Q
Can admissions data be used to
contact families of incoming students, for example to invite them to attend the PTA summer fair? If yes, on what grounds is this acceptable?
A In most cases, your PTA is a separate
entity from the school, therefore you cannot share data with them unless the parent (or future parent) has given specific permission for you to do so. I would recommend asking parents as part of the enrolment process if they are happy to receive information from the PTA, then you could invite them to such events. If you are sharing parent data with the PTA, however, you will need to consider how the PTA is processing this personal data as the school will still have a responsibility to ensure this is being used appropriately. In many cases, schools will send
communications out to parents on the PTA’s behalf, so the school doesn’t actually share data, however even in this context the school is processing the parents’ personal data to promote PTA activities. As such, you will still need to rely on either consent from the parents to receive this information or be able to demonstrate that the school has a legitimate interest in promoting the summer fair to future parents and this needs to be made clear in your privacy notice. Don’t forget that if relying on email you will need consent under the PECR.
Q
Are there any restrictions on contacting local businesses
to request support, i.e. for sponsorship. And how should this data list be maintained?
A No, as long as the request relates to the actual business (rather
than a request for personal support from the individual). With local businesses, you are more likely to be successful by asking someone from the school community to make this approach – a parent or governor. Our recent careers fair had many parents involved. We ask them for support and they then contact us if they can help. Of course, such information should only be kept for as long as necessary – i.e. while planning and executing the event. Exhibitors could however, be asked if they would be interested in helping again in the future, which would justify keeping such information for a longer period of time, with this specific purpose in mind.
Q
Is it acceptable to maintain a database of local clubs
– those who currently use the school’s facilities and those who don’t (but might want to)?
A Yes, as long as the information stored is not personal data. If
it is personal data, i.e. a personal email address for the contact you hold (rather than an email address relating to the club) then you will need to consider having consent to continue to contact that individual under the PECR. When clubs do use the school’s facilities regularly, you could consider introducing a consent
form that clearly states why you intend to hold that data, for how long, and how you intend to use it.
Q
How should schools collect Gift Aid information from
parents? As this information will be uploaded to the HMRC website, does the school need special wording around the ‘sharing’ of this data with a third party?
A Gift Aid information should be collected at the same time as
a donation is made and needs to be kept for six full financial years after the financial year in which the donation is made. There are excellent examples of wording available from HMRC that should be followed. As there is a legal basis for retaining this data, there is no need for a data-sharing agreement in this case. Please see
gov.uk/claim-gift- aid/gift-aid-declarations.
Q
A local primary school organised a junior colour run
last autumn, with many children from other schools in the area taking part. It was hugely popular and they plan to run it again this autumn. Can they contact those who took part last year, inviting them to join in this year?
A It depends. You may be able to rely on legitimate interest to
contact runners from last year, given you are inviting them to the same event, but you would need to ensure you carry out a legitimate interest assessment to ensure you have considered their privacy rights and whether your communication is
Q
Many local estate agents put up boards promoting school summer fairs, paying the school/PTA around
£25 per board. Parents sign up to agree to take a board. How should this data be collected by the school and how should this be sent on to the estate agent so that they can visit those addresses to put up boards?
A You would need a data-sharing agreement between the school and the estate agent, which includes a clause
asking for proof of disposal of the information after a specified period of time – ideally six weeks after the event. Make it clear to parents that their data will be shared with the estate agent and explain the destruction agreement.
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