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It’s been interesting to hear of the frustrations of fellow list members, and I feel your collective pain.

 

I hold my head in my hands each time I see something like this … and also being a member of School Governor groups, Primary ICT Co-ordinator groups and CS/ICT Teacher groups … I am seeing so many examples of this.

 

Trying to get schools to understand it is, in general, a risk assessment and that they have to actually think before reacting in a risk-adverse way! I wouldn’t mind, but many schools have got a wealth of experience on managing risk already … they just need to think a little.

 

I’ll also hold up my hands and say that I was one of many involved feeding into the DfE Toolkit that went out … and if all the examples were put in that were suggested within the case studies, it would have been 5 times as long. And yet I get schools saying time and time again that they have not been given specific advice about their specific scenario.

 

The charts have a very good reason for being there. They have a role to inspire individual motivation and to form part of peer-support within a class. This could easily argued as public task *as long as the school actually thinks about what they are doing and why!* (not LI … please don’t confuse schools with LI … it has been hard enough with schools being told that everything has to be done under Consent). Where group work or activities are completed there is a reasonable expectation and understanding that previous ‘rewards’ will be known to other children and there is no way to further restrict the children from sharing it. At that point it is about informing parents that summary statistical information will be used and shared to support individual, group and class progress both academically and pastorally. This means that you are not sharing specifics … the difficulty is when we say ‘rewards’ … most rewards systems also deal with removal of points too … and that would be for behaviour, failure to complete tasks and so on. That is where the risks lie. Celebrate rewards … little Jane has earned x for sporting achievements last week, little Johnny has received y for outstanding academic results, or highlight areas to achieve.

 

As for it being in a possibly public area, there are already some good safeguarding practices that say not to use full name, to use avatars of some kind instead of pictures … this is not rocket science for a school. If the school is used for other activities (brownies, adult ed), then have it on the inside of cupboard door that gets closed and locked each night. The same applies to medical information in kitchens … cover when not needed and lock away where possible.

 

As for doing this with adults … I think about the number of EdTech suppliers I have walked into over the years (even as a school or LA contact) to see sales targets for individuals up on the wall, support targets and even Dev targets …

 

-- 

Tony Sheppard

Operations Manager

GDPR in Schools

 

 

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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