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Norbury C of E Primary School

NorburyC of E Primary School

Laughter and Learning in a
Caring Christian School

Policies

 

Anti Bullying Policy

Introduction

At Norbury CE Primary School we provide a safe, caring and friendly environment for all our pupils to allow them to learn effectively, improve their life chances and help them maximise their potential. Every child has the right to be safe in the school environment.

We expect pupils to feel safe in school, including an understanding of the issues relating to safety, such as bullying.  We also want them to feel confident to seek support from school by talking to teachers, support staff and even their peers should they feel unsafe.

 

Policy Development

This policy was formulated in consultation with the whole school community with input from:

  • Members of staff
  • Governors
  • Parents and Carers
  • Children

 

Pupils contribute to the development of the policy through pupil voice questionnaires, the School Council, circle time discussions, discussions in class and communication with staff.  The School Council have developed a pupil friendly ‘anti-bullying’ policy to be displayed in all classrooms and prominent areas in school.

 

Parents and Carers are encouraged to contribute to the anti-bullying policy by:

 

  • taking part in written consultations
  • parent focus groups
  • parent questionnaires

 

The Policy aims to produce a consistent school response to any bullying incidents that may occur.  All people connected with the school are aware of our zero tolerance to bullying. Norbury School is proud that our children feel they can talk to the staff and that the staff will look after them and listen to them.

Roles and Responsibilities

 

The Head Teacher – Has overall responsibility for the policy and its implementation.  This also involves liaising with the governing body, parents/carers, LA and outside agencies.

 

The Anti-bullying Coordinator in our school is:  Sally Wright

The nominated Governor with the responsibility for Anti-bullying (Behaviour) is:  Carollyn McDonald

Their responsibilities are:

 

  • Policy development and review
  • Informing staff of policy content
  • Implementing the policy and monitoring and assessing its effectiveness in practice
  • Ensuring evaluation takes place and that this informs policy review
  • Managing bullying incidents
  • Managing the reporting and recording of bullying incidents
  • Assessing and co-ordinating training and support for staff and parents/carers where appropriate
  • Co-ordinating strategies for preventing bullying behaviour
  • Providing information about the effectiveness of the anti-bullying policy upon request
  • Establishing and promoting a climate of mutual support, trust, respect and celebration or success, therefore making bullying less likely.

 

The Governing Body – Supports the Headteacher in all attempts to eliminate bullying from our school.  Any parent or carer who is dissatisfied with the way the school has dealt with a bullying incident can ask the Chair of Governors to look into the matter.  The Governing Body will respond within 10 days to any request from parents to investigate incidents of bullying.  In all cases, the Chair will notify the Headteacher and work together to conduct a further investigation.  Advice from the LA may be sought.

 

Teacher and Support Staff – All staff at Norbury School take all forms of bullying seriously and seek to prevent it from taking place. A staff behaviour log is retained and circulated to all staff regularly Incidents that amount to bullying are logged in the School Safeguarding File.  Staff will do all they can to support the child being bullied and the bully.  If a child is being bullied or is a bully, parents will be informed. Time is devoted to supporting the bullied and the bully.  The Headteacher is made aware of any bullying and parents are invited to school to discus in more detail.  Should it be necessary or required, the Headteacher may seek the support of external agency teams such as the LA Behaviour Support Team, the Multi Agency Team etc. Teaching staff are supported via the provision of training.  Staff may use a range of teaching methods such as role play, drama, circle time, informal and formal curriculum time to further explore bullying and its unacceptable nature. Golden rules are circulated at the beginning of the academic year and children are encouraged to:

“Treat others as you wish to be treated.”

 

Parents  Parents who are concerned if their child is being bullied or is a bully should speak to the class and/or Headteacher in the first instance.  The course of action will then be discussed and agreed.

 

Pupils – Pupils are encouraged to tell someone they trust, for example, an adult or a peer. Assemblies regularly refer to issues surrounding appropriate behaviour eg; school values, sharing worries and being kind. These are delivered in an age appropriate and memorable way, for example through picture books such as ‘The Big Bag of Worries’. In addition, pupils are invited to express their views via the annual pupil questionnaire.  Pupils have a responsibility to follow the ‘Recipe for a Good Friend’ as drawn up by the children to support anti-bullying.

 

 

Monitoring and Review – The policy in operation is monitored by staff and the Headteacher on a daily basis.  Incidents of bullying are logged and monitored frequently by the Headteacher.  The effectiveness of the policy is monitored via the bi-annual safeguarding review.  Information is reported to Governors in strictest confidence.

 

Definition of Bullying

‘Behaviour by an individual or group usually repeated over time, that intentionally hurts another individual or group either physically or emotionally’.

Safe to Learn: embedding anti bullying work in schools (2007).

How does bullying differ from teasing/falling out between friends or other types of aggressive behaviour?

 

?? there is a deliberate intention to hurt or humiliate.

?? there is a power imbalance that makes it hard for the victim to defend themselves.

 

?? it is usually persistent.

 

Occasionally an incident may be deemed to be bullying even if the behaviour has not been repeated or persistent – if it fulfils all other descriptions of bullying.  This possibility should be considered, particularly in cases of sexual, sexist, racist or homophobic bullying and when children with disabilities are involved.  If the victim might be in danger then intervention is urgently required.

What does bullying look like?

 

Bullying will include at least one of the defined categories of abuse as defined in ‘Working Together to Safeguard Children’ (2018) which is defined in the ‘Keeping Children Safe in Education Statutory Guidance 2018’ as:

 

  • Physical Abuse – may involve hitting, shaking, throwing, poisoning, burning/scalding, drowning, suffocating, or otherwise causing physical harm to a child.

 

  • Emotional Abuse – is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person.  It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may involve seeing or hearing the ill-treatment of another.  It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger.

 

  • Sexual Abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. Other children can perpetrate sexual abuse, this is known as ‘peer on peer abuse’.

 

Bullying can include:

  • name calling
  • taunting
  • mocking
  • making offensive comments
  • physical assault
  • taking or damaging belongings
  • cyber-bullying – inappropriate text messaging and e-mailing; sending offensive or degrading images by phone or via the internet
  • producing offensive graffiti
  • gossiping and spreading hurtful and untruthful rumours
  • excluding people from groups.

Although bullying can occur between individuals it can often take place in the presence (virtually or physically) of others who become the ‘bystanders’ or ‘accessories’.

 

Why are children and young people bullied?

Specific types of bullying include:

  • bullying related to race, religion or culture
  • bullying related to special educational needs or disabilities
  • bullying related to appearance or health
  • bullying relating to sexual orientation
  • bullying of young carers or looked after children or otherwise related to home circumstances
  • sexist or sexual bullying

There is no hierarchy of bullying – all forms should be taken equally seriously and dealt with appropriately.

Bullying can take place between:

  • young people
  • young people and staff
  • between staff
  • individuals or groups

 

Certain groups of pupils are known to be particularly vulnerable to bullying by others:
these may include pupils with special educational needs such as learning or physical
disabilities; young carers, looked After children, those from ethnic and racial
minority groups and those young people who may be perceived as lesbian, gay, bi-
sexual, transgender or questioning their gender role.

Reporting and Responding to Bullying

 

Norbury School has clear and well publicised systems to report bullying for the whole school community (including staff, parents/carers, children and young people).  This includes those who are the victims of bullying or have witnessed bullying behaviour (bystanders)

  • In the first instance, the concern should be raised with the class teacher
  • The concern should also be raised with the Headteacher
  • Staff at this point will collect evidence of the concern
  • Evidence will be logged in internal monitoring files
  • The victim of the bullying will be supported
  • The bully will be spoken to
  • Parents will be informed as appropriate
  • A plan of action to track and follow the incident will be drawn up. This may involve the support of external agencies.

 

Procedures

 

All reported incidents will be taken seriously and investigated involving all parties.

  • Once a concern of bullying has been logged with the class or Headteacher, information will need to be collated from a variety of sources. This may involve interviewing and discussing events or actions with pupils, staff or others. All interviews will be handled confidentially and sensitively.
  • Parents of the bullied and the bully will need to be informed once information has been collated
  • There will be a multistep approach appropriate to the situation presented, for example:

solution focused, restorative approach, circle of friends, individual work with victim, perpetrator, referral to outside agencies if appropriate

  • Referral will be made to the School Behaviour Policy, outlining the appropriate level of sanction to be employed.A firm approach to bullying will be adopted within school.
  • Parents of the bullied and the bully will need to be informed once information has been collated
  • Liaison with the bully, bullied and their parents will be in place, including appropriate follow up.
  • Support for the victim and the bully will be evident

 

Recording Bullying and Evaluating the Policy

Bullying incidents will be recorded by the member of staff who deals with the incident and this will be notified to and held by the Anti-bullying coordinator.

 

The information we hold will be used to ensure individual incidents are followed up.  It will also be used to identify trends and inform preventative work in school and development of the policy.

This information will be presented to the governors in an anonymous format as part of the annual report.

 

The policy will be reviewed and updated annually. The policy review will be linked to the School Improvement Plan, working towards a more inclusive and harmonious ethos across the school community.

Strategies for Preventing Bullying

As part of our on-going commitment to the safety and welfare of our pupils we at

Norbury CE Primary School has developed the following strategies to promote positive behaviour and discourage bullying behaviour.

 

  • Restorative Approaches
  • Positive behaviour management and reinforcement of importance of positive and empathetic social behaviour eg through classroom systems, gold book assembly.
  • A climate where every pupil is expected to be the best that they can be and a growth mind-set is promoted.
  • Involvement and teaching of SEAL including Anti-Bullying Unit.
  • Anti-Bullying/Friendship week annually in November.
  • PSHE/citizenship
  • Specific curriculum input on areas of concern such as Cyberbullying and online safety
  • Golden rules introduced in September throughout school
  • Student voice through groups such as school council
  • Parent groups eg PiPs
  • Playground Ambassador/Buddy Scheme
  • Parent information events/information
  • Staff training and development for all staff. This should be anticipatory and related to pupil need.
  • Counselling and/or Mediation schemes may be accessed for individual children through services such as CAMHs

Safeguarding

Safeguarding our children is of paramount importance and underpins all of the work at our school. Staff are contemplative and vigilant in noticing changes in children’s behavior which may include negative behavior towards others. This policy should be read in conjunction with the school Child Protection and Safeguarding Policy.

 

Healthy Eating Policy

At Norbury C of E Primary School we understand that a balanced diet makes an important contribution to children’s growth and development as well as to their ability to learn successfully.

The school is dedicated to providing an environment that promotes healthy eating and enables pupils to make informed food choices.  This will be achieved by a whole school approach to food provision and food education documented in this policy.  This school food policy is coordinated by Sally Wright, deputy head teacher.

The main aims of our school food policy are:

  • To provide a range of healthy food choices throughout the school day and in line with the mandatory School Food Standards.
  • To support pupils to make healthy food choices and be better prepared to learn and achieve.
  • To ensure a consistent approach to healthy eating across the school community including pupils, staff and parents/careers.

