive (Personal)
EDU029	Annual Reports - records of statistical performance related reports required by DfE	10 years	From date of report	Education (Governors’ Annual Reports) (England)(Amendment)Regulations 2002.SI 2002 No 1171	Secure Disposal	Yes	Official
EDU030	Adult & Community Education - Registers and learning agreements for following programmes which the SFA are using as match funding for 2007-2013 ESF Programme 2: 16-18 & 19+ Apprenticeships, Workplace learning, Train to Gain, EFA Foundation Learning and Entry to Employment, Skills support for the unemployed	1st January 2023	N/A	Department of Work and Pensions	Secure Disposal	Yes	Official Sensitive (Personal)
EDU031	Adult & Community Education - Registers and learning agreements for following programmes which the SFA are using as match funding for 2014 - 2020 ESF Programme 2: 16-18 & 19+ Apprenticeships, Workplace learning, Train to Gain, EFA Foundation Learning and Entry to Employment, Skills support for the unemployed	1st January 2030	N/A	Department of Work and Pensions	Secure Disposal	Yes	Official Sensitive (Personal)

Ref No	Records Description	Retention Period	Trigger	Legal Basis for Retention or Justification	Action at the End of Retention Period	Contains Personal Information	Protective Marking
EDU032	Mayor’s ESF 2019-23 Programme - Career Clusters - 16-19 Education, Training and support to equip with work skills	31st December 2033	N/A	Department of Work and Pensions	Secure Disposal	Yes (Y/N)	Official Sensitive (Personal)