BUCKRIDGE PRIVATE SCHOOL

Protection of Personal Private Information Policy according to (POPIA)

INTRODUCTION

Buckridge Private School values the privacy of every person and is committed to protecting information that the school collect. All staff including contractors, service providers, must comply with POPIA and this policy. This policy explains how our school collects and manages personal and health information, consistent with POPIA law.

Current version of this policy

This policy will be regularly reviewed and updated to take into account new laws, technology and the ever-changing school environment when required. Always familiarize yourself with it and any changes that might be brought forth by new global educational trends.

Definitions

Personal information is information or opinion, whether true or not, about a person whose identity is apparent, or can reasonably be ascertained, from the information or opinion – that is recorded in any form. For example, a person's name, address, phone number and date of birth (age).

Health information is information or opinion about a person’s physical, mental or psychological health or disability, that is also personal information – whether in writing or not. This includes information or opinion about a person’s health status and medical history, immunisation status and allergies, as well as counselling records.

Sensitive information is information or opinion about a set of specific characteristics, including a person’s racial or ethnic origin, political opinions or affiliations, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices; or criminal record. It also includes health information.

What information do we collect?

Our school collects the following type of information:

·         Information about students and their families, provided by students, their families and others.

·         Information about job applicants, staff, interns and visitors; provided by job applicants, staff members, interns, visitors and others.

How do we collect this information?

Our school collects information in a number of ways, including:

·         in person and over the phone: from students and their families, staff, interns, visitors, job applicants and others

·         from electronic and paper documentation: including job applications, emails, invoices, enrolment forms, letters to our school, consent forms (for example: enrolment, excursion indemnity forms), Social Services forms, Bursary application forms, psychological/specialist reports, Dairy/ communication book, Registers auto biographical data records, our school’s website or school-controlled social media platforms.

·         Through online tools: such as apps e.g. Facebook Page

·         Through any CCTV cameras located at our school.

Collection notices

When our school collects information about you, our school takes reasonable steps to advise you of how the information will be handled. This includes the purpose of the collection, and how to access, update and correct information held about you. For information about students and their families, a the admission/enrolment package is used as the tool draw this information from the parents and mature minors in the senior phase in some instances like filling the dairy book..

Unsolicited information about you

Our school may receive information about you that we have taken no active steps to collect eg ED-Lab files sent by previous school for learner’s records which are only shared from school to school electronically according to the SA-SAMS. If permitted or required by law, our school may keep records of this information. If not, we will destroy the information when practicable, lawful and reasonable to do so.

Why do we collect this information?

Primary purposes of collecting information about students and their families

Our school collects information about students and their families when necessary to:

·         educate students

·         support students’ social and emotional wellbeing, and health 

·         fulfil legal requirements, including to:

·         take reasonable steps to reduce the risk of reasonably foreseeable harm to students, staff and visitors (duty of care)

·         make reasonable adjustments for students with disabilities (anti discrimination law)

·         provide a safe and secure workplace (occupational health and safety law)

·         enable our school to:

·         communicate with parents about students’ schooling matters and celebrate the efforts and achievements of students

·         maintain the good order and management of our school 

·         enable the Department to:

·         ensure the effective management, resourcing and administration of our school

·         fulfil statutory functions and duties 

·         plan, monitor, regulate and evaluate the school’s policies, services and functions

·         comply with reporting requirements

·         investigate incidents in schools and/or respond to any legal claims against the school, including any of its employees.

Primary purposes of collecting information about others

Our school collects information about staff, interns and job applicants:

·         to assess applicants’ suitability for employment or studentship.

·         to administer employment or  placement of a student

·         to fulfil various legal obligations, including employment and contractual obligations, occupational health and safety law and to investigate incidents

·         to respond to legal claims against our school.

When do we use or disclose information?

Our school uses or discloses information consistent with POPIA privacy law, as follows:

1.      for a primary purpose – as defined above

2.      for a related secondary purpose that is reasonably to be expected – for example, to enable the school SMT to fulfil its objectives, functions and powers

3.      with notice and/or consent – including consent provided on enrolment and other forms (the information collected will not be disclosed beyond the Department of Education and without consent, unless such disclosure is lawful)

4.      when necessary to lessen or prevent a serious threat to:

·         a person’s life, health, safety or welfare

·         the public’s health, safety or welfare

5.      when required or authorised by law – including as a result of our duty of care, anti-discrimination law, occupational health and safety law, child wellbeing and safety law, reporting obligations to agencies such as the Department of Health and Department of Social Development, complying with court orders, subpoenas or search warrants

6.      to investigate or report unlawful activity, or when reasonably necessary for a specified law enforcement purpose, including the prevention or investigation of a criminal offence or seriously improper conduct, by or on behalf of a law enforcement agency

7.      for Departmental research or school statistics purposes

8.      to establish or respond to a legal claim.

A unique school identifier student number is assigned to each student to enable the school to carry out its functions effectively.

Student transfers

When a student has been accepted at, and is transferring to, another school, and our school transfers information about the student to that school. This may include copies of the student’s school records, including any health information, cumulative records, disciplinary record testimonial letter, and current end of term report and or confirmation of payment letter when requested by the receiving school.

This enables the next school to continue to provide for the education of the student, to support the student’s social and emotional wellbeing and health, and to fulfil legal requirements.

Responding to complaints

On occasion, our school and Circuit offices receive complaints from parents and others. Our school will use and disclose information as considered appropriate to respond to these complaints (including responding to complaints made to external organisations or agencies).

Accessing your information

All individuals, or their authorised representative(s), have a right to access, update and correct information that our school holds about them through the school information update form which is obtainable from the school office upon request at any time of the year.

Access to student information

Our school only provides school reports and ordinary school communications to parents who have a legal right to that information. Requests for access to other student information must be made in writing. In some circumstances, an authorised representative may not be entitled to information about the student. These circumstances include when granting access would not be in the student’s best interests or would breach our duty of care to the student, would be contrary to a mature minor student’s wishes or would unreasonably impact on the privacy of another person.

Access to staff information

School staff may first seek access to their personnel file by contacting the principal. If direct access is not granted, the staff member may request access through the Director of the institution.

Storing and securing information

Our school takes reasonable steps to protect information from misuse and loss, and from unauthorised access, modification and disclosure. Our school stores all paper and electronic records securely, consistent with the Department’s records management policy and information security standards as well as informed by POPIA issued by the Government of South Africa. All school records are disposed of, or transferred to the School Archives, as required by the School storage and destruction of information Policy in line with the Department’s regulations on the storage and destruction of school records.

When using software and contracted service providers to manage information, our school assesses these according to the appropriate departmental and school processes. One example of this is that staff passwords for school systems are strong and updated on a regular basis, consistent with the school’s password policy. Learner Files holding Records are kept in the school office in cardboards that are always locked and only persons with authority to see the information have access to the files holding learner personal information. Any staff member who wants to have access to the learner files should seek permission from the Principal first. Only the administration staff have access to learner when carrying out their responsible daily duties in serving the needs and interest of the learner and or when updating any new information or when serving and checking any records for a parent.

Staff files will be kept in the office of the Principal. No one is allowed to have any access to the file other the Principal and Director of the school. Any member of the staff can request their file from the principal for the purpose of updating any information. No staff shall be allowed to get a file that is not theirs for whatever reasons. The files shall be kept in a lockable cupboard and only the Principal shall have the keys to the cupboard holding the files with personal information of members of staff.

Updating your information 

We endeavor to ensure that information about students, their families and members of staff is accurate, complete and up to date. To update any information in the records kept by the school, please contact our school Admin office.

BY SMT.