Breakfast

Breakfast is an important meal that should provide 25% of a child’s energy requirement and supports pupils to be ready to learn at the start of each day.

The school runs a daily breakfast club for pupils from 7.45am – 8.45

The breakfast menu includes porridge, fruit, toast and cereal.

School lunches

School meals are provided by Derbyshire County Council and served between 12-12:30 in the village hall.  The school meals meet the mandatory requirements of the School Food Standards 2015.  The school caterer has achieved the Soil Association Food for Life Catering Mark Silver Accreditation.  This award means that the caterers uses local, seasonal and fresh ingredients which are free from trans fats, harmful additives and are not genetically modified.  Only UK Farm Assured meat is used which is better for animal welfare, sustainable sources of fish and free range eggs.

School meals are planned on a 3-week cycle which changes every 6 months.  New dishes and recipes are trialed by our school catering staff and children before they are added to the new menu.

School catering staff attend annual transition events for new pupils and explain the meals which will be available.  Parents are encouraged to discuss any dietary needs with catering staff and adaptations are made accordingly.

Packed lunches

The school’s packed lunch policy is developed using guidance from the Children’s Food Trust.  The guidance aims to support pupils to have a balanced lunch and best prepare them for learning in the afternoon.

Packed lunches should aim to include:

  • Some starchy foods such as bread (sliced bread, pitta bread, wraps, bagels), pasta, potatoes, couscous.
  • 1 portion of fruit and 1 portion of vegetables or salad
  • Dairy food such as cheese or yoghurt
  • Meat, fish or another source of protein such as eggs, beans and pulses, humus, falafel

Packed lunches should not regularly include:

  • Crisps or crisp type snacks e.g. flavored rice cakes or cheddars
  • Chocolate bars or biscuits
  • Items high in sugar such as biscuits, cakes or desserts

Packed lunches should never include:

  • Sweets

Please see www.childrensfoodtrust.org.uk if you require any additional information.

In recognition of the important environmental drive to reduce plastic waste, we would also like to ask parents to consider packaging when preparing a packed lunch.  For example, avoid individually wrapped items, using Tupperware to pack items rather than cling-film, using water bottles rather than cartons of drink.

Snacks

The school understands that healthy snacks can be an important part of the diet of young people.  In our EYFS/KS1 classes, fruit is provided during the morning.  This changes on a seasonal basis and can include; pears, apples, bananas, satsumas, tomatoes, baby cucumbers, strawberries and raisins.

KS2 pupils are able to bring in their own snacks to eat at break time.  This should ideally be a piece of fruit.

 

 

After school club

Children attending our after school club will be provided with a healthy snack and a drink.  The after school club menu includes: ham or cheese sandwiches, crudités, crackers, beans on toast, fruit and yoghurt.

Drinks

The school is a water only school, with the exception of the free milk entitlement for younger and pupil premium pupils.  Parents may also choose to purchase daily milk for their pupils by signing up at https://www.coolmilk.com.

Drinking water and cups are provided in each classroom.  Children are encouraged to drink water at regular intervals throughout the school day.

School trips

EYFS/KS1 and pupil premium children can be provided with a packed lunch for school trips.  Please pre-order this with your child’s class teacher.  Children are welcome to bring their own packed lunches on trips, however, these lunches must adhere to the same food and drink guidance described above.

 

Rewards

The school does not allow food to be used as a reward for good behavior or achievement.  Other methods of positive reinforcement are used in school including class awards, Class Dojo Points Gold Book certificates, learner plates.

Celebrations

The school recognises the importance of celebrating birthdays and special occasions.  Birthdays will be celebrated in a special assembly where children will take part in our school birthday traditions of singing songs and blowing out the candles on the Victorian birthday cake.  Classes might also choose to celebrate birthdays in their own ways such as: a birthday card or birthday badge. We discourage chocolates, sweets and cakes for birthdays.

For celebration events, we welcome a variety of foods for children to try.

Fund-raising events may include the sale of treat food such as cakes, but the inclusion of other foods will also be encouraged.

 

 

 

Food and nutrition is taught at an appropriate level throughout each key stage in Science, PSHE and Design and Technology.  The Eat well model is used throughout the school (see appendix 1) as a model of understanding a balanced diet.  Our EYFS children cook every week, enjoying a balance of mostly savory and some sweeter dishes.  Cooking opportunities throughout the school are linked to the curriculum such as; weighing ingredients in Maths, cooking traditional celebration foods in RE or tasting global foods as part of Geography work.  Christmas cookery clubs are also provided for older children and supported by school catering staff.  At Forest School children will be given regular opportunities to cook on the fire, preparing a range of snacks such as toast, crumpets, noodles, soup and s’mores.

Staff delivering cooking sessions and clubs on the school premises and at our Forest School site have achieved Level ½ in Food Safety and Hygiene.

The school is committed to doing everything possible to accommodate pupils’ specialist dietary requirements including allergies, intolerance, religious or cultural practices.  School catering staff will work with parents and school staff to plan for and meet individual dietary requirements.  Individual health care plans will be developed for any children with food allergies and medicine administered in line with our ‘Administration of Medicines Policy’ and guidance on ‘Supporting pupils with medical conditions’.

Pupil’s food allergies are displayed in a sensitive way in relevant places around the school including the school office and kitchen.

The school expects staff to contribute to and support this food policy across the school day.  Staff and visitors will be expected to model good practice behavior around food and drink and in line with the policy, when in the company of pupils.

Teaching staff are also encouraged to eat a school lunch and sit with pupils in the dining hall on a regular basis.

Our relationships with parents/careers is very important and we aim to support them with information and advice around food, so that they are best prepared to make healthy choices for their families.  Teaching and catering staff are available on an informal basis to support parents and careers where appropriate.

 

SEND Policy

This policy complies with the statutory requirement laid out in the SEND Code of Practice 0-25 (June 2014) 3.65 and has been written with reference to the following guidance and documents;

  • Equality Act 2010: Advice for Schools DfE February 2013
  • SEND Code of practice 0-25 (June 2014)
  • Schools SEN Information Report Regulations (2014)
  • Statutory Guidance on Supporting Pupils at School with Medical Conditions
  • The National Curriculum in England Key Stage 1 and 2 Framework Document September 2013
  • Safeguarding Policy
  • Accessibility Plan
  • Teacher’s Standards 2012
  • Positive Behaviour Management Policy
  • Anti-Bullying Policy
  • Equal Opportunities PolicyInformationThis policy was written in consultation with stakeholders including children, parents, staff and governors. The day to day implementation of this policy is led by our Special Educational Needs Co-ordinator Sally Wright. It is the responsibility of the Headteacher, Rebecca Chapman, to ensure that it is implemented. Sally and Rebecca can be contacted at school on 01335 324337 or at info@norbury.derbyshire.sch.uk. The governor with responsibility for Special Educational Needs is Kate Fitzpatrick. Kate can also be contacted through school on the above number or email.Our SEND policy reflects the SEND Code of Practice 2014, 0-25 guidance. It has been shared with the school’s governing body and will be reviewed regularly.A SEND Information Report will be shared with parents, carers and the governing body and published on the school’s website. This will be updated as a result of any changes to arrangements, such as staffing or CPD or annually as required. Parents, carers and children will be invited to contribute to the SEND Information Report.“Every Teacher is a Teacher of Every Child”Every teacher is a teacher of every child or young person, including those with SEND. As such ‘Norbury Church of England Primary School’ adopts a ‘whole school approach’ to special educational needs, which involves all staff adhering to a model of good practice. The staff of the school are committed to identifying and providing for the needs of all children in a wholly inclusive environment.

 

Aims and Objectives of this Policy

At Norbury Church of England Primary School we work hard to ensure every child achieves their full potential, and encourage all children to have high aspirations. When working with children with SEND (Special Educational Needs and Disabilities) we are focussed on supporting children to achieve their very best possible outcomes.

This policy supports us in meeting the following objectives;

  1. To identify and provide for pupils who have special educational needs and additional needs .
  2. To work within the guidance provide in the SEND Code of Practice, 2014.
  3. To operate a “whole pupil, whole school” approach to the management and provision of support for special educational needs.
  4. To identify a Special Educational Needs and Disability Co-ordinator (SENDCO) who will support staff in implementing our school policy and procedures.
  5. To provide support and advice for all staff working with special educational needs pupils.

Identifying Special Educational Needs

We use a variety of methods to identify SEND. In the 2014 SEN Code of Practice it breaks down SEND into four broad categories of need. These are: Communication and Interaction; Cognition and Learning; Social, Mental and Emotional Health and Sensory and/or Physical. We use these categories to help inform us of the best ways of supporting a child. We use a variety of techniques to help us to identify a child’s Special Educational Needs such as; informal observation and discussion with other members of school staff or professionals, child monitoring tools and screening test and advice from other professionals such as SSSEN or educational psychologists, always thinking about the whole child. Input is sought from parents/carers and children at each stage. We are aware that there are many other variables that can impact on a child’s performance but do not constitute Special Educational Needs and Disabilities.

These can include:

? Attendance and Punctuality

? Health and Welfare

? English as an Additional Language

? Being in receipt of Pupil Premium Grant

? Being a Looked After Child

? Being a child of Serviceman/woman

A Graduated Approach to SEND Support

The attainment of all children at Norbury Church of England Primary School is tracked at least termly basis and this information is scrutinised by class teachers, the Head teacher and SENDCO to ensure that children are making appropriate progress. In addition to this, learning in classrooms is observed and work scrutinised to ensure that children are engaging in lessons appropriately and that teaching meets their needs. Monitoring has shown that, in lessons, teachers differentiate work for pupils of differing abilities and match precise and individualised learning opportunities to the needs of their pupils. Through Pupil Progress meetings, which are held termly, teachers are held to account about the progress of all children, including those children who have Special Educational Needs.

If children appear not to be making satisfactory progress or they are having difficulties accessing the curriculum, support and adjustments will be put in place for a child. For example, this may be; additional focussed work on key areas, 1:1 or in a small group, increased communication with parents, additional TA support during lessons. If after receiving this additional support a child does not make adequate progress we may then identify a child as having Special Educational Needs. When making this decision we consider a range of evidence including assessments, observations and the feelings, opinions and experiences of the child and parents/carers.

If we place a child on the Special Needs Register we will set up an Individual Education Plan (IEP) for the child, outlining their targets and how we will work with the child to achieve these targets. In addition, we will make suggestions about how the child can be supported in working towards these targets at home. An IEP will be reviewed at least three times per year and new targets set after being reviewed, seeking input from the child and parents/carers. We will use a variety of structured tools, such as ‘Good Day/Bad Day’ reviews, to seek input from the children concerned, to ensure that even our youngest children are able to contribute their views.

When a child has a higher level of need we will draw on the expertise of other professionals for their advice on how best to meet a child’s needs. The professionals we work closely with include: Speech and Language Therapists, Educational Psychologists, Paediatricians, Occupational Therapists and Physiotherapists, SSSEN support and MAT team workers, as well as other support services.

