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Privacy Statement

Holden Clough Community Primary School - Privacy Policy, May 2018

Holden Clough respects your right to privacy and complies with its obligations and adheres to the principles under the Data Protection Bill 2018 and the General Data Protection Regulation (GDPR). The purpose of this Privacy Policy is to outline how we deal with any personal data, including special categories of data, you provide to us or we collect about you from third parties. We take great care with any personal data we hold, so that we provide the highest standard of service to you, whilst taking steps to keep your data secure and to ensure it is only used for the specified, explicit and legitimate purposes stated within this privacy policy.

Unless otherwise stated the controller of your personal data for all purposes outlines in Section 3, 4 and 5 of this privacy policy is Holden Clough Community Primary School. Our Data Protection Officer can provide you with additional information on this policy, your rights and how we fulfil our obligations

Name: MaryAnn Davison

Address: c/o Holden Clough Community Primary School, St Albans Avenue, OL6 8XN

Email Address:

Phone Number: c/o 0161 3305248


Information Collection

In order to fulfil our obligations, Holden Clough Primary School collects personal data. Personal data is any information about a living person that can be used to identify that person. We will only collect information that is adequate, relevant and limited to what is necessary in relation to the purposes identified within this policy.

We collect personal data on pupils, parents and guardians, staff, governors, volunteers and other people who engage with or support the school.

Why we collect or use personal data

We use personal data for the following purposes

  • Pupil enrolment;
  • Pupil registration;
  • School administration;
  • Examinations;
  • Attendance & disciplinary records;
  • Child welfare (including medical welfare);
  • Contacting parent(s)/guardian(s) about school or pupil matters;
  • Staff administration;
  • Raising awareness of the school;
  • Ensuring safety and security on the school grounds;
  • Fund raising for the school.

Purposes for which we hold your Information

Holden Clough is required to have a lawful basis for all processing of personal data. Within the GDPR there are 6 lawful bases in total, and of those, there are 5 legal bases which we rely upon: Legal Obligation; Consent; Public Task, Contract and Vital Interests.

1. Legal Obligation

The following processes are examples of those which we undertake which are required to comply with a legal obligation under UK law to which Holden Clough is subject:

  • Providing information relating to staff and to the Tameside MBC;
  • Providing information on pupils to the Tameside MBC and Department of Education;

2. Contract

The following processes are examples of those which we undertake which are necessary for the performance of a contract to which the data subject is a party:

  • Administering staff activities;
  • Paying staff.

3. Public Task

The following processes are carried out under the terms of Holden Clough’s public task:

  • Administering staff activities;
  • Pictures of people entering the school captured on CCTV system for security and health and safety purposes;
  • Recruitment of staff;
  • Carrying out teaching and assessment of pupils.

4. Consent

Before carrying out the following processes we will ask for your consent:

  • Maintaining extra-curricular records (such as pupil attendance on day trips or residential visits);
  • School photographs.

5. Vital Interests

Although unlikely to occur on school premises, vital interests would be applicable if personal data had to be processed in order to:

  • Ensure medical attention is given to save someone’s life.


Special categories of data and data on criminal convictions and offences

We process health related data for several reasons and do this under a legitimate interest under Article 9 of the GDPR. For example:

  • Staff illness and sick leave;
  • Pupil illness and health-related information;
  • Data on accidents.

Data Sharing

The school is required to share pupils’ data with the DfE on a statutory basis.

The National Pupil Database (NPD) is managed by the DfE and contains information about pupils in schools in England. Holden Clough is required by law to provide information about our pupils to the DfE as part of statutory data collections, such as the school census; some of this information is then stored in the NPD. The DfE may share information about our pupils from the NDP with third parties who promote the education or wellbeing 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 any data shared from the NPD is maintained.

Holden Clough will not share your personal information with any third parties without your consent, unless the law allows us to do so.

The school routinely shares pupils’ information with:

  • Pupils’ destinations upon leaving the school;
  • The LA;
  • The NHS;
  • The DfE


In accordance with the GDPR, the school does not store personal data indefinitely; it is only stored for as long as necessary to complete the task for which it was originally collected.

As well as advice provided by the school’s Data Protection Officer, we also consult the Information and Record Management Society’s guidance on retention periods for school records.

What are your rights?

You have the right to:

  • Be informed about how Holden Clough uses your personal data;
  • Request access to the personal data that Holden Clough holds;
  • Request that your personal data is amended if it is inaccurate or incomplete;
  • Request that your personal data is erased where there is no compelling reason for its continued processing;
  • Request that the processing of your data is restricted;
  • Object to your personal data being processed.

Where the processing of your data is based on consent, you have the right to withdraw this consent at any time.

Raising concerns or making a complaint

If you have a concern about the way Holden Clough is collecting or using your personal data, in the first instance you can contact the school’s Data Protection Officer, whose details are provided on the first page of this policy. Alternatively, you can contact the Information Commissioner’s Office, Monday – Friday, 9am – 5pm, on 0303 123 1113.

DO NOT send your child into school if they have any ONE of the following symptoms: (1) A HIGH TEMPERATURE (this mean they feel hot to the touch on their back or chest) - (2) A NEW, CONTINUOUS COUGH (this means coughing a lot, for more than one hour, or 3 or more coughing episode within 24 hours) - (3) A LOSS OR CHANGE TO SENSE OF SMELL OR TASTE (this means they cannot smell or taste anything, or things smell or taste different to normal)