New School Year, New Requests

As staff and the students face the return to a new year, it’s worth taking a moment to ensure that you are prepared for the data protection challenges the year brings. As the year commences, the amount of personal data being collected rises rapidly.

If there were any issues with collection, collation, usage or storage last year, now is the time to consider improvements. You may have had new systems or upgrades a critical time for errors to be made.

The other area that can become very busy is requests for information. This may be about individuals in the form of SARs, or more general information in Freedom of Information and Environmental Information Regulations requests.

For SARs and most information requests, it’s now well established that these emerge as part of existing, usually difficult situations with parents or members of staff. Getting these requests right is essential in helping to close the issues behind them and avoiding further complications like the involvement of the Information Commissioner’s Office.

You need to have a clear, preferably documented, process for handling these requests. This includes interacting with the requester to get any clarifications required and setting clear parameters for extracting data. With data in hand, you need to have a well-defined set of rules to establish what data forms part of a response.

Finally, we come to what most organisations find to be the most difficult part of a request, Redaction. SARs and FOI requests have very different redaction rules but may often contain similar base data. The method you choose to undertake redaction is worth considering, but the crucial part is to have very clear guidance about what is included and what is redacted. Of particular concern is where information about one individual is interwoven with data about others.

Your Data Protection Officer should be able to provide the basis of guidance on these matters, but it well worth making sure that this information doesn’t just reside with that one person.