Managing Pupils Needs on the SEN Register

Most pupils on the SEN register will have an IEP. IEPs are reviewed in October, February and June and new targets are set. Actions and Objectives must be clear and agreed with the child, their parents and other relevant members of staff, such as SENTAs, TAs or midday supervisors. The IEP will also identify the person/s responsible for completing each action. It is the class teacher’s responsibility to ensure that actions relating to additional provision in school are completed.

Support and interventions will be monitored to ensure that is having an impact on a child’s progress. Progress is tracked diligently throughout the school and we would expect additional interventions to have a positive impact on progress. For children for whom progress is not adequate when an IEP is in place, the support allocated will be analysed by the Headteacher, SENDCO and class teacher to consider which interventions have been most successful. If over time a child doesn’t make adequate progress we may request the support of other professionals to identify how best to meet a child’s needs. Referrals will always be made in consultation with parents/carers and young people. Referrals are approved by the Head teacher. The SENCO manages the involvement of other services.

Criteria for exiting the SEN register

For many children, inclusion on Special Education Needs Register can be short term and with intervention at the appropriate point they will overcome any barriers to learning. At Pupil Progress meetings, which are held three times per year between class teachers and the Head teacher, we discuss the progress of children with SEN and whether their needs have changed. If we feel that the child’s needs are being met within the usual range of classroom differentiation, we will discuss with parents removing them from the Special Needs Register.

Supporting Pupils and Families

At Norbury Church of England Primary School we are committed to working closely with families to ensure that we best meet the needs of children. No pupil will be refused admission to school on the basis of his or her special educational need. In line with the SEN and Disability Act we will not discriminate against disabled children and we will take all reasonable steps to provide effective educational provision. This complies with Derbyshire County Council’s admission policy. For a copy of the school’s admissions policy please see the website or ask at the school office.

Derbyshire County Council produce a Local Offer which contains information about many of the services and resources available to families. This can be accessed through the internet at www.derbyshiresendlocaloffer.org

We also encourage parents to make use of Derbyshire’s Information, Advice and Support Service for SEND, who provide free and impartial advice. Their website can be accessed at http://www.derbyshire.gov.uk/education/schools/special_educational_needs/ and their contact email address is sen.admin@derbyshire.gov.uk .

Norbury Church of England Primary School, produces a SEN Information Report which can be accessed through our school website. The aim of this document is to produce a reader friendly breakdown of the support available for pupils with SEND in our school. It will be reviewed annually, or should any arrangements within the school change.

If a child needs additional support with external tests, such as SATs we apply for special dispensations as a school. This is arranged by the Head Teacher.

At transition points, including starting school and transferring to secondary school, we spend additional time with parents and children with SEND, ensuring that this transition is made as smoothly as possible. This will often include us carrying out extra visits or arranging additional meetings. We work closely with the SENDCO at our local secondary school to ensure support for pupils making this educational journey.

Supporting Pupils at School with Medical Conditions

The school recognises that pupils at school with medical conditions should be enabled to have full access to education, including school trips, Forest School and physical education. Some children with medical conditions may be disabled and where this is the case the school will comply with its duties under the Equality Act 2010.

Some may also have special educational needs (SEN) and may have a statement, or Education, Health and Care (EHC) plan which brings together health and social care needs, as well as their special educational provision. The SEND Code of Practice (2014) is followed at all times. We will work with external agencies, such as medical professionals, the school nurse, MAT team, physical impairment officers and occupational therapists as appropriate. We will seek the opinions of and input from parents/carers and young people to ensure that they are fully included and that their medical needs are being appropriately addressed.

The annual accessibility audit and accessibility plan ensure that our school environment allows for inclusion for pupils with specific medical conditions or SEND.

Monitoring and Evaluation of SEND

Provision for children with SEND is regularly monitored through classroom observations, book scrutiny, and learning walks, and also analysis of results and progress at Pupil Progress meetings. The SEND governor is involved in this process. The views of pupils and parents are saught as part of our person centred approach to the review and target setting process. Findings are also used to inform the school development plan to ensure that there is a continual improvement in provision for all pupils.

Training and Resources

At Norbury Church of England Primary School we are highly committed to ensure the best possible outcomes for all children.

Our excellent staff are our major resource for the learning and progress of our children.

We employ skilled teachers and teaching assistants who work together to deliver quality outcomes for our children. Children who are not making sufficient progress, or are having social, emotional and behavioural difficulties, will be allocated individualised support by their class teacher, with the support of the SENDO and Head teacher. Children with statements or Educational Health Care Plans have additionally allocated hours of Teaching Assistant support, to ensure that they make good progress towards their targets. We ensure that staff are trained in new initiatives relevant to SEND, such as the new code of practice or approaches to intervention. We aim to ensure that we pre-empt the training needs of staff in relation to specific pupils, for example, ensuring that all staff who will be working with a pupil with ASD have appropriate training before transition into a new class. In addition, staff are encouraged to identify their own training needs, relevant to the learning needs of their class. We ensure that staff have time to learn and build skills from the expertise of other staff members, by allowing time during staff meetings to consider strategies for working with specific pupils; information sharing between teaching professionals within our own school to make the most of our extensive experience and previous specialist training.

Roles and Responsibilities

Our SEND governor is Jessica Batterby, and she meets regularly with the SENDCO, Sally Wright, to keep abreast of current developments. To gain an understanding of how Special Needs provision is delivered, she is involved in learning walks where appropriate, and monitors data as part of the governors monitoring cycle, to ensure that children with SEND are making sufficient progress.

Special Educational Needs Teaching Assistants are deployed by classroom teachers, with support from the SENDCO. They work in support of individual children, providing feedback on individual tasks completed to the class teacher. The class teacher is responsible for the review of IEP’s with input from parents/carers, pupils and other agencies where appropriate. The SENDCO will work to support teachers where needed.

The SENDCO, Sally Wright, will organise annual statement review and implementation meetings or reviews of Educational Health Care Plans, using a person centred approach to the review to ensure that the children concerned feel at the heart of the process.

The SENDCO will liaise with external agencies to identify support for children on the SEN register where appropriate.

The SENDCO will keep updated on educational reforms and current practises relating to Special Educational Needs and Disabilities, and will share this information with staff.

The Deputy Head teacher, Sally Wright, is the designated teacher with safeguarding responsibility (DSL – Designated Safeguarding Leader).

Update 04/12/19

 

Accessibility Policy

This policy complies with the statutory requirement laid out in the SEND Code of Practice 0-25 (June 2014) 3.65 and has been written with reference to the following guidance and documents;

  • Equality Act 2010: Advice for Schools DfE February 2013
  • SEND Code of practice 0-25 (June 2014)
  • Schools SEN Information Report Regulations (2014)
  • Statutory Guidance on Supporting Pupils at School with Medical Conditions
  • The National Curriculum in England Key Stage 1 and 2 Framework Document September 2013
  • Safeguarding Policy
  • Accessibility Plan
  • Teacher’s Standards 2012
  • Positive Behaviour Management Policy
  • Anti-Bullying Policy
  • Equal Opportunities PolicyInformationThis policy was written in consultation with stakeholders including children, parents, staff and governors. The day to day implementation of this policy is led by our Special Educational Needs Co-ordinator Sally Wright. It is the responsibility of the Headteacher, Rebecca Chapman, to ensure that it is implemented. Sally and Rebecca can be contacted at school on 01335 324337 or at info@norbury.derbyshire.sch.uk. The governor with responsibility for Special Educational Needs is Kate Fitzpatrick. Kate can also be contacted through school on the above number or email.Our SEND policy reflects the SEND Code of Practice 2014, 0-25 guidance. It has been shared with the school’s governing body and will be reviewed regularly.A SEND Information Report will be shared with parents, carers and the governing body and published on the school’s website. This will be updated as a result of any changes to arrangements, such as staffing or CPD or annually as required. Parents, carers and children will be invited to contribute to the SEND Information Report.“Every Teacher is a Teacher of Every Child”Every teacher is a teacher of every child or young person, including those with SEND. As such ‘Norbury Church of England Primary School’ adopts a ‘whole school approach’ to special educational needs, which involves all staff adhering to a model of good practice. The staff of the school are committed to identifying and providing for the needs of all children in a wholly inclusive environment.

 

Aims and Objectives of this Policy

At Norbury Church of England Primary School we work hard to ensure every child achieves their full potential, and encourage all children to have high aspirations. When working with children with SEND (Special Educational Needs and Disabilities) we are focussed on supporting children to achieve their very best possible outcomes.

This policy supports us in meeting the following objectives;

  1. To identify and provide for pupils who have special educational needs and additional needs .
  2. To work within the guidance provide in the SEND Code of Practice, 2014.
  3. To operate a “whole pupil, whole school” approach to the management and provision of support for special educational needs.
  4. To identify a Special Educational Needs and Disability Co-ordinator (SENDCO) who will support staff in implementing our school policy and procedures.
  5. To provide support and advice for all staff working with special educational needs pupils.

Identifying Special Educational Needs

We use a variety of methods to identify SEND. In the 2014 SEN Code of Practice it breaks down SEND into four broad categories of need. These are: Communication and Interaction; Cognition and Learning; Social, Mental and Emotional Health and Sensory and/or Physical. We use these categories to help inform us of the best ways of supporting a child. We use a variety of techniques to help us to identify a child’s Special Educational Needs such as; informal observation and discussion with other members of school staff or professionals, child monitoring tools and screening test and advice from other professionals such as SSSEN or educational psychologists, always thinking about the whole child. Input is sought from parents/carers and children at each stage. We are aware that there are many other variables that can impact on a child’s performance but do not constitute Special Educational Needs and Disabilities.

These can include:

? Attendance and Punctuality

? Health and Welfare

? English as an Additional Language

? Being in receipt of Pupil Premium Grant

? Being a Looked After Child

? Being a child of Serviceman/woman

A Graduated Approach to SEND Support

The attainment of all children at Norbury Church of England Primary School is tracked at least termly basis and this information is scrutinised by class teachers, the Head teacher and SENDCO to ensure that children are making appropriate progress. In addition to this, learning in classrooms is observed and work scrutinised to ensure that children are engaging in lessons appropriately and that teaching meets their needs. Monitoring has shown that, in lessons, teachers differentiate work for pupils of differing abilities and match precise and individualised learning opportunities to the needs of their pupils. Through Pupil Progress meetings, which are held termly, teachers are held to account about the progress of all children, including those children who have Special Educational Needs.

If children appear not to be making satisfactory progress or they are having difficulties accessing the curriculum, support and adjustments will be put in place for a child. For example, this may be; additional focussed work on key areas, 1:1 or in a small group, increased communication with parents, additional TA support during lessons. If after receiving this additional support a child does not make adequate progress we may then identify a child as having Special Educational Needs. When making this decision we consider a range of evidence including assessments, observations and the feelings, opinions and experiences of the child and parents/carers.

