I hope that this alert finds you well in light of the recent disruption to your working arrangements. We have created some resources for use during this period which I am sure you will find useful- they will be explained in more detail below.
The following documentation can now be found on the Veritau Portal:
Coronavirus (Covid19) Privacy Notice for Pupils, Parents and Employees
We have created a specific Privacy Notice to capture changes to your processing activities in light of Coronavirus and the changes to your working practice. This is for schools who are staying open to accommodate the children of critical workers and other pupils who are allowed to be in school during the closures. The Notice also reflects that some schools may be hosting pupils and staff from other schools during this period. This is not intended to replace your existing Privacy Notices or repeat the information contained within them- this is only to reflect any changes brought on by the current situation.
Please ensure that you add to or amend this Notice to best reflect your processing requirements during the Cornavirus (Covid19) pandemic. We would recommend that you make this available on your website and signpost this to the relevant parents/pupils/staff members.
Guidance on working from home
Now that most schools will have had to dramatically change their working practices to accommodate home working, this is an excellent time to remind all staff how to implement the appropriate security measures when dealing with personal information. We would encourage all staff members who are working from home to read this guidance to minimise the occurrence of any data breaches.
Do we still have to respond to FOI/EIR/GDPR requests in light of the current situation?
Yes. The outbreak does not remove your legal obligation to provide data under the FOI Act, the EIR and the GDPR. However, the Information Commissioner’s Office has recognised that your organisation’s resources may be diverted away from non-essential services. The ICO has announced that they will not penalise public authorities for non-compliance during this period. More information can be found on the ICO’s website: https://ico.org.uk/about-the-ico/news-and-events/icos-blog-on-its-information-rights-work/
Should I inform applicants that there may be a delay?
Yes. Where possible you should make applicants aware if a response to their request will be late. If you have an automatic acknowledgement for FOI/EIR/GDPR requests, then it may be useful to add a statement here advising of a potential delay. The ICO have also advised data subject to expect delays on these requests.
Can we stop processing these requests entirely during this period?
Though the ICO has been clear that they will not pursue any regulatory action during this period for non-compliance, we would strongly encourage you to continue processing requests as normal wherever you can. This will mean you have less of a backlog in the future.
Due to the recent government advice the Veritau Information Governance team will be working from home. Due to this our 01609 532526 office number will not be in use, if you require a telephone call please email: Schoolsdpo@veritau.co.uk and a team member will contact you shortly
If you have any queries about the contents of this email or if you would like to contact the team please do so by emailing or calling:
schoolsDPO@veritau.co.uk | 01609 532526