Privacy Notice

Privacy Notice: How we use Pupil Information in Cumbria Education Trust (William Howard School)

General Data Protection Regulation (GDPR) (regulation (EU) 2016/679)

We at William Howard School, are a data controller for the purposes of GDPR. We collect information from you and may receive information about you from your previous school and the Learning Records Service.

The WHS General Data Protection Regulations (GDPR) Policy can be viewed on the Policies page of the website:

Consent will be sought from the child after the age of 13 if we consider they have the competence to consent for themselves (often referred to as the Gillick competence test). If there is any doubt parental consent will continue to be required.


The categories of pupil information that we collect, process, hold and share include:

  • Personal data (such as name, unique pupil number and address);
  • Characteristics (such as ethnicity, language, nationality, country of birth and free school meal eligibility);
  • Attendance information (such as sessions attended, number of absences and absence reasons).
  • Assessment information (such as reports, feedback, test data and exam results)
  • Relevant medical information (such as medication details, allergies, medical conditions and notes from meetings/GPs/other health care professionals)
  • Special Educational Needs information (such as Education and Health Care Plans (EHCPs), Individual Education Plans (IEPs) and notes from review meetings and professional assessments)
  • Exclusion and behaviour information
  • Post 16 learning information and destination data


Why we collect and use this information

We use the pupil data:

  • To support pupil learning;
  • To monitor and report on pupil progress;
  • To provide appropriate pastoral care;
  • To assess the quality of our services;
  • To comply with the law regarding data sharing.


The lawful basis on which we use this information

We collect and use pupil information for general purposes under paragraphs 9.1c and 9.2g of the General Data Protection Regulations policy which complies with Articles 6 and 9 of the GDPR.


Collecting pupil information

Whilst the majority of pupil information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the GDPR, we will inform you whether you are required to provide certain pupil information to us or if you have a choice in this. We may also receive information about pupils from other organisations such as their previous school, local authority and/or Department for Education (DfE).


Storing pupil data

The length of time we hold pupil information is set out in the IRMS retention guidance. A copy of this guidance is available at or alternatively a hard copy can be made available upon request from school.

Who we share pupil information with

We routinely share pupil information with:

  • schools that the pupils attend after leaving us;
  • Cumbria County Council;
  • the Department for Education (DfE);
  • other public services that have a lawful right to collect pupil information
  • third parties as listed in Appendix 6 of the GDPR policy.


Why we share pupil information

We do not share information about our pupils with anyone without consent unless the law and our policies allow us to do so.

We share pupil information with the DfE on a statutory basis. This information sharing underpins school funding and educational attainment policy and monitoring. We are required to share information about our pupils with the DfE under regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.


Data collection requirements

To find out more about the data collection requirements placed on us by the DfE (for example; via the school census) go to:


Youth support services

Pupils aged 13+

Once our pupils reach the age of 13 we will pass pupil information including name, date of birth, address, contact telephone numbers and destination after leaving school to Inspira as they have responsibilities in relation to the education of 13-19 year olds under section 507B of the Education Act 1996 and The Education and Schools Act 2008. This enables them to provide services as follows:

  • youth support services;
  • careers advisers.

A parent or guardian can request that only their child’s name, address and date of birth is passed on to Inspira by informing the Headteacher’s PA or admin office. This right is transferred to the pupil once they are 13.

Pupils aged 16+

We will also share certain information about pupils aged 16+ with Inspira including name, date of birth, address, contact telephone numbers and destination after leaving school as they have responsibilities in relation to the education of 13-19 year olds under section 507B of the Education Act 1996 and The Education and Schools Act 2008. This enables them to provide services as follows:

  • post-16 education and training providers;
  • youth support services;
  • careers advisers.

For more information about services for young people, please visit Cumbria County Council’s website:


The National Pupil Database (NPD)

The NPD is owned and managed by the DfE and contains information about pupils in schools in England. It provides evidence on educational performance to inform independent research, as well as studies commissioned by the DfE. It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including schools, local authorities and awarding bodies.

We are required by law, to provide information about our pupils to the DfE as part of statutory data collections such as the school census and early years’ census. Some of this information is then stored in the NPD. The law that allows this is the Education (Information About Individual Pupils) (England) Regulations 2013.

To find out more about the NPD go to: information.

The DfE may share information about our pupils from the NPD with third parties who promote the education or well-being of children in England by:

  • conducting research or analysis;
  • producing statistics;
  • providing information, advice or guidance.

The DfE has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. Decisions on whether the DfE releases data to third parties are subject to an approval process and based on a detailed assessment of:

  • who is requesting the data;
  • the purpose for which it is required;
  • the level and sensitivity of data requested; and
  • the arrangements in place to store and handle the data.

To be granted access to pupil information, organisations must comply with strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the DfE’s data sharing process go to:

For information about which organisations the DfE has provided pupil information (and for which project) go to:

To contact DfE go to:


Requesting access to your personal data

Under data protection legislation, parents and pupils have the right to request access to their personal data. To make a request for your personal data, or be given access to your child’s educational record, contact the Headteacher’s PA or admin office.

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress;
  • prevent processing for the purpose of direct marketing;
  • object to decisions being taken by automated means;
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
  • claim compensation for damages caused by a breach of the Data Protection regulations.

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at:



The Data Protection Officer for Cumbria Education Trust is Mr N Polmear (Tel:01697 745768)