If we place a child on the Special Needs Register we will set up an Individual Education Plan (IEP) for the child, outlining their targets and how we will work with the child to achieve these targets. In addition, we will make suggestions about how the child can be supported in working towards these targets at home. An IEP will be reviewed at least three times per year and new targets set after being reviewed, seeking input from the child and parents/carers. We will use a variety of structured tools, such as ‘Good Day/Bad Day’ reviews, to seek input from the children concerned, to ensure that even our youngest children are able to contribute their views.

When a child has a higher level of need we will draw on the expertise of other professionals for their advice on how best to meet a child’s needs. The professionals we work closely with include: Speech and Language Therapists, Educational Psychologists, Paediatricians, Occupational Therapists and Physiotherapists, SSSEN support and MAT team workers, as well as other support services.

Managing Pupils Needs on the SEN Register

Most pupils on the SEN register will have an IEP. IEPs are reviewed in October, February and June and new targets are set. Actions and Objectives must be clear and agreed with the child, their parents and other relevant members of staff, such as SENTAs, TAs or midday supervisors. The IEP will also identify the person/s responsible for completing each action. It is the class teacher’s responsibility to ensure that actions relating to additional provision in school are completed.

Support and interventions will be monitored to ensure that is having an impact on a child’s progress. Progress is tracked diligently throughout the school and we would expect additional interventions to have a positive impact on progress. For children for whom progress is not adequate when an IEP is in place, the support allocated will be analysed by the Headteacher, SENDCO and class teacher to consider which interventions have been most successful. If over time a child doesn’t make adequate progress we may request the support of other professionals to identify how best to meet a child’s needs. Referrals will always be made in consultation with parents/carers and young people. Referrals are approved by the Head teacher. The SENCO manages the involvement of other services.

Criteria for exiting the SEN register

For many children, inclusion on Special Education Needs Register can be short term and with intervention at the appropriate point they will overcome any barriers to learning. At Pupil Progress meetings, which are held three times per year between class teachers and the Head teacher, we discuss the progress of children with SEN and whether their needs have changed. If we feel that the child’s needs are being met within the usual range of classroom differentiation, we will discuss with parents removing them from the Special Needs Register.

Supporting Pupils and Families

At Norbury Church of England Primary School we are committed to working closely with families to ensure that we best meet the needs of children. No pupil will be refused admission to school on the basis of his or her special educational need. In line with the SEN and Disability Act we will not discriminate against disabled children and we will take all reasonable steps to provide effective educational provision. This complies with Derbyshire County Council’s admission policy. For a copy of the school’s admissions policy please see the website or ask at the school office.

Derbyshire County Council produce a Local Offer which contains information about many of the services and resources available to families. This can be accessed through the internet at www.derbyshiresendlocaloffer.org

We also encourage parents to make use of Derbyshire’s Information, Advice and Support Service for SEND, who provide free and impartial advice. Their website can be accessed at http://www.derbyshire.gov.uk/education/schools/special_educational_needs/ and their contact email address is sen.admin@derbyshire.gov.uk .

Norbury Church of England Primary School, produces a SEN Information Report which can be accessed through our school website. The aim of this document is to produce a reader friendly breakdown of the support available for pupils with SEND in our school. It will be reviewed annually, or should any arrangements within the school change.

If a child needs additional support with external tests, such as SATs we apply for special dispensations as a school. This is arranged by the Head Teacher.

At transition points, including starting school and transferring to secondary school, we spend additional time with parents and children with SEND, ensuring that this transition is made as smoothly as possible. This will often include us carrying out extra visits or arranging additional meetings. We work closely with the SENDCO at our local secondary school to ensure support for pupils making this educational journey.

Supporting Pupils at School with Medical Conditions

The school recognises that pupils at school with medical conditions should be enabled to have full access to education, including school trips, Forest School and physical education. Some children with medical conditions may be disabled and where this is the case the school will comply with its duties under the Equality Act 2010.

Some may also have special educational needs (SEN) and may have a statement, or Education, Health and Care (EHC) plan which brings together health and social care needs, as well as their special educational provision. The SEND Code of Practice (2014) is followed at all times. We will work with external agencies, such as medical professionals, the school nurse, MAT team, physical impairment officers and occupational therapists as appropriate. We will seek the opinions of and input from parents/carers and young people to ensure that they are fully included and that their medical needs are being appropriately addressed.

The annual accessibility audit and accessibility plan ensure that our school environment allows for inclusion for pupils with specific medical conditions or SEND.

Monitoring and Evaluation of SEND

Provision for children with SEND is regularly monitored through classroom observations, book scrutiny, and learning walks, and also analysis of results and progress at Pupil Progress meetings. The SEND governor is involved in this process. The views of pupils and parents are saught as part of our person centred approach to the review and target setting process. Findings are also used to inform the school development plan to ensure that there is a continual improvement in provision for all pupils.

Training and Resources

At Norbury Church of England Primary School we are highly committed to ensure the best possible outcomes for all children.

Our excellent staff are our major resource for the learning and progress of our children.

We employ skilled teachers and teaching assistants who work together to deliver quality outcomes for our children. Children who are not making sufficient progress, or are having social, emotional and behavioural difficulties, will be allocated individualised support by their class teacher, with the support of the SENDO and Head teacher. Children with statements or Educational Health Care Plans have additionally allocated hours of Teaching Assistant support, to ensure that they make good progress towards their targets. We ensure that staff are trained in new initiatives relevant to SEND, such as the new code of practice or approaches to intervention. We aim to ensure that we pre-empt the training needs of staff in relation to specific pupils, for example, ensuring that all staff who will be working with a pupil with ASD have appropriate training before transition into a new class. In addition, staff are encouraged to identify their own training needs, relevant to the learning needs of their class. We ensure that staff have time to learn and build skills from the expertise of other staff members, by allowing time during staff meetings to consider strategies for working with specific pupils; information sharing between teaching professionals within our own school to make the most of our extensive experience and previous specialist training.

Roles and Responsibilities

Our SEND governor is Jessica Batterby, and she meets regularly with the SENDCO, Sally Wright, to keep abreast of current developments. To gain an understanding of how Special Needs provision is delivered, she is involved in learning walks where appropriate, and monitors data as part of the governors monitoring cycle, to ensure that children with SEND are making sufficient progress.

Special Educational Needs Teaching Assistants are deployed by classroom teachers, with support from the SENDCO. They work in support of individual children, providing feedback on individual tasks completed to the class teacher. The class teacher is responsible for the review of IEP’s with input from parents/carers, pupils and other agencies where appropriate. The SENDCO will work to support teachers where needed.

The SENDCO, Sally Wright, will organise annual statement review and implementation meetings or reviews of Educational Health Care Plans, using a person centred approach to the review to ensure that the children concerned feel at the heart of the process.

The SENDCO will liaise with external agencies to identify support for children on the SEN register where appropriate.

The SENDCO will keep updated on educational reforms and current practises relating to Special Educational Needs and Disabilities, and will share this information with staff.

The Deputy Head teacher, Sally Wright, is the designated teacher with safeguarding responsibility (DSL – Designated Safeguarding Leader).

Update 04/12/19

 

Equality Policy

Why we have developed this Equality Policy

This Equality Policy for Norbury CE Primary School includes all the protected characteristics covered under the Equality Act 2010 as well as other aspects which have the potential to discriminate against or to devalue any individuals within our community.  We are further committed to the development of cohesive communities both within our school’s physical boundaries and within our local, national and global environments.  Our school embraces the aim of working together with others to improve children’s educational and wellbeing outcomes, and notes the rights set out in the UN Convention on the Rights of the Child.

The purpose of this Policy is to set out how our practice and policies have due regard to the need to:

– eliminate discrimination, harassment and victimisation;

– advance equality of opportunity and

– foster good relations between groups.

It explains how we aim to listen to pupils, staff, parents and the
community in achieving better outcomes for our children and young people.

Our school within the wider context

The national demographic presents an ever-changing picture in terms of age,
ethnicity, disability and social deprivation.

March 2018 data shows:

  • 100% of the school population ascribe themselves as White British.
  • 0% of the school are non-white.
  • The home language is English in 100% of homes.
  • 8.5% of the school are eligible for free school meals.
  • There are currently NO children looked after by the local authority.
  • 3% of students are supported by School Action Plus or EHCP.
  • 50% of students are female and 50% are male.

Overall aims of our Equality Policy

  • To eliminate discrimination, harassment and victimisation.
  • To promote equality of access and opportunity within our school and within our wider community.
  • To promote positive attitudes to difference and good relationships between people with different backgrounds, genders, cultures, faiths, abilities and ethnic origins.

To ensure that equality and inclusive practice are embedded across all aspects of

school life the Equality Policy refers to the UN Convention on the Rights of the Child,
which includes recognition of a range of educational, wellbeing, and material
outcomes.

Our approach

We seek to embed equality of access, opportunity and outcome for all members of our school community, within all aspects of school life.

We actively seek out opportunities to embrace the following key concepts:

  • Shared Humanity. Identifying commonality and shared values, aspirations and

needs underpins our approach to equality.  We value our fundamental similarities and universality

  • Valuing difference and diversity. We appreciate the richness within our

differences and look for ways of celebrating and understanding them better

  • Interdependence, interaction and influence. We recognise that, as they evolve, distinct cultures, beliefs and lifestyles will impact on and inform each other
  • Social cohesion within our school and within our local community
  • Excellence. We aim to inspire and recognise high personal and collective

achievement throughout our community, the UK and the wider world.

  • Personal and cultural identity. We will provide opportunities to explore and value the complexity of our personal and cultural identities
  • Fairness and social justice. We will develop our understanding of the inequality

that exists in society and explore ways of individually and collectively promoting a more equitable society

Our vision statement about Equality

Norbury CE Primary School seeks to foster warm, welcoming and respectful environments, which allow us to question and challenge discrimination and inequality, resolve conflicts peacefully and work and learn free from harassment and violence.

We recognise that there are similarities and differences between individuals and groups but we will strive to ensure that our differences do not become barriers to participation, access and learning and to create inclusive processes and practices,
where the varying needs of individuals and groups are identified and met. We therefore cannot achieve equality for all by treating everyone the same.

We will build on our similarities and seek enrichment from our differences and so promote understanding and learning between and towards others to create cohesive communities.

Our duties

We recognise and accept our equality duties as set out in the Equality Act 2010 and have sought to involve the whole school community in the process in order to ensure better outcomes for all.

They are also guided by the United Nations Convention on the Rights of the Child.

We will ensure we identify opportunities for promoting our vision, the key

concepts and our duties on equality legislation across all aspects of school life, including the provision of extended services.

These opportunities are likely to include all or some of the following, dependent on our current priorities.

