Privacy Notice

Due to the unprecedented circumstances of COVID-19 we are working hard to prioritise the delivery of essential front-line services to our most vulnerable people and communities.

The Department of Education, Sport and Culture has diverted resources to priority work areas with consequential impacts on other areas such as the handling of Subject Access Requests. Your statutory rights are important to us and remain unchanged. Please note however that you may experience delays in our response to your request. We will inform you of any extension to the period for responding and the reasons for the delay.

If you are able to narrow the scope of your request that would be very helpful and may mean we can respond to you more quickly. In addition you may want to reconsider whether your request can be resubmitted at a later date once the impact of COVID-19 has eased.

We will be alert to any guidance from the regulator, the Information Commissioner, as the situation changes, to ensure that we comply with any guidance or changes to information rights.

For more information on Coronavirus (COVID-19), see gov.im/coronavirus

Secondary Schools

In addition to the information set out in the Isle of Man Privacy Notice for each institution, the Department may also collect the following information about you or your child(ren) under the Registration of Pupils Regulations 2016:

Information may also be requested in response to the following, which are not covered by the Registration of Pupils Regulations 2016. The legal basis for these may include consent, contract, legal obligation, to protect the vital interests of the data subject or of another natural person or performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller:

The Data Protection Officer for the Department of Education, Sport and Culture is:

Andrew Shipley
Department of Education, Sport and Culture
Hamilton House,
Douglas. 
IM1 5EZ

Tel: 01624 685828. 
Email: DPO-DESC@gov.im

The Department of Education, Sport and Culture will use your information to:

• Undertake School Self-Review and Evaluation (SSRE)
• Process out of catchment area requests
• Process and pass information on to the Treasury to determine eligibility for Free School Meals
• Process and pass on information to transport services of Bus Vannin relating to requests for transport support
• Process applications for student awards
• With consent, send contact details to prospective employers and organisations
• Record details of educational provision for those educating otherwise than at provided and maintained schools on the Isle of Man
• Use attendance information to fulfill the Department’s obligations under the Education Act 2001. This may be shared with agencies such as counselling services, Social Care, the Police and Health, Youth Justice, if there is a significant issue
• Schools make referrals (consisting of name, DOB, Parent names and their DOB, address and outlines of concerns) with the Department of Health and Social Care, normally with parental consent, unless there is a risk of significant harm to the child
• When children are on welfare plans (Early Help and Support (Consent), Child with Complex Needs (consent – section 23 of the Children and Young Persons Act 2001) and Child Protection (Legal basis – section 46 of the Children and Young Persons Act 2001) or Looked after Children (Legal basis – section 25 of the Children and Young Persons Act 2001 or court order)) schools will bring updated information on a regular basis regarding, for example, their aptitude, behavior, attainment, attendance, and any other information deemed important to understand the current needs of the child
• SEN and EAL Registers is where your child has special educational needs (SEN), or speaks English as an additional language (EAL), the school will seek your permission to include your child's details on the school SEN or EAL register.  Schools need to share their SEN register with the Inclusion and Safeguarding Division of the Department in order to arrange and resource appropriate educational provision and services to meet your child's needs. The SEN register information shared with the Department includes your child's name, date of birth, gender, Year group/class, level of need, primary and secondary difficulty, area of need, and any relevant teacher comments. The EAL register information shared with the Department includes child's name, date of birth, gender, Year group/class, first language, other language spoken, year of entry to Isle of Man school, EAL level and position in family.
• Provide access to funding of apprenticeships and to training via Training Services, a section in the Department
• Synchronising all RAN users to allow students to download a copy of Office for use on their own devices
• To monitor the security of a school site, minimising vandalism and theft, and deterring anti-social behaviour
• To validate details in regard to pre-school credit applications
• Help prevent and detect crime

The Department of Education, Sport and Culture has a statutory obligation to check and verify the data you provide to us:

• For Subject Access Requests to verify that we provide information to the correct person
• For financial information in relation to student awards.
• To ensure that data is up to date and accurate

This may include checks of publicly available information but in some cases, where it is necessary and relevant to your application, theinformation you provide may be disclosed or shared with other organisations.

This will only be done where there is a legal obligation for us to do so. We will do this to allow us to:

• Obtain information from schools about class numbers
• Verify eligibility for Free School Meals and inform schools that this is the case
• Verify eligibility for and organise appropriate transport for students requiring these services
• Enable Student Awards to determine the level and type of financial support available
• Allow support to be provided for those families who need it from a number of agencies including the Department of Health and Social Security
• Verify the information and documentation you have provided is correct
• Help prevent and detect crime including fraud, money laundering, identity theft or other criminal offences

Third parties the Department or schools (see individual school / UCM / Villa Marina Gaiety / MSR and Ardwhallin websites for more information) may share information with include:

