Hi Jon,
I think the issue of data processor is not that relevant here. What matters is how a parent (or a pupil) accesses the "educational record". Under the Regulations, specifically schools have the legal obligation to provide access to that information (as long as they process it) and any request should be made to them. So, if the school processes the information and it constitutes an "education record" as defined in regulation 3, then that information must be made available.
I hope that helps,
Jackie.
Jackie Milne
Legal Information Specialist
JISC Legal
Tel: 0141 548 4939
Email: [log in to unmask]
JISC Legal is hosted by the University of Strathclyde, a charitable body, registered in Scotland, with registration number SC015263.
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