  • learning and teaching and the planned curriculum
  • the engagement, participation and involvement of a broad and diverse range of children, young people, their parents and partner agencies
  • preparation for entry to the school
  • school policies
  • breaks and lunchtimes
  • the provision of school meals
  • interaction with peers
  • opportunities for assessment and accreditation
  • exam arrangements
  • behaviour management approach and sanctions
  • exclusion procedures
  • school clubs, activities and school trips
  • the school’s arrangements for working with other agencies
  • preparation of pupils for the next phase of education
  • classroom organisation
  • timetabling
  • grouping of pupils
  • homework
  • access to school facilities
  • activities to enrich the curriculum
  • school sports
  • employees’ and staff welfare.

The roles and responsibilities within our school community

Our Headteacher will:

  • ensure that staff, parents/carers and pupils/students are informed about the Equality Policy
  • oversee the effective implementation of the policy
  • ensure staff have access to training which helps to implement the policy
  • develop partnerships with external agencies regarding the policy so that the school’s actions are in line with the best advice available
  • monitor the policy and report to the Governing Body on the effectiveness of the policy
  • ensure that the senior leadership team (SLT) is kept up to date with any development affecting the policy or actions arising from it.

Our governing body will:

  • designate a governor with specific responsibility for the Equality Policy
  • ensure that any action plans are monitored through a relevant sub-committee
  • support the headteacher in implementing any actions necessary
  • engage with parents and partner agencies about the policy
  • evaluate and review the policy.

Our Senior Leadership Team will:

  • have responsibility for supporting other staff in implementing this policy
  • provide a lead in the dissemination of information relating to the policy
  • with the Headteacher, provide advice/support in dealing with any incidents/issues
  • assist in implementing reviews of this policy.

Our pupils/students will:

  • understand how the policy relates to them, appropriate to age and ability
  • be expected to act in accordance with the policy.

Our parents/carers will:

  • have access to the policy through a range of different media appropriate to their requirements
  • be encouraged to actively support the policy
  • be encouraged to attend any relevant meetings and activities related to the policy
  • be informed of any incident related to this policy which could directly affect their

Our school staff will:

  • be involved in the on-going development of the policy
  • be fully aware of the Equality Policy and how it relates to them
  • understand that this is a whole school issue and support the Equality Policy
  • make known any queries or training requirements.

Our Staff

We comply fully with legislation which protects our staff (including teachers, teaching assistants, supervisors and student teachers) from discrimination based on the protected characteristics.  With regard to disability, we make reasonable adjustments as necessary to prevent a disabled person being at a substantial disadvantage in comparison with people who are not disabled.

This includes discrimination in relation to recruitment, terms and conditions,

promotions, transfers, dismissals, training and employment practices (such as dress codes) and disciplinary procedures.

We make efforts to ensure that the diversity of our workforce reflects that of our local community and wider society. In accordance
with the Equality Act we do not enquire about the health of an applicant until a job
offer has been made or require job applicants to complete a generic ‘all encompassing’ health questionnaire as part of the application procedure.

We will ensure the safety and well-being of our staff and take seriously and act on incidents of harassment and discrimination recognising that our staff may be either victims or perpetrators.

There are some specific exceptions to the religion or belief provisions of the Equality

Act for employment by schools designated as having a religious character. See

Department of Education website for further guidance on this:

http://www.education.gov.uk/aboutdfe/policiesandprocedures/equalityanddiversity/a0064570/the-equality-act-2010

We interpret our duties positively and take the necessary actions to remove barriers
to inclusion and work hard to ensure a safe, positive and inclusive environment. An
example of this would be that we have made substantial modification of the school
building in order to provide for profoundly visually and hearing impaired students.

Responding to hate or prejudice-based incidents and bullying

We recognise that hate incidents or prejudice -based bullying behaviour is driven by negative assumptions, stereotypes or misinformation. These are then directed
against an individual or group, based on difference (real or perceived), and linked to, for example, racism, homophobia, negative views of disabled people or sexism.  We will take action to prevent, challenge and eliminate any such behaviour.

We recognise that we as individuals and society often struggle with difference of any kind (perceived or actual), which can result in seizing upon the most visible sign of difference e.g. skin colour or disability.

Through our school ethos and curriculum, we want our pupils/students to understand better the diversity that exists in society. We want to provide opportunities for them to explore the subtleties and complexities in order to prevent and respond to incidents
and situations. We will address the experience, understanding and needs of the
victim, the perpetrator, bystanders and the wider school community through our
actions and responses.

We will record all hate incidents and prejudice based bullying. We will use this

information to identify trends and patterns, so that we have approaches in place to provide appropriate responses in terms of support for victims and their families, sanctions and support for perpetrators and their families and education for our children, young people and communities.

We expect students and staff alike to take an active stand against all forms of discrimination and always to report it:

  • To any teacher
  • To the form tutor
  • To a member of the senior leadership team
  • To a line manager
  • To a school prefect

All incidents of a racial nature are logged and dealt with as they occur and reported to the LA.  Regular monitoring of bullying takes place and our school bullying policy.

Implementation, monitoring and reviewing

This policy was published in March 2018.  It will be actively promoted and disseminated throughout the school community.

Implementation, monitoring and review are the responsibility of our Senior

Leadership Team and our governors who have agreed and published this policy which sets out our priorities and supports these with specific and measurable objectives.

We will review annually on the policy and analyse whether our policy and related objectives have furthered the aims of the general equality duty and in particular educational outcomes for all within our school community with reference to the protected group.

Safeguarding

Safeguarding our children is of paramount importance and underpins all of the work at our school. All children have the right to feel safe at our school and we work hard to ensure that this is the case. This policy should be read in conjunction with the school Child Protection and Safeguarding Policy.

Updated 04/12/19

 

Code of Conduct for visitors 

Code of Conduct for Parents, Carers & Visitors Policy

Introduction
We are very fortunate to have a supportive and friendly parent body who contribute greatly to the supportive atmosphere of our school. Our parents recognise that educating children is a process that involves partnership between parents, class teachers and the school community. As a partnership, our parents/carers will understand the importance of a good working relationship to equip children with the necessary skills for adulthood. For these reasons we continue to welcome and encourage parents/carers to participate fully in the life of our school.

Purpose
The purpose of this policy is to provide a reminder to all parents, carers and visitors to our school about the expected conduct. This is so that we can continue to flourish, progress and achieve in an atmosphere of mutual understanding. This code of conduct is applicable to parents/carers and visitors at all times whilst they are on school premises.

Guidance
We expect parents, carers and visitors to:
• Respect the caring ethos and values of our school.
• Ensure that pupils attend school regularly and are dropped off and collected promptly, according to the start and end times of the school day. Late arrivals are disruptive for the rest of the class and result in lost learning time. Late collection impacts on teachers marking, planning and preparation time at the end of the day and can be upsetting for pupils.
• Understand that both teachers and parents need to work together for the benefit of their children.
• Demonstrate that all members of the school community should be treated with respect and therefore set a good example in their own speech and behaviour.
• Seek to clarify a child’s version of events with the school’s view in order to bring about a peaceful solution to any issue.
• Correct their own child’s behaviour, especially in public where it could otherwise lead to conflict, aggressive behaviour or unsafe behaviour.
• Approach the school to help resolve any issues of concern.
• Avoid using staff as threats to admonish children’s behaviour.
In order to support a peaceful and safe school environment the school expects that parents/carers and visitors refrain from the following:
• Disruptive behaviour which interferes or threatens to interfere with the operation of a classroom, an employee’s office, office area or any other area of the school grounds including team matches.
• Using loud/or offensive language, swearing, cursing, using profane language or displaying temper.
• Threatening to do actual bodily harm to a member of school staff, Governor, visitor, fellow parent/carer or student regardless of whether or not the behaviour constitutes a criminal offence.
• Damaging or destroying school property.
• Abusive or threatening e-mails or text/voicemail/phone messages or other written communication.
• Defamatory, offensive or derogatory comments regarding the school or any of the students/parent/staff, at the school on Facebook or other social sites. (See Appendix 1). Any concerns you may have about the school must be made through the appropriate channels by speaking to the class teacher in the first instance. Further concerns may then be pursued with the, Head teacher or the Chair of Governors, so they can be dealt with fairly, appropriately and effectively for all concerned.
• The use of physical aggression towards another adult or child.
• Approaching someone else’s child in order to discuss or chastise them. (Such an approach to a child may be seen to be an assault on that child and may have legal consequences). Any concerns about pupil behaviour should be reported to a member of school staff.
• Smoking and consumption of alcohol or other drugs whilst on school property.
• Dogs being brought on to school premises, other than by prior arrangement for educational purposes.
• Posting images of other people’s children on social media sites.

Should any of the above behaviour occur on school premises the school may feel it is necessary to contact the appropriate authorities and if necessary, even ban the offending adult from entering the school grounds.

We trust that parents and carers will assist our school with the implementation of this policy and we thank you for your continuing support of the school.

Appendix 1: Inappropriate use of Social Network Sites
Social media websites are being used increasingly to fuel campaigns and complaints against schools, Headteachers, school staff, and in some cases other parents/students. The Governors considers the use of social media websites being used in this way as unacceptable and not in the best interests of the children or the whole school community. Any concerns you may have must be made through the appropriate channels by speaking to the class teacher, the Headteacher or the Chair of Governors, so they can be dealt with fairly, appropriately and effectively for all concerned.

In the event that any student or parent/carer of a child/ren being educated in the school is found to be posting libellous or defamatory comments on Facebook or other social network sites, they will be reported to the appropriate ‘report abuse’ section of the network site. All social network sites have clear rules about the content, which can be posted, on the site and they provide robust mechanisms to report contact or activity which breaches this. The school will also expect that any parent/carer or student removes such comments immediately.

In serious cases the school will also consider its legal options to deal with any such misuse of social networking and other sites. Additionally, and perhaps more importantly is the issue of cyber bullying and the use by one child or a parent to publicly humiliate another by inappropriate social network entry. We will take and deal with this as a serious incident of school bullying. Thankfully such incidents are extremely rare.
We would expect that parents would make all persons responsible for collecting children aware of this policy.

 

Data Breach Procedure

Norbury CE Primary School

GDPR and Data Protection Policy

 General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) is the law that protects personal privacy and upholds individual’s rights. It applies to anyone who handles or has access to people’s personal data.

 This policy is intended to ensure that personal information is dealt with properly and securely and in accordance with the legislation. It will apply to personal information regardless of the way it is used, recorded and stored and whether it is held in paper files or electronically.

Policy Objectives

The school as the Data Controller will comply with its obligations under the GDPR and DPA. The school is committed to being concise, clear and transparent about how it obtains and uses personal information and will ensure data subjects are aware of their rights under the legislation.

All staff must have a general understanding of the law and understand how it may affect their decisions in order to make an informed judgement about how information is gathered, used and ultimately deleted.  All staff must read, understand and comply with this policy.

The Information Commissioner as the Regulator can impose fines of up to 20 million Euros (approximately £17 million) for serious breaches of the GDPR, therefore it is imperative that the School and all staff comply with the legislation.

