St Bernadette’s Catholic Primary School is set in beautiful grounds in Brighton. Their code of conduct is underpinned by the three words: READY, RESPECTFUL and SAFE – this code of conduct is also reflected in their attitude to data protection.

The school have been a customer of DPE since 2018 and have regular online meetings with one of our data protection consultants to check in on data protection policies, procedures, training and compliance – at least once per term. St Bernadette’s data protection ‘team’ is made up of the Deputy Head, i.e. a member of SLT and the School Business Manager – we find this combination a very successful one in schools as it has someone that can align data protection practices to the school and business strategy, while at the same time having someone available to implement everything on an operational level.

Having a member of SLT in the data protection role means that there is some authority when a procedure may need to be modified or streamlined. Having a member of the admin team means there is a good knowledge of the operational procedures of the school. The combination of two mean that compliance is regularly checked and modified accordingly. Plus they are a lovely team to work with!

A Data Protection Education subscription also includes a ‘Making the Rounds’ or data walk; after a recent data walk around St Bernadette’s Catholic Primary school, Data Protection Education thought that other schools could benefit from hearing about some of the procedures adopted by St Bernadette’s as they are not only practical and efficient for the school but they are also data protection compliant. 

The data walk indicated not only good physical security but highlighted some regular processes followed in schools done in a data protection friendly way, while maintaining safeguarding standards:

• Fire exit procedure  - A list for each class is kept in the admin office. This means that it is the teacher’s job to ensure that all pupils in the classroom are taken out to the fire exit point when the fire alarm goes off. The list is printed half termly from the MIS System and then used daily in the classrooms as a backup to the digital register. These are kept in the office, and taken out by a member of the admin team if there is a need to evacuate. They are then used to check off all children by the teachers while at the fire meeting point. The registers are kept locked in the office and then destroyed securely at the end of each half term.

• Accident procedure - An ‘ICE’ box is kept in the admin office and taken onto the playground during break. The box does not contain medication or any medical details about pupils, just ice packs, water and paper towels. There is one ice box and one accident book for the KS1 playground and one for the KS2 playground. They are returned at the end of break time, the icepacks returned to the freezer, and this is repeated at lunchtime. It means that minor bumps can be dealt with on the playground. The accident book is completed on the playground, the top copy goes to the parent if deemed necessary. The office administrator audits the books half termly. Any child requiring medication or more serious injury is brought to the office – either during break times or during lessons. Medication is kept in a locked cupboard in the medical room and the list of children requiring medication/inhalers is inside the locked cupboard. The key is in the key safe in the office. Medication/first aid is administered by first aid trained staff, and recorded in the medicine book/accident book as appropriate.

• Allergy/dietary information - The school has recently migrated to Arbor so their dietary and allergy information is entered onto a pupil’s record in Arbor. Staff undertake online allergy training on the National College. No allergy information is printed out. The kitchen staff use the CyPad for logging and viewing allergy information which is provided by their catering company, Caterlink. This will flag up any dietary requirements and lunch information is held digitally.

• SLT office - All SLT offices are locked. The SLT offices and admin office have keypad locks and are kept locked when unoccupied.

The above procedures are put into place quite differently in all schools. Sometimes it depends on the size or age of the children in the school, but sometimes it might be based on what has been traditionally done so a review or seeing how other schools might being doing it now can be helpful. Some of the above procedures can result in a school printing several lists, either daily, weekly or termly, often with full names, classes and occasionally dates of birth and special category data about the children. The lists are used sometimes as a visual reminder of where that person needs to be or a group that they may be, however, considerations when printing lists should be: 

• Once information is taken out of the pupil MIS it is more at risk of a data breach.
• Where is the list stored when not in use? If it is on the wall in the classroom is it forthe convenience of the teacher or the children?
•  What happens to the list when it is no longer useful?

St Bernadette’s have the added low risk factor that there are currently only a few external companies that let any rooms in the school. These are for after school activity clubs, and are restricted to use of the hall and outside play areas. If you have lettings that regularly use your school out of school hours consider reviewing: Lettings Best Practice and Guidance which discusses the risks and considerations. However, it does mean that because they have good practice around data protection, there will be very little to improve should that change in the future.

Further information about our Making the Rounds: