St. Thomas More/St. Margaret College, Secondary School, Zejtun, intends to fully comply with the Data Protection Act 2001 which regulates the processing of personal data whether held electronically or in manual form. This school requires to process personal data to comply with legal obligations under the Education Act 1988 and all other statutory provisions, including the National Minimum Curriculum which outlines the following:
a) The right of every citizen to receive education;
b) Equality of access to the educational system;
c) Placing the student at the centre of the educational system;
d) Stimulating the development of students’ potential without undermining solidarity and co-operation;
e) Holistic principles at the heart of the student – school relationship;
f) Facilitating parents’ participation.
Processing includes obtaining, recording, holding, accessing, disclosing or using personal data. The Head of school, being the data controller in terms of the Data Protection Act, has overall responsibility for ensuring that records are correctly processed. All staff within St. Thomas More College/St. Margaret College, Secondary School, Zejtun, involved with such processing are aware of their duties and responsibilities in line with this policy.
PROCESSING PURPOSES – The school processes personal data in relation to students and parents/legal guardians for the following purposes:
Student and parent/legal guardian details are collected upon registration of a student to attend this school or upon admission of a student to this school. Such registration details are required to establish a student register for the administration of the intake of yearly students, and for the daily operations and efficient running of the school. Student records may also include photographs. The student details will incorporate the details of their parents/legal guardians to be contacted as necessary and to maintain a sound relationship with them, by involving them in the educational development of their child attending this school. Parents/legal guardians may also participate in school activities in the interest of their children. It is the responsibility of parents/legal guardians to provide the school with any amendments or changes to the registration details of our students to keep such information up to date.
b) Academic progress monitoring
This school is committed to provide the best education possible to its students. Performance data, including examination and/or assessment results are compiled and associated with student records, to monitor their progress during the scholastic years.
c) Organisation of school functions
From time to time the school organises activities to promote students’ achievements, and give them exposure to certain field work to develop further their potential and abilities. The functions may form part of curricular requirements (such as prize day, graduation day, parents’ day, religious functions, sports day, etc.) or may be of a non-curricular nature (such as outings, exhibitions, Christmas parties, etc.). In all functions, data of students and their parents/legal guardians may be processed for this purpose. Consent will be sought for processing of personal data related to non-curricular activities.
d) Historic records
Selective records processed for the above mentioned purposes (administration, academic and school functions) may be archived and kept for historic and record purposes.
e) Student welfare
The school may process records related to the welfare and social behaviour of the student concerned. Such information may include court orders regarding custody of minors, information compiled by child protection services including guidance and counselling, as well as any other information obtained from the student or parent/legal guardian, law enforcement officers, and other support agencies including Appoġġ, Sedqa, and Caritas. Such welfare data is processed in the best interest of the student concerned in order to provide her with the best possible protection and assistance, to improve her welfare, and further progress the development of the student involved.
Medical examinations may be carried out by state doctors, nurses, psychologists, statementing board members and other health professionals to monitor the state of health of the students attending this school. Other health related information may also be provided by the parent/legal guardian themselves as a preventive measure.
g) Statistics and research
Personal data processed for statistical and research purposes are made anonymous. Where data is required for research related to students, consent is sought from the parent/legal guardian prior to its disclosure only when the research/statistics will not be rendered anonymous.
PROCESSING OF VISUAL IMAGES – St. Thomas More College, Girls’ Junior Lyceum, Zejtun, allows the taking of visual images in the form of photos, videos or other means, in its school activities. It is pertinent to point out that the school is only responsible for visual images taken by school representatives. Persons taking visual images for personal use during a school activity are held responsible for the use of such visual images. Where a public event is held in this school and such event is advised by the Director of Information, the press covering the event will be data controllers in relation to the visual images. In such cases, while the reporter shall enquire with the Head of School whether there are any objections to visual images of particular children, the Head of School or his representative would also point out any such objections to the press where possible.
Upon the admittance of students in this school, consent will be sought from parents/legal guardians where visual images are:
- taken by school representatives in non-curricular activities;
- used for communications purposes by publishing them on:-
- printed matter including internal and external publications (e.g. school magazines, annual reports, newsletters, etc),
- school notice boards (except to process orders by students),
- media – including newspapers and TV,
- the internet (school and Education Directorates websites);
- used for any other purpose other than administrative, school functions, historic and communications purposes.
The consent given by parents/legal guardians may be withdrawn after informing the head of school in writing. No visual image of the student in question will be taken after the consent has been withdrawn.
When a professional photographer is engaged by the school, the school shall ensure that the photographer understands data protection considerations and that he/she is capable to satisfy all responsibilities and obligations in accordance with the Data Protection Act. This relationship will be regulated by a contract between the school and the photographer.
Visual images are retained for a period of three years except for those selected to be kept for historic records of the school.
RECIPIENTS OF DATA – Personal data will not be disclosed to other third parties without the consent of the parent/legal guardian, unless obliged by law and unless it is in the best interest of the child. Personal data will therefore be accessed and disclosed as follows:
Restricted staff members of the school will access personal data on a need to know basis in the course of executing their duties. The professional staff requiring such data is fully aware of the obligations the school has under the Data Protection Act, and they will only use the data for the purposes for which it was collected.
The school endeavours to inform students and their parents/legal guardians when there is a possibility that personal data may be disclosed to third parties, and will ask for consent where applicable. However, there are instances where personal data will have to be disclosed without consent to the following third parties:
- Education Directorates – to evaluate and develop education policies related to state schools, to enforce the Education Act where required, and to monitor the national educational system.
- College Principals – to monitor that educational policies and standards are achieved to the required quality, and to ensure the educational and holistic well being of the students attending the schools within the college.
- Other schools – where a student is transferred to another school, all academic records and other data related to the welfare and health of the student are forwarded to the other school, for continuation purposes.
- Examination Authorities – to enable our students to sit for examinations as part of the examinations process.
- Health Authorities – to avoid contagious diseases or epidemics as obliged under health legislation in the interest of public health.
- Hospitals/Clinics/other medical professional – where a student needs medical treatment due to illness or injuries suffered by her. Health inspections are also conducted as part of the health monitoring programme for school children.
- Police – in cases of criminal investigations and in the interest of law and order inside the school premises.
- Social workers/Support agencies – where the welfare of the student is not being maintained and in cases of child abuse.
- The Employment and Training Corporation – in the case of students who do not proceed to further their education in higher educational institutions, so as to provide them with employment opportunities and other related information.
- Courts – as ordered.
STUDENT AND PARENT/LEGAL GUARDIAN RIGHTS – Students and parents/legal guardians are entitled to be provided with:
a) actual information processed about them;
b) a description from where this information has been collected;
c) the purpose for processing such information;
d) details about the recipients to whom data is disclosed;
e) Knowledge of the logic involved in any automatic processing of data concerning them.
The request has to be made in writing duly signed by the parents/legal guardians and addressed to the head of school. Requests concerning students are to be made by their parents/legal guardian on behalf of the students.
The school aims to comply as quickly as possible with requests for access to personal information and will ensure that it is provided within a reasonable time, unless there is a good reason for delay. When a request for access cannot be met within a reasonable time, the reason will be explained in writing to the parent/legal guardian making the request.
In the event that personal data prove to be incorrect, the parent/legal guardian concerned may request to rectify, erase or not to use the information in question.
RETENTION OF PERSONAL DATA – The school does not hold any data longer than necessary, having considered the purposes for processing. In this regard, all personal data relating to students and their parents/legal guardian will be held for the period during which the student attended this school, with the exception of records selected to be kept for record purposes, and statistical data. Eventually visual images not selected for historic record purposes will be kept for three years only.
Marks obtained by students in examinations are also kept for the duration of their attendance at this school, with the exception of results of the last scholastic year which are held for a period of five years only. It is therefore very important that all certificates, results and any other record indicating the educational progress of the student, is to be appropriately preserved by the parents/legal guardian for future use by the student.
ENQUIRIES – All enquiries related to this school’s Data Protection Policy are to be addressed as follows:
The Head of School
St. Thomas More College, Girls’ Junior Lyceum,
Luqa Briffa Street