Scope of the Policy

Personal data is any information that relates to an identified or identifiable living individual who can be identified directly or indirectly from the information[1].  The information includes factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a living individual.  This includes any expression of opinion about an individual and intentions towards an individual.  Under the GDPR personal information also includes an identifier such as a name, an identification number, location data or an online identifier.

The School collects a large amount of personal data every year including: pupil records, staff records, names and addresses of those requesting prospectuses, examination marks, references, fee collection as well as the many different types of research data used by the School.  In addition, it may be required by law to collect and use certain types of information to comply with statutory obligations of Local Authorities (LAs), government agencies and other bodies.

The Principles

The principles set out in the GDPR must be adhered to when processing personal data:

  1. Personal data must be processed lawfully, fairly and in a transparent manner (lawfulness, fairness and transparency)
  2. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation)
  3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose(s) for which they are processed (data minimisation)
  4. Personal data shall be accurate and where necessary kept up to date and every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay (accuracy).
  5. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purpose for which the personal data is processed (storage limitation)
  6. Appropriate technical and organisational measures shall be taken to safeguard the rights and freedoms of the data subject and to ensure that personal information are processed in a manner that ensures appropriate security of the personal data and protects against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data (integrity and confidentiality).

Transfer Limitation

In addition, personal data shall not be transferred to a country outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission or where the organisation receiving the data has provided adequate safeguards[2].

This means that individuals’ rights must be enforceable and effective legal remedies for individuals must be available following the transfer.  It may also be possible to transfer data where the data subject has provided explicit consent or for other limited reasons.  Staff should contact the DPO if they require further assistance with a proposed transfer of personal data outside of the EEA.

Lawful Basis for processing personal information

Before any processing activity starts for the first time, and then regularly afterwards, the purpose(s) for the processing activity and the most appropriate lawful basis (or bases) for that processing must be selected:

  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the school
  • Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract
  • Processing is necessary for compliance with a legal obligation to which the data controller is subject
  • Processing is necessary in order to protect the vital interests of the data subject or of another natural person
  • Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party[3]
  • The data subject has given consent to the processing of his or her data for one or more specific purposes. Agreement must be indicated clearly either by a statement or positive action to the processing.  Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient.  If consent is given in a document which deals with other matters, the consent from be kept separate from those other matters

Data subjects must be easily able to withdraw consent to processing at any time and withdrawal must be promptly honoured.  Consent may need to be refreshed if personal data is intended to be processed for a different and incompatible purpose which was not disclosed when the data subject first consented.

The decision as to which lawful basis applies must be documented, to demonstrate compliance with the data protection principles and include information about both the purposes of the processing and the lawful basis for it in the school’s relevant privacy notice(s).

When determining whether legitimate interests are the most appropriate basis for lawful processing (only where appropriate outside the school’s public tasks) a legitimate interest assessment must be carried out and recorded.  Where a significant privacy impact is identified, a data protection impact assessment (DPIA) may also need to be conducted.

Sensitive Personal Information

Processing of sensitive personal information (known as ‘special categories of personal data’) is prohibited[4] unless a lawful special condition for processing is identified.

Sensitive personal information is data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or orientation or is genetic or biometric data which uniquely identifies a natural person.

Sensitive personal information will only be processed if:

  • There is a lawful basis for doing so as identified on previous page
  • One of the special conditions for processing sensitive personal information applies:
  • the individual (‘data subject’) has given explicit consent (which has been clearly explained in a Privacy Notice)
  • the processing is necessary for the purposes of exercising the employment law rights or obligations of the school or the data subject
  • the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent
  • the processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade-union aim
  • the processing relates to personal data which are manifestly made public by the data subject
  • the processing is necessary for the establishment, exercise or defence of legal claims
  • the processing is necessary for reasons of substantial public interest
  • the processing is necessary for purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, the provision of social care and the management of social care systems or services
  • the processing is necessary for reasons of public interest in the area of public health

The school’s privacy notice(s) set out the types of sensitive personal information that it processes, what it is used for, the lawful basis for the processing and the special condition that applies.

Sensitive personal information will not be processed until an assessment has been made of the proposed processing as to whether it complies with the criteria above and the individual has been informed (by way of a privacy notice or consent) of the nature of the processing, the purposes for which it is being carried out and the legal basis for it.

Unless the School can rely on another legal basis of processing, explicit consent is usually required for processing sensitive personal data.  Evidence of consent will need to be captured and recorded so that the school can demonstrate compliance with the GDPR.

Automated Decision Making

Where the school carries out automated decision making (including profiling) it must meet all the principles and have a lawful basis for the processing. Explicit consent will usually be required for automated decision making (unless it is authorised by law or it is necessary for the performance of or entering into a contract).

Additional safeguards and restrictions apply in the case of solely automated decision-making, including profiling.  The School must as soon as reasonably possible notify the data subject in writing that a decision has been taken based on solely automated processing and that the data subject may request the school to reconsider or take a new decision.  If such a request is received staff must contact the DPO as the school must reply within 21 days.

Data Protection Impact Assessments (DPIA)

All data controllers are required to implement ‘Privacy by Design’ when processing personal data.

This means the School’s processes must embed privacy considerations and incorporate appropriate technical and organisational measures (like pseudonymisation) in an effective manner to ensure compliance with data privacy principles.

Where processing is likely to result in high risk to an individual’s data protection rights (for example where a new technology is being implemented) a DPIA must be carried out to assess:

  • whether the processing is necessary and proportionate in relation to its purpose
  • the risks to individuals
  • what measures can be put in place to address those risks and protect personal information

Staff should adhere to the Data Protection Toolkit for Schools from the DfE with reference to the DPIA template.

When carrying out a DPIA, staff should seek the advice of the DPO for support and guidance and once complete, refer the finalised document to the DPO for sign off.

Documentation and records

Written records of processing activities must be kept and recorded including:

  • the name(s) and details of individuals or roles that carry out the processing
  • the purposes of the processing
  • a description of the categories of individuals and categories of personal data
  • categories of recipients of personal data
  • details of transfers to third countries, including documentation of the transfer mechanism safeguards in place
  • retention schedules
  • a description of technical and organisational security measures

As part of the School’s record of processing activities the DPO will document, or link to documentation on:

  • information required for privacy notices
  • records of consent
  • controller-processor contracts
  • the location of personal information;
  • DPIAs and
  • Records of data breaches.

Records of processing of sensitive information are kept on:

  • The relevant purposes for which the processing takes place, including why it is necessary for that purpose
  • The lawful basis for our processing and
  • Whether the personal information is retained or erased in accordance with the Retention Schedule and, if not, the reasons for not following the policy.

The School should conduct regular reviews of the personal information it processes and update its documentation accordingly.  This may include:

  • Carrying out information audits to find out what personal information is held
  • Talking to staff about their processing activities
  • Reviewing policies, procedures, contracts and agreements to address retention, security and data sharing.

Privacy Notice

The school will issue privacy notices as required, informing data subjects (or their parents, depending on age of the pupil, if about pupil information) about the personal information that it collects and holds relating to individual data subjects, how individuals can expect their personal information to be used and for what purposes.

 

When information is collected directly from data subjects, including for HR or employment purposes, the data subject shall be given all the information required by the GDPR including the identity of the data controller and the DPO, how and why the School will use, process, disclose, protect and retain that personal data through a privacy notice (which must be presented when the data subject first provides the data).

When information is collected indirectly (for example from a third party or publicly available source) the data subject must be provided with all the information required by the GDPR as soon as possible after collecting or receiving the data.  The school must also check that the data was collected by the third party in accordance with the GDPR and on a basis which is consistent with the proposed processing of the personal data.

The School will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

The School will issue a minimum of two privacy notices, one for pupil information, and one for workforce information, and these will be reviewed in line with any statutory or contractual changes.

Purpose Limitation

Personal data must be collected only for specified, explicit and legitimate purposes.  It must not be further processed in any manner incompatible with those purposes.

Personal data must not be used for new, different or incompatible purposes from that disclosed when it was first obtained unless the data subject has been informed of the new purposes and they have consented where necessary.

Data minimisation

Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Staff may only process data when their role requires it.  Staff must not process personal data for any reason unrelated to their role.

The School maintains a Retention Schedule to ensure personal data is deleted after a reasonable time for the purpose for which it was being held, unless a law requires such data to be kept for a minimum time.  Staff must take all reasonable steps to destroy or delete all personal data that is held in its systems when it is no longer required in accordance with the Schedule.  This includes requiring third parties to delete such data where applicable.

Staff must ensure that data subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

Individual Rights

Staff as well as any other ‘data subjects’ have the following rights in relation to their personal information:

  • To be informed about how, why and on what basis that information is processed (see the relevant privacy notice)
  • To obtain confirmation that personal information is being processed and to obtain access to it and certain other information, by making a subject access request

Individual Responsibilities

During their employment, staff may have access to the personal information of other members of staff, suppliers, clients or the public.  The school expects staff to help meet its data protection obligations to those individuals.

If you have access to personal information, you must:

  • only access the personal information that you have authority to access and only for authorised purposes
  • only allow other staff to access personal information if they have appropriate authorisation
  • only allow individuals who are not school staff to access personal information if you have specific authority to do so
  • keep personal information secure (e.g. by complying with rules on access to premises, computer access, password protection and secure file storage and destruction in accordance with the school’s policies)
  • not remove personal information, or devices containing personal information (or which can be used to access it) from the school’s premises unless appropriate security measures are in place (such as pseudonymisation, encryption or password protection) to secure the information and the device
  • not store personal information on local drives or on personal devices that are used for work purposes

Information Security

The school will use appropriate technical and organisational measures to keep personal information secure, to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

All staff are responsible for keeping information secure in accordance with the legislation and must follow their school’s acceptable usage policy.

The school will develop, implement and maintain safeguards appropriate to its size, scope and business, its available resources, the amount of personal data that it owns or maintains on behalf of others and identified risks (including use of encryption and pseudonymisation where applicable). It will regularly evaluate and test the effectiveness of those safeguards to ensure security of processing.

Staff must guard against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data. Staff must exercise particular care in protecting sensitive personal data from loss and unauthorised access, use or disclosure.

Staff must follow all procedures and technologies put in place to maintain the security of all personal data from the point of collection to the point of destruction. Staff may only transfer personal data to third-party service providers who agree in writing to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

Staff must maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

Confidentiality means that only people who have a need to know and are authorised to use the personal data can access it.

Integrity means that personal data is accurate and suitable for the purpose for which it is processed.

Availability means that authorised users can access the personal data when they need it for authorised purposes.

Staff must comply with and not attempt to circumvent the administrative, physical and technical safeguards the school has implemented and maintains in accordance with the GDPR and DPA.

