This privacy notice explains how Portsmouth City Council collects, uses and protects personal information about school staff.
Portsmouth City Council is the Data Controller for the personal information described in this notice.
This notice explains:
- What personal information we collect
- Why we use it and our lawful basis
- Where we get it from
- Who we share it with
- How long we keep it
- How we keep it secure
- Your rights and how to contact us
For information about the wider categories of personal information processed by the Council, please see the Council's Data Protection Privacy Notice.
Who we are and how to contact us
Data Controller: Portsmouth City Council
Address: Civic Offices, Portsmouth, PO1 2AL
Information Governance Team:
Email: dataprotection@portsmouthcc.gov.uk
If you have questions about this notice or would like to exercise your data protection rights, please contact the Information Governance Team.
Who this notice applies to
This notice applies to employees and members of the school workforce whose information is processed by Portsmouth City Council.
The personal information we collect
The categories of school workforce information we process include:
- Personal information (such as name, employee number, teacher number and National Insurance number)
- Characteristics information (such as sex, age and ethnic group)
- Contract information (such as start date, hours worked, post, role and salary information)
- Work absence information (such as absences and reasons for absence)
- Qualifications and, where relevant, subjects taught
- Relevant health information, including disabilities and special needs
- Address details and payroll information
This list is not exhaustive. For the current categories of information we process, please see the Council's Data Protection Privacy Notice.
Where we get your information from
We collect personal information from:
- Employment contracts
- Recruitment and application forms
- Payroll systems
- Information provided directly by employees
- Verbal information collected for workforce census purposes where required
Workforce data is essential for the Council's operational requirements.
Whilst much of the information provided is mandatory, some information is collected on a voluntary basis. Where this applies, we will explain whether providing information is optional or required.
How we use your information and our lawful basis
We use workforce information to:
- Develop a comprehensive understanding of the workforce and how it is deployed
- Inform recruitment and retention policies
- Administer payroll and salary payments
- Maintain sickness records and manage absences
- Monitor equal opportunities
- Provide support for disabilities and special needs
Lawful bases under UK GDPR
For general employment purposes, the lawful basis is:
Article 6(1)(b) UK GDPR
Processing is necessary for the performance of a contract or to take steps before entering into a contract.
For statutory workforce reporting and data collections, the lawful basis is:
Article 6(1)(c) UK GDPR
Processing is necessary for compliance with a legal obligation.
For workforce planning purposes, the lawful basis is:
Article 6(1)(e) UK GDPR
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
Special category personal data
Where special category personal data is processed, one or more of the following conditions may apply:
Article 9(2)(a) UK GDPR
The data subject has given explicit consent.
Article 9(2)(b) UK GDPR
Processing is necessary to fulfil obligations and rights relating to employment, social security and social protection law.
Article 9(2)(h) UK GDPR
Processing is necessary for occupational health, assessing working capacity, medical diagnosis, health or social care, treatment, or management of health and social care systems and services.
Who we share your information with
We routinely share workforce information with:
- Department for Education (DfE)
- Ofsted, where required for inspection purposes
We do not share information about school workforce members unless there is a lawful basis to do so.
The Council shares workforce data in order to:
- Meet statutory workforce census requirements
- Provide payroll and workforce services
- Support school workforce administration and reporting
The Council is required to share school workforce information under section 5 of the Education (Supply of Information about the School Workforce) (England) Regulations 2007 and associated amendments.
Fraud prevention
The Council has a duty to protect public funds.
Information may be used for the prevention and detection of fraud and may be shared with organisations responsible for auditing or administering public funds.
Further information can be found by searching for "National Fraud Initiative" on the Portsmouth City Council website.
Department for Education (DfE)
The Department for Education collects personal data from schools and local authorities through statutory data collections.
The Council is required to provide workforce information for the School Workforce Census under sections 113 and 114 of the Education Act 2005.
Data is transferred securely and held by the DfE in accordance with the Government Security Policy Framework.
How the DfE uses your information
Data shared with the DfE helps to:
- Inform education workforce policy and pay
- Monitor workforce effectiveness and diversity
- Support school funding analysis
- Support educational research and policy development
Further sharing by the DfE
The DfE may share information with approved third parties where this is lawful, secure and in the public interest, including for:
- Research and analysis
- Production of statistics
- Information, advice and guidance
Any sharing is subject to strict approval, information security requirements and legal safeguards.
Further information is available through the DfE's published data sharing information.
How long we keep your information
We retain information only for as long as necessary and in accordance with the Council's Corporate Retention Schedule.
For more information, see the Council's retention schedule.
How we keep your information secure
The Council stores workforce information securely and applies appropriate technical and organisational safeguards to protect personal information.
These measures include:
- Access controls
- Secure systems and storage
- Staff training
- Information governance controls
- Data retention and disposal procedures
Your data protection rights
Under UK data protection law, you have rights which may include:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (in certain circumstances)
- The right to restrict processing
- The right to object to processing
- Rights relating to automated decision-making and profiling
- The right to withdraw consent where consent is the lawful basis
Some rights may be limited depending on the lawful basis being used for processing.
For example:
- The right to erasure does not generally apply where processing is required by legal obligation or public task.
- The right to data portability does not generally apply where processing is based on legal obligation, public task, vital interests or legitimate interests.
- The right to object does not apply where processing is necessary for a contract, legal obligation or vital interests.
Requesting access to your information
To request access to your personal information, contact:
Information Governance Team
Email: dataprotection@portsmouthcc.gov.uk
You also have the right to complain to the Information Commissioner's Office (ICO) if you believe your information has not been handled correctly.
Complaints
If you have concerns about how your personal information is being used, please contact Portsmouth City Council in the first instance.
You can also raise concerns with the Information Commissioner's Office (ICO).
How to contact us
Information Governance Team
Portsmouth City Council
Email: dataprotection@portsmouthcc.gov.uk
Changes to this privacy notice
We may update this privacy notice from time to time.
Last updated: 31 October 2024