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I had a discussion yesterday along the following lines:

Are the workings of a school pupil in a jotter personal data? Would this
mean that all work by the pupil is personal data (e.g. artwork)?

Are the jotters data because they are part of a relevant filing system (e.g.
jotters of each child in the class in a basket for that particular child),
because they are an accessible record or for any other reason?

If the jotters are an accessible record could the exemption in Sch. 11 be
used in that the jotters are for the sole use of the teacher?!

Any views gratefully received. I think that the jotters are data for both
reasons given above but that the exemption above does not apply.

David Logan
Principal Solicitor
West Dunbartonshire Council.

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