Where the school uses external organisations to process personal information on its behalf, additional security arrangements need to be implemented in contracts with those organisations to safeguard the security of personal information.  Contracts with external organisations must provide that:

  • the organisation may only act on the written instructions of the school
  • those processing data are subject to the duty of confidence
  • appropriate measures are taken to ensure the security of processing
  • sub-contractors are only engaged with the prior consent of the school and under a written contract
  • the organisation will assist the school in providing subject access and allowing individuals to exercise their rights in relation to data protection
  • the organisation will delete or return all personal information to the school as requested at the end of the contract
  • the organisation will submit to audits and inspections, provide the school with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell the school immediately if it does something infringing data protection law

Before any new agreement involving the processing of personal information by an external organisation is entered into, or an existing agreement is altered, the relevant staff must seek approval from the DPO.

Storage and retention of personal information

Personal data will be kept securely in accordance with the school’s data protection obligations.

Personal data should not be retained for any longer than necessary.  The length of time data should be retained will depend upon the circumstances, including the reasons why personal data was obtained.  Staff should adhere to the School’s Record Retention Schedule which is kept in the Data Protection folder in the School Office.

Personal information that is no longer required will be deleted in accordance with the School’s Record Retention Schedule.

Data breaches

A data breach may take many different forms:

  • Loss or theft of data or equipment on which personal information is stored
  • Unauthorised access to or use of personal information either by a member of staff or third party
  • Loss of data resulting from an equipment or systems (including hardware or software) failure
  • Human error, such as accidental deletion or alteration of data
  • Unforeseen circumstances, such as a fire or flood
  • Deliberate attacks on IT systems, such as hacking, viruses or phishing scams
  • Blagging offences where information is obtained by deceiving the organisation which holds it

The school must report a data breach to the Information Commissioner’s Office (ICO) without undue delay and where possible within 72 hours, if the breach is likely to result in a risk to the rights and freedoms of individuals.  The school must also notify the affected individuals if the breach is likely to result in a high risk to their rights and freedoms.

Staff should ensure they inform their line manager/DPO/Head teacher immediately that a data breach is discovered and make all reasonable efforts to recover the information, following the school’s agreed breach reporting process.

Training

The school will ensure that staff are adequately trained regarding their data protection responsibilities.

Consequences of a failure to comply

The school takes compliance with this policy very seriously.  Failure to comply puts data subjects whose personal information is being processed at risk and carries the risk of significant civil and criminal sanctions for the individual and the school and may in some circumstances amount to a criminal offence by the individual.

Any failure to comply with any part of this policy may lead to disciplinary action under the school’s procedures and this action may result in dismissal for gross misconduct.  If a non-employee breaches this policy, they may have their contract terminated with immediate effect.

If you have any questions or concerns about this policy, you should contact your line manager or the school’s DPO.

Review of Policy

This policy will be updated as necessary to reflect best practice or amendments made to the GDPR or DPA

The Supervisory Authority in the UK

Please follow this link to the ICO’s website (https://ico.org.uk/) which provides detailed guidance on a range of topics including individuals’ rights, data breaches, dealing with subject access requests, how to handle requests from third parties for personal data etc.

Glossary

Automated Decision-Making (ADM):  when a decision is made which is based solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits automated decision-making (unless certain conditions are met) but not automated processing.

Automated Processing:  any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of automated processing.

Consent:  agreement which must be freely given, specific, informed and be an unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear positive action, which signifies agreement to the processing of personal data relating to them.

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.  It is responsible for establishing practices and policies in line with the GDPR. The school is the Data Controller of all personal data relating to its pupils, parents and staff.

Data Subject:  a living, identified or identifiable individual about whom we hold personal data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their personal data.

Data Privacy Impact Assessment (DPIA):  tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major systems or business change programs involving the processing of personal data.

Data Protection Officer (DPO):  the person required to be appointed in public authorities under the GDPR.

EEA:  the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent:  consent which requires a very clear and specific statement (not just action).

General Data Protection Regulation (GDPR):  General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the legal safeguards specified in the GDPR.

Personal data is any information relating to an identified or identifiable natural person (data subject) who can be identified, directly or indirectly by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  Personal data includes sensitive personal data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Privacy by Design:  implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Notices: separate notices setting out information that may be provided to Data Subjects when the school collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, school workforce privacy policy) or they may be stand-alone privacy statements covering processing related to a specific purpose.

Processing means anything done with personal data, such as collection, recording, structuring, storage, adaptation or alteration, retrieval, use, disclosure, dissemination or otherwise making available, restriction, erasure or destruction.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

Pseudonymisation or Pseudonymised:  replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Sensitive Personal Data:  information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal data relating to criminal offences and convictions.

[1] GDPR Article 4 Definitions

[2] These may be provided by a legally binding agreement between public authorities or bodies, standard data protection clauses provided by the ICO or certification under an approved mechanism.

[3] The GDPR states that legitimate interests do not apply to processing carried out by public authorities in the performance of their tasks, Article 6 However, the ICO indicates that where there are other legitimate purposes outside the scope of the tasks as a public authority, legitimate interests may be considered where appropriate (particularly relevant for public authorities with commercial interests).

  • To have data corrected if it is inaccurate or incomplete
    • To have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (‘the right to be forgotten’)
    • To restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but you do not want the data to be erased) or where the school no longer need the personal information, but you require the data to establish, exercise or defend a legal claim
    • To restrict the processing of personal information temporarily where you do not think it is accurate (and the school are verifying whether it is accurate), or where you have objected to the processing (and the school are considering whether the school’s legitimate grounds override your interests)
    • In limited circumstances to receive or ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format
    • To withdraw consent to processing at any time (if applicable)
    • To request a copy of an agreement under which personal data is transferred outside of the EEA.
    • To object to decisions based solely on automated processing, including profiling
    • To be notified of a data breach which is likely to result in high risk to their rights and obligations
    • To make a complaint to the ICO or a Court
 

Data Protection

Norbury CE Primary School
GDPR and Data Protection Policy

General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) is the law that protects personal privacy and upholds individual’s rights. It applies to anyone who handles or has access to people’s personal data.

This policy is intended to ensure that personal information is dealt with properly and securely and in accordance with the legislation. It will apply to personal information regardless of the way it is used, recorded and stored and whether it is held in paper files or electronically.

Policy Objectives
The school as the Data Controller will comply with its obligations under the GDPR and DPA. The school is committed to being concise, clear and transparent about how it obtains and uses personal information and will ensure data subjects are aware of their rights under the legislation.

All staff must have a general understanding of the law and understand how it may affect their decisions in order to make an informed judgement about how information is gathered, used and ultimately deleted. All staff must read, understand and comply with this policy.

The Information Commissioner as the Regulator can impose fines of up to 20 million Euros (approximately £17 million) for serious breaches of the GDPR, therefore it is imperative that the School and all staff comply with the legislation.

Scope of the Policy
Personal data is any information that relates to an identified or identifiable living individual who can be identified directly or indirectly from the information . The information includes factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a living individual. This includes any expression of opinion about an individual and intentions towards an individual. Under the GDPR personal information also includes an identifier such as a name, an identification number, location data or an online identifier.

The School collects a large amount of personal data every year including: pupil records, staff records, names and addresses of those requesting prospectuses, examination marks, references, fee collection as well as the many different types of research data used by the School. In addition, it may be required by law to collect and use certain types of information to comply with statutory obligations of Local Authorities (LAs), government agencies and other bodies.

The Principles
The principles set out in the GDPR must be adhered to when processing personal data:

1. Personal data must be processed lawfully, fairly and in a transparent manner (lawfulness, fairness and transparency)
2. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation)
3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose(s) for which they are processed (data minimisation)
4. Personal data shall be accurate and where necessary kept up to date and every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay (accuracy).
5. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purpose for which the personal data is processed (storage limitation)
6. Appropriate technical and organisational measures shall be taken to safeguard the rights and freedoms of the data subject and to ensure that personal information are processed in a manner that ensures appropriate security of the personal data and protects against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data (integrity and confidentiality).

Transfer Limitation
In addition, personal data shall not be transferred to a country outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission or where the organisation receiving the data has provided adequate safeguards .

This means that individuals’ rights must be enforceable and effective legal remedies for individuals must be available following the transfer. It may also be possible to transfer data where the data subject has provided explicit consent or for other limited reasons. Staff should contact the DPO if they require further assistance with a proposed transfer of personal data outside of the EEA.

Lawful Basis for processing personal information
Before any processing activity starts for the first time, and then regularly afterwards, the purpose(s) for the processing activity and the most appropriate lawful basis (or bases) for that processing must be selected:

• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the school

• Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract

• Processing is necessary for compliance with a legal obligation to which the data controller is subject

• Processing is necessary in order to protect the vital interests of the data subject or of another natural person

• Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party

• The data subject has given consent to the processing of his or her data for one or more specific purposes. Agreement must be indicated clearly either by a statement or positive action to the processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If consent is given in a document which deals with other matters, the consent from be kept separate from those other matters

Data subjects must be easily able to withdraw consent to processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if personal data is intended to be processed for a different and incompatible purpose which was not disclosed when the data subject first consented.

The decision as to which lawful basis applies must be documented, to demonstrate compliance with the data protection principles and include information about both the purposes of the processing and the lawful basis for it in the school’s relevant privacy notice(s).

When determining whether legitimate interests are the most appropriate basis for lawful processing (only where appropriate outside the school’s public tasks) a legitimate interest assessment must be carried out and recorded. Where a significant privacy impact is identified, a data protection impact assessment (DPIA) may also need to be conducted.

Sensitive Personal Information
Processing of sensitive personal information (known as ‘special categories of personal data’) is prohibited unless a lawful special condition for processing is identified.

Sensitive personal information is data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or orientation or is genetic or biometric data which uniquely identifies a natural person.

Sensitive personal information will only be processed if:
• There is a lawful basis for doing so as identified on previous page
• One of the special conditions for processing sensitive personal information applies:
(a) the individual (‘data subject’) has given explicit consent (which has been clearly explained in a Privacy Notice)
(b) the processing is necessary for the purposes of exercising the employment law rights or obligations of the school or the data subject
(c) the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent
(d) the processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade-union aim
(e) the processing relates to personal data which are manifestly made public by the data subject
(f) the processing is necessary for the establishment, exercise or defence of legal claims
(g) the processing is necessary for reasons of substantial public interest
(h) the processing is necessary for purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, the provision of social care and the management of social care systems or services
(i) the processing is necessary for reasons of public interest in the area of public health

The school’s privacy notice(s) set out the types of sensitive personal information that it processes, what it is used for, the lawful basis for the processing and the special condition that applies.

Sensitive personal information will not be processed until an assessment has been made of the proposed processing as to whether it complies with the criteria above and the individual has been informed (by way of a privacy notice or consent) of the nature of the processing, the purposes for which it is being carried out and the legal basis for it.

Unless the School can rely on another legal basis of processing, explicit consent is usually required for processing sensitive personal data. Evidence of consent will need to be captured and recorded so that the school can demonstrate compliance with the GDPR.

Automated Decision Making
Where the school carries out automated decision making (including profiling) it must meet all the principles and have a lawful basis for the processing. Explicit consent will usually be required for automated decision making (unless it is authorised by law or it is necessary for the performance of or entering into a contract).