• Department of Health and Social Services
• Department of Infrastructure – Bus Vannin
• Treasury – Social Security Division and Income Tax Division
• Department for Enterprise
• Manx Sport and Recreation – for swimming lessons and other physical education activities
• Isle of Man Constabulary – for bicycle training
• Employers and organisations - relating to employment opportunities

Examination bodies (Including Cambridge International Examinations, WJEC, Council for the Curriculum, Examinations and Assessment (CCEA), Scottish Qualifications Authority (SQA), BTEC). This information is to facilitate participation in external examinations and includes:

• Name
• DOB
• Predicted grades

SIMS (Secondary School Information Management System) – CAPITA

Arbor (Primary School Information Management System) – Data Protection Policy

ParentPay - In order to better improve services to students and parents as well as improve the management and efficient working of Education Establishments, one strand of the digital strategy aims to enable students to pay for services with a smart card that parents can top up online. In order to achieve this, we have formed a partnership with ParentPay.

ItsLearning - ItsLearning is entering into use across the Isle of Man educational establishments and is the means through which teachers and students will share lessons, homework and ideas, from anywhere. To generate a login for ItsLearning, we need to share information with the platform provider. See the privacy policy for Itslearning for more details.

Google docs and mail - Two of our main collaboration and communication tools are Google Docs and Google Mail. These are a means through which the school shares information with students, and vice-versa, from anywhere. To create a Google account it is necessary to share your son/daughter’s name and year group with Google. Review Google's privacy policy.

Quasmedia: provides web-hosting for most schools.

Online learning resources: Increasingly, schools subscribe to learning resources which are accessible through a computer or mobile device. Current examples include:

GCSEPod: includes many resources designed to help students to understand what they need to know for their exams

MyMaths: a rich resource bank of maths questions which students can work on from home.

Online text books (eg Oxford University Press)

Schools would like to be able to offer access to those online learning resources which are judged to be most beneficial to students. Please consult with your school to determine which apps and services are currently being used by them.

List of entities, consider UK Government bodies: Home Office, Isle of Man Government Departments, Boards and Office etc Specifically

• law enforcement agencies
• fraud prevention agencies

Information obtained or disclosed by third parties will not be used for any other purpose other than supporting your child particularly regarding educational provision within schools.

Failure to provide consent where required may limit the use of applications within schools. In the case of ParentPay alternative means will be needed to pay for services such as school dinners.

Please note, a young person can give consent from the age of 13 (depending on their capacity). If consent is being sought from them then it will be evidenced in an appropriate form.

The Department of Education, Sport and Culture will:

• Keep your information safe and secure in compliance with its information security policy
  
• Only use and disclose your information as detailed above, where necessary
• Retain the information for no longer than is necessary and your information will be permanently deleted once the timeframes set out below and in the Department’s retention schedule have been reached (there will need to be an authorisation process, to dispose of this in line with our Records Management Policy and retention periods as outlined below and in the Department’s retention schedule (unless there is an over-riding reason to retain this information)

You have a right to access your personal data to ensure that it is accurate, and to request that it is rectified, blocked, erased or destroyed if it is inaccurate. 

Please be advised that there are records selected for permanent preservation under the Public Records Act 1999, namely the school admission register. It is therefore necessary to contact the Public Records Office before permanent deletion of specified records to ensure that these have not been selected for permanent preservation.

• To make any request relating to your data held by us, please contact the Data Protection Officer for the Department of Education, Sport and Culture who is: Andrew Shipley. Department of Education, Sport and Culture, Hamilton House, Douglas. IM1 5EZ. Tel 01624 685828.  Email: DPO-DESC@gov.im

If you are not satisfied with the response you receive, you may also complain to the Information Commissioner, whose details can be found on www.inforights.im, or the relevant supervisory authority. You may have a right to other remedies.

There are occasions when data is transferred outside of the EEA but these are in exceptional circumstances. Permission will be sought from parents / guardians / students to transfer the information to a known recipient. If possible this will be password protected, with a password being sent by an alternative means.

Names, contact information and information provided by a recipient of the Ella Oleson scholarship will be sent to the University of Idaho in the United States in order to access this programme.

For those students who study at Universities outside of the EEA it may be necessary to send financial information and contact information to the establishment.

You can find out more information including:

• Looking at the Isle of Man Government Privacy Policy
• Asking to see your information or making a complaint if you feel that your information is not being handled correctly
• Making a subject access request which is a request for all of the personal data we hold about you

Contacting our Data Protection Officer by: 

Email: DPO-DESC@gov.im

Tel: +44 1624 685828

Department of Education
Sport and Culture
Hamilton House
Douglas
IM1 5EZ

If you are not satisfied with the response you receive, you may also complain to the Information Commissioner  or the relevant supervisory authority. You may have a right to other remedies.

Administrative procedures, such as deletion of records, will occur in the summer months, particularly August, of the relevant year indicated below.

For more specific details about retention periods see the Department’s retention schedule.