Subject Access Request Procedure
General Principles
Hullavington CE Primary and Nursery Primary School makes reasonable endeavours to ensure that:
1. all personal data collected on paper systems and on electronic systems shall be stored securely;
2. personal data shall not be accessible to or disclosed to any unauthorised third party;
3. staff, learners and other users of the School are able to appeal if a request for information is refused by the School;
4. where information has been provided by the data subject, in relation to the GDPR, School records will be up to date and accurate;
5. where subject access requests have been completed, the data subject has received confirmation that their data is being processed, has been provided access to their information and supplementary information such as where it is being stored.
Making a Subject Access Request
A subject access request should be made using the form which can be requested from the school office or downloaded from the website. This should be sent to Jacqui Trubee, our School Business Manager. Parents are asked to be specific as to what data they are requesting.
Appeals Procedure
In the event of dissatisfaction with the way in which your request was processed and/or with the decision taken by the School in relation to a request for personal information, an appeal can be made:
1 Resolving an appeal
The School encourages dissatisfied parents to raise concerns about how their request was dealt with and/or the outcome of a request for information by writing to the School. The details of an appeal should be clearly stated in writing and sent to:
Data Protection Officer
The reason(s) for the appeal should be clearly stated in the letter and the following procedure will then be applied:
2 How an appeal is dealt with
An appeal can be raised on two grounds:
1) the way in which the original request was processed, or
2) a refusal to disclose requested information.
An acknowledgement of the appeal will be made within three working days and the Data Protection Officer will arrange for a review to be conducted.
3 Any appeals against the way in which a request was processed and appeals against a decision not to disclose information
The Data Protection Officer or another member of the Governing Body will review the process used to deal with a request and/or a decision to refuse the disclosure. This review will be conducted by a person not party to the original decision and will consider any issues pertinent to the decision, pertinent to the process and as required by the relevant legislation.
The Data Protection Officer will inform the complainant of the outcome in writing. A response will normally be made within 20 working days of a formal appeal. However, the response time will vary depending on individual circumstances. Where consideration takes longer than 20 working days, i.e. because of research into the legal aspects relating to the appeal, the Data Protection Officer will endeavour to keep the complainant informed of progress and the reasons for any delay. Appeals will be dealt with in confidence as far as it is reasonable to do so.
4 What to do if you remain dissatisfied
Individuals have a right to appeal to the Information Commissioner’s Office. If such an appeal is to be made, the application should be made in writing to the:
Information Commissioner’s Office
Wycliffe House,
Water Lane Wilmslow,
Cheshire
SK9 5AF
The ICO may also be contacted by telephone on: 0303 123 1113