Who we are

Portsmouth City Council (“the Council”, “we”, “us”) is the data controller for the personal information described in this notice. We are registered with the Information Commissioner’s Office (ICO), registration number Z5578313.

This is a service‑specific privacy notice. It should be read alongside the Council’s corporate privacy notice, which provides general information about how we process personal data across all services.

Who this notice applies to

This notice applies to:
  • Children and young people who are educated at home (elective home education)
  • Parents, carers, or others with parental responsibility who contact or engage with the Elective Home Education (EHE) service

What personal information we collect

We collect and process personal information to carry out our statutory duties relating to elective home education. This may include:
  • Identity and contact details: name, address, date of birth, contact details of the child and parent/carer
  • Education information: details of previous or current schools attended, education history, and information relating to the provision of education at home
  • Characteristics: such as ethnicity and first language (where relevant)
  • Special educational needs and disabilities (SEND): including information about additional needs or relevant medical information
  • Safeguarding information: such as details of professional involvement or court orders, where necessary
  • Evidence of suitable education: information provided to demonstrate that a child is receiving a suitable, efficient, full‑time education
This may include special category personal data, which we handle with additional safeguards.

Why we use your information and our lawful bases

We use personal information to:
  • Meet our statutory duties in relation to children educated at home
  • Establish whether a suitable and efficient full‑time education is being provided
  • Provide advice, guidance and support to families who elect to educate their children at home
  • Safeguard and promote the welfare of children and young people
  • Respond to complaints, concerns, or legal requirements
  • Produce anonymised statistics to help plan and improve services
Our lawful bases under the UK General Data Protection Regulation (UK GDPR) are:
  • Article 6(1)(c) – processing is necessary to comply with a legal obligation
  • 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
Where we process special category personal data, the additional lawful bases include:
  • Article 9(2)(g) – substantial public interest, including safeguarding of children and individuals at risk
  • Article 9(2)(h) – health or social care purposes
We also process information in line with duties placed on local authorities by the Department for Education.

Who we share information with

We only share personal information where the law allows and where it is necessary. This may include sharing with:
  • Other Council services, such as children’s social care or special educational needs services
  • Education providers or professionals, where relevant
  • Health, safeguarding, or law enforcement agencies, where there is a legal requirement or safeguarding concern
  • The Department for Education, where required by law
We do not sell personal information or use it for marketing purposes.

How long we keep your information

We keep personal information only for as long as necessary to fulfil the purposes for which it was collected and in line with the Council’s corporate retention schedule. Retention periods are determined by legal, regulatory, and safeguarding requirements.

How we keep your information secure

We take appropriate technical and organisational measures to protect personal information. This includes:
  • Secure IT systems and controlled access
  • Staff training on data protection and confidentiality
  • Policies and procedures designed to protect information from loss, misuse, or unauthorised access

Your data protection rights

Under data protection law, you have rights including:
  • The right to access your personal data
  • The right to request correction of inaccurate or incomplete data
  • The right to request erasure or restriction of processing, in certain circumstances
  • The right to object to processing, where applicable
Some rights are not absolute and may depend on our legal duties, particularly where safeguarding children is concerned.

How to contact us or make a complaint

If you have a complaint or query about how we collect and use personal information, if you would like a change to be made to your record, or want to object to processing, please contact us using the details above.

If you are not satisfied with our response, you can complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)