Impact of the Universal Free School Meals Policy – Privacy Notice (Department for Education data)

Who is undertaking this research project?

The research project is being undertaken by a research team based in the Institute of Social and Economic Research (ISER) within the University of Essex

Institute of Social and Economic Research,
University of Essex,
Wivenhoe Park,
Colchester,
Essex CO4 3SQ

Web: https://www.iser.essex.ac.uk

The University of Essex is registered as a data controller with the Information Commissioner’s Office (Registration Number: Z699129X).

The Data Protection Officer contact for the University of Essex is;

Data Protection Officer
University of Essex
Wivenhoe Park
Colchester
CO3 4SQ
dpo@essex.ac.uk

What are the purpose(s) for which data are being processed within this research project?

This project is funded by the Nuffield Foundation, to evaluate the effects on age 11 educational attainment, and attendance rates at school throughout primary school, of the Universal Free School Meal programmes implemented by Local Authorities in England since 2004.

Under the General Data Protection Regulation (GDPR), a legal basis is required for processing of personal data. The legal basis under which data is processed within this project is:

Article 6 (1) (e) – “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”

Processing of data concerning gender and ethnicity (and other ‘special categories’ of data) requires the fulfilment of an additional condition under GDPR. The specific condition fulfilled by the processing of such data within this project is:

Article 9 (2) (j) – “processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.”

When relying on this condition for processing special categories of personal data, an organisation must determine which condition of the Data Protection Act 2018, Schedule 1 Part 1 supports that processing. For this project that will be Condition 4 as the data will be processed for Scientific Research.

For further information, see: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/

Which sources of data are being used by this research project?

Individual-level data on Primary school children’s characteristics and demographic background, and their educational attainment and absences from school.

How is the data being collected within this research project?

All data has been collected by the Department for Education, through a combination of administrative returns made by schools and exam boards. No new primary data is being collected.

What categories of data will be obtained from these sources?

The project will obtain specific data from the National Pupil Database. The data that will be obtained has been identified by the research team as necessary and sufficient to robustly answer the research question.

The following data will be obtained:

National Pupil Database

For students in school years Reception to Year 6, for the 1995/96 to 2018/19 academic years:

  • Performance in Early Years Foundation Stage Profile, Key Stage 1 and Key Stage 2 assessments.
  • Counts of absences from school, by reason, by academic year.
  • Individual characteristics including: Sex, ethnicity, Free School Meal entitlement, English as an Additional Language, Lower Super Output Area of residence.
  • Local Education Authority and School identifier

More information can be found here: https://www.gov.uk/government/collections/national-pupil-database

Will my data be used by the research project?

It is impossible for the Project Team to determine if your data is included within the secondary data provided to us by DfE since these data are functionally anonymised and in the case of School Workforce Census, provided at the school level. ISER can not identify any living individual from the data provided by DfE.

Data will be used to produce statistical summaries and models, from within the ONS Secure Research Service. All results requested from the Service are checked to ensure there is no risk of disclosure, before being released to researchers.

Can I opt-out of the use of my data by the research project?

ISER have no way of knowing who is included within the data sets supplied to us by DfE since all data are functionally anonymised when we receive them. You cannot therefore opt out of this project by contacting ISER. There are no provisions to opt out of NPD or School Workforce Statistics data.

How will my privacy be protected?

The project will use anonymised data for analysis purposes. This means that no identifiable data, such as name and address, will be included in the data obtained by the research team at the University of Essex. The data requested are necessary and sufficient to build a statistical model to estimate the effect of Universal Free School Meal programmes on children’s absences and educational performances.

All data received at the University of Essex will be securely stored within an infrastructure that is certified to the Internationally agreed standard for Information Security (ISO27001:2013), and will be managed in accordance with the Data Sharing Agreements that govern the use of the data obtained from the different sources. Access to the data will be restricted to a small number of named and approved members of the research team.

What are my rights in relation to the data?

The General Data Protection Regulation provides the following rights for individuals in relation to their personal data:

The right to be informed
The right of access
The right of rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling

For further information, see: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

A summary of these rights and their applicability in respect of this project is provided in the table below.

RightApplies to this project ?Rationale
The right to be informedYesDetails regarding the project and its use of data are provided within this privacy notice.
The right of accessNoThe research team are unable to determine the data that relates to a specific data subject.
The right to rectificationNoThe research team are unable to determine the data that relates to a specific data subject.
The right to erasureNoThe research team are unable to determine the data that relates to a specific data subject.
The right to restrict processingNoThe research team are unable to determine the data that relates to a specific data subject.
The right to data portabilityNoThe research team are unable to determine the data that relates to a specific data subject.
The right to objectNoThe research team are unable to determine the data that relates to a specific data subject.
Rights in relation to automated decision making and profilingNoThe research team are unable to determine the data that relates to a specific data subject.

Will my data be transferred to any organisations outside of the University of Essex?

No data be transferred outside of the University of Essex.

How long will my data be retained by the research project?

Data will be retained by the research team until 31/10/2023 to facilitate the publication of reports.

What approvals have been obtained by the research project?

The research project has successfully obtained:

Ethical approval from the University of Essex ethics committee.

What if I have further questions?

The Data Controllers for the National Pupil Database, the Data Sharing and Data Platform Services Unit at the Department for Education, may be contacted at data.SHARING@education.gov.uk

Additionally, any queries or concerns regarding the processing of personal data can be made to the Information Commissioner’s Office https://ico.org.uk

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