Love the hat v GDPR thing. What are they worried about that the parent of one child may accidentally collect biometric data as in a
stray hair from another child’s hat in the lost property box? Illegal sharing of data? Joint data controller? Priv Notice to the owner of the stray hair to say data is now being processed by another party? Where does the madness end???
I am very new to DP and was thrown in at the deep end and have decided that if it was OK on 24th May it’s probably OK now
but I just have to write it all down. I was previously a primary school teacher very briefly and the teacher needs those charts for motivation and crowd control but could of course pseudonymise…..
Only today I picked my own son up for an appointment and had to sign him out on a list of everyone else who had been collected early
that day and could see what time they left, who picked them up and what for. I didn’t mention it as the school had previously referred to the GDPR with an s on the end – which is my own pet hate and also sent me a PN informing me I was a joint data controller
with them.
Hope you got the hat back. When they get to big school they just lose one expensive trainer…..
Alison DPO ELDC
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]]
On Behalf Of Mike Penton
Sent: 29 June 2018 16:06
To: [log in to unmask]
Subject: Re: [data-protection] Friday digression
This message originated from outside your organization
I have a digression from the digression: my wife was told earlier this week that she couldn’t accompany our son into the classroom
after school to look for his missing hat “because of GDPR”…
I’m sure a visible reward chart would be against the current default spirit of ‘everyone’s a winner’ :)
From: This list is for those interested in Data Protection issues <[log in to unmask]>
On Behalf Of Palmer-Dunk, Daniel
Sent: 29 June 2018 11:37
To: [log in to unmask]
Subject: [data-protection] Friday digression
Good morning everyone,
I don’t raise the following with any serious purpose, but someone asked me about it and I wondered if anyone else
might have anything to say on the subject:
Is putting a ‘reward chart’ for children (in this case in a primary school) on a classroom wall a breach of data
protection? Children get ‘points’ for behaviour, effort, etc. and these are logged against their name on a chart.
My thoughts are that the school could claim legitimate interests for this processing, but is display of the information
necessary? The information could easily be conveyed privately on an individual basis to either the child or the child's parents. Is visibility to other children more necessary than visibility to their parents? What are the expectations of confidentiality on
the children/parents?
Possibly the display satisfies an interest in the transparency and accountability of the reward system, but does
this outweigh the stress and anxiety caused to children in comparing themselves against their peers? Moreover, could the school demonstrate
compelling legitimate grounds which override the interests, rights and freedom of the child if an objection was made? I would eagerly await detail of the interest balancing exercise.
Of course, the processing and disclosure of the information is low overall risk, but it would be outrageous do this
with adults in the employment context. I’m sure many parents find the idea of forcing children to compete against each other in this way just as unpleasant and harmful.
In any case, thinking about it amused me for a little while, and I thought it might some of you.
Dan
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