Additional safeguards and restrictions apply in the case of solely automated decision-making, including profiling. The School must as soon as reasonably possible notify the data subject in writing that a decision has been taken based on solely automated processing and that the data subject may request the school to reconsider or take a new decision. If such a request is received staff must contact the DPO as the school must reply within 21 days.

Data Protection Impact Assessments (DPIA)
All data controllers are required to implement ‘Privacy by Design’ when processing personal data.

This means the School’s processes must embed privacy considerations and incorporate appropriate technical and organisational measures (like pseudonymisation) in an effective manner to ensure compliance with data privacy principles.

Where processing is likely to result in high risk to an individual’s data protection rights (for example where a new technology is being implemented) a DPIA must be carried out to assess:

• whether the processing is necessary and proportionate in relation to its purpose
• the risks to individuals
• what measures can be put in place to address those risks and protect personal information

Staff should adhere to the Data Protection Toolkit for Schools from the DfE with reference to the DPIA template.

When carrying out a DPIA, staff should seek the advice of the DPO for support and guidance and once complete, refer the finalised document to the DPO for sign off.

Documentation and records
Written records of processing activities must be kept and recorded including:

• the name(s) and details of individuals or roles that carry out the processing
• the purposes of the processing
• a description of the categories of individuals and categories of personal data
• categories of recipients of personal data
• details of transfers to third countries, including documentation of the transfer mechanism safeguards in place
• retention schedules
• a description of technical and organisational security measures

As part of the School’s record of processing activities the DPO will document, or link to documentation on:

• information required for privacy notices
• records of consent
• controller-processor contracts
• the location of personal information;
• DPIAs and
• Records of data breaches.

Records of processing of sensitive information are kept on:

• The relevant purposes for which the processing takes place, including why it is necessary for that purpose
• The lawful basis for our processing and
• Whether the personal information is retained or erased in accordance with the Retention Schedule and, if not, the reasons for not following the policy.

The School should conduct regular reviews of the personal information it processes and update its documentation accordingly. This may include:

• Carrying out information audits to find out what personal information is held
• Talking to staff about their processing activities
• Reviewing policies, procedures, contracts and agreements to address retention, security and data sharing.

Privacy Notice
The school will issue privacy notices as required, informing data subjects (or their parents, depending on age of the pupil, if about pupil information) about the personal information that it collects and holds relating to individual data subjects, how individuals can expect their personal information to be used and for what purposes.

When information is collected directly from data subjects, including for HR or employment purposes, the data subject shall be given all the information required by the GDPR including the identity of the data controller and the DPO, how and why the School will use, process, disclose, protect and retain that personal data through a privacy notice (which must be presented when the data subject first provides the data).

When information is collected indirectly (for example from a third party or publicly available source) the data subject must be provided with all the information required by the GDPR as soon as possible after collecting or receiving the data. The school must also check that the data was collected by the third party in accordance with the GDPR and on a basis which is consistent with the proposed processing of the personal data.

The School will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

The School will issue a minimum of two privacy notices, one for pupil information, and one for workforce information, and these will be reviewed in line with any statutory or contractual changes.

The staff school workforce privacy notice can be found in the Data Protection folder in the School Office.

Purpose Limitation
Personal data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.

Personal data must not be used for new, different or incompatible purposes from that disclosed when it was first obtained unless the data subject has been informed of the new purposes and they have consented where necessary.

Data minimisation
Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Staff may only process data when their role requires it. Staff must not process personal data for any reason unrelated to their role.

The School maintains a Retention Schedule to ensure personal data is deleted after a reasonable time for the purpose for which it was being held, unless a law requires such data to be kept for a minimum time. Staff must take all reasonable steps to destroy or delete all personal data that is held in its systems when it is no longer required in accordance with the Schedule. This includes requiring third parties to delete such data where applicable.

Staff must ensure that data subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

Individual Rights
Staff as well as any other ‘data subjects’ have the following rights in relation to their personal information:

• To be informed about how, why and on what basis that information is processed (see the relevant privacy notice)

• To obtain confirmation that personal information is being processed and to obtain access to it and certain other information, by making a subject access request

To have data corrected if it is inaccurate or incomplete

• To have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (‘the right to be forgotten’)

• To restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but you do not want the data to be erased) or where the school no longer need the personal information, but you require the data to establish, exercise or defend a legal claim

• To restrict the processing of personal information temporarily where you do not think it is accurate (and the school are verifying whether it is accurate), or where you have objected to the processing (and the school are considering whether the school’s legitimate grounds override your interests)

• In limited circumstances to receive or ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format

• To withdraw consent to processing at any time (if applicable)

• To request a copy of an agreement under which personal data is transferred outside of the EEA.

• To object to decisions based solely on automated processing, including profiling

• To be notified of a data breach which is likely to result in high risk to their rights and obligations

• To make a complaint to the ICO or a Court

Individual Responsibilities
During their employment, staff may have access to the personal information of other members of staff, suppliers, clients or the public. The school expects staff to help meet its data protection obligations to those individuals.

If you have access to personal information, you must:

• only access the personal information that you have authority to access and only for authorised purposes
• only allow other staff to access personal information if they have appropriate authorisation
• only allow individuals who are not school staff to access personal information if you have specific authority to do so
• keep personal information secure (e.g. by complying with rules on access to premises, computer access, password protection and secure file storage and destruction in accordance with the school’s policies)
• not remove personal information, or devices containing personal information (or which can be used to access it) from the school’s premises unless appropriate security measures are in place (such as pseudonymisation, encryption or password protection) to secure the information and the device
• not store personal information on local drives or on personal devices that are used for work purposes

Information Security
The school will use appropriate technical and organisational measures to keep personal information secure, to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

All staff are responsible for keeping information secure in accordance with the legislation and must follow their school’s acceptable usage policy.

The school will develop, implement and maintain safeguards appropriate to its size, scope and business, its available resources, the amount of personal data that it owns or maintains on behalf of others and identified risks (including use of encryption and pseudonymisation where applicable). It will regularly evaluate and test the effectiveness of those safeguards to ensure security of processing.

Staff must guard against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data. Staff must exercise particular care in protecting sensitive personal data from loss and unauthorised access, use or disclosure.

Staff must follow all procedures and technologies put in place to maintain the security of all personal data from the point of collection to the point of destruction. Staff may only transfer personal data to third-party service providers who agree in writing to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

Staff must maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

Confidentiality means that only people who have a need to know and are authorised to use the personal data can access it.

Integrity means that personal data is accurate and suitable for the purpose for which it is processed.

Availability means that authorised users can access the personal data when they need it for authorised purposes.

Staff must comply with and not attempt to circumvent the administrative, physical and technical safeguards the school has implemented and maintains in accordance with the GDPR and DPA.

Where the school uses external organisations to process personal information on its behalf, additional security arrangements need to be implemented in contracts with those organisations to safeguard the security of personal information. Contracts with external organisations must provide that:

• the organisation may only act on the written instructions of the school
• those processing data are subject to the duty of confidence
• appropriate measures are taken to ensure the security of processing
• sub-contractors are only engaged with the prior consent of the school and under a written contract
• the organisation will assist the school in providing subject access and allowing individuals to exercise their rights in relation to data protection
• the organisation will delete or return all personal information to the school as requested at the end of the contract
• the organisation will submit to audits and inspections, provide the school with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell the school immediately if it does something infringing data protection law

Before any new agreement involving the processing of personal information by an external organisation is entered into, or an existing agreement is altered, the relevant staff must seek approval from the DPO.

Storage and retention of personal information
Personal data will be kept securely in accordance with the school’s data protection obligations.

Personal data should not be retained for any longer than necessary. The length of time data should be retained will depend upon the circumstances, including the reasons why personal data was obtained. Staff should adhere to the School’s Record Retention Schedule which is kept in the Data Protection folder in the School Office.

Personal information that is no longer required will be deleted in accordance with the School’s Record Retention Schedule.

Data breaches
A data breach may take many different forms:

• Loss or theft of data or equipment on which personal information is stored
• Unauthorised access to or use of personal information either by a member of staff or third party
• Loss of data resulting from an equipment or systems (including hardware or software) failure
• Human error, such as accidental deletion or alteration of data
• Unforeseen circumstances, such as a fire or flood
• Deliberate attacks on IT systems, such as hacking, viruses or phishing scams
• Blagging offences where information is obtained by deceiving the organisation which holds it

The school must report a data breach to the Information Commissioner’s Office (ICO) without undue delay and where possible within 72 hours, if the breach is likely to result in a risk to the rights and freedoms of individuals. The school must also notify the affected individuals if the breach is likely to result in a high risk to their rights and freedoms.

Staff should ensure they inform their line manager/DPO/Head teacher immediately that a data breach is discovered and make all reasonable efforts to recover the information, following the school’s agreed breach reporting process

Training
The school will ensure that staff are adequately trained regarding their data protection responsibilities.

Consequences of a failure to comply
The school takes compliance with this policy very seriously. Failure to comply puts data subjects whose personal information is being processed at risk and carries the risk of significant civil and criminal sanctions for the individual and the school and may in some circumstances amount to a criminal offence by the individual.

Any failure to comply with any part of this policy may lead to disciplinary action under the school’s procedures and this action may result in dismissal for gross misconduct. If a non-employee breaches this policy, they may have their contract terminated with immediate effect.

If you have any questions or concerns about this policy, you should contact your line manager or the school’s DPO.

Review of Policy
This policy will be updated as necessary to reflect best practice or amendments made to the GDPR or DPA.

The Supervisory Authority in the UK
Please follow this link to the ICO’s website (https://ico.org.uk/) which provides detailed guidance on a range of topics including individuals’ rights, data breaches, dealing with subject access requests, how to handle requests from third parties for personal data etc.

Glossary

Automated Decision-Making (ADM): when a decision is made which is based solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits automated decision-making (unless certain conditions are met) but not automated processing.

Automated Processing: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of automated processing.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear positive action, which signifies agreement to the processing of personal data relating to them.

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. It is responsible for establishing practices and policies in line with the GDPR. The school is the Data Controller of all personal data relating to its pupils, parents and staff.

Data Subject: a living, identified or identifiable individual about whom we hold personal data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their personal data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major systems or business change programs involving the processing of personal data.

Data Protection Officer (DPO): the person required to be appointed in public authorities under the GDPR.

EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (not just action).

General Data Protection Regulation (GDPR): General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the legal safeguards specified in the GDPR.

Personal data is any information relating to an identified or identifiable natural person (data subject) who can be identified, directly or indirectly by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data includes sensitive personal data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Notices: separate notices setting out information that may be provided to Data Subjects when the school collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, school workforce privacy policy) or they may be stand-alone privacy statements covering processing related to a specific purpose.

Processing means anything done with personal data, such as collection, recording, structuring, storage, adaptation or alteration, retrieval, use, disclosure, dissemination or otherwise making available, restriction, erasure or destruction.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal data relating to criminal offences and convictions.