Hi Azhar, I think that there is a level of expectation that the student will have already gained some form of acceptance from his/her emergency contact details.
The emergency contact data subject can always exercise their own rights to have themselves removed of course.
We are trying to get our learner portal set up presently do that the students can keep this type of information up to date themselves.
Regards.
Ian Headley
Data Protection Officer
RNN Group
M 07810 802777
Twitter : @rnndataprotect
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Azhar Iqbal
Sent: 01 May 2018 16:26
To: [log in to unmask]
Subject: [data-protection] Student Emergency Contact Details
Hi All,
Your thoughts/comments on this one please.
As part of our enrolment process we collect students’ parent/carer/guardian contact details (name, address, telephone number, email address) from the student. This information is for emergency contact purposes as well as keeping the parent/carer/guardian informed of the student’s progression, marks, attendance etc. For the latter purpose we give students the right to withdraw their consent to allow us to keep their parent/carer/guardian informed of their progression (our students are typically over the age of 16).
In this scenario, where we have collected the information from the student, would it be prudent/required for us to let the parent/carer/guardian know that we have their personal data (and therefore point to our privacy notice)? Or do we inform the student how we intend to use the data, and therefore assume (I know, assumption where students concerned doesn’t bode well!) that the student has told their parent/carer/guardian? For the emergency contact purposes, could we argue that we have legitimate interest to store this information without consent?
Thanks
Azhar
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