These resources help us meet the UK GDPR Accountability Principle.
Record of Processing Activities (RoPA): [Upload/Link to your Information Asset Register.]
Data Protection Impact Assessment (DPIA) Guidance: [Upload a guide and template for when a DPIA is required.]
All organisations processing personal data must register and pay an annual fee to the ICO.
A DPIA is a mandatory, systematic process required by the UK GDPR to help us identify and minimise data protection risks before we start a new project or activity.
It is a legal requirement to conduct a DPIA when introducing a type of processing that is "likely to result in a high risk" to the rights and freedoms of individuals (pupils, parents, or staff).
A DPIA is essentially a documented, pre-emptive review that asks:
What data are we using?
Why are we using it? (The purpose and lawful basis)
What are the risks if this data is compromised?
How can we reduce or eliminate those risks? (Mitigation)
You must complete a DPIA before starting any new project or introducing new technology that involves:
New Large-Scale Monitoring: Such as the introduction of new CCTV, body-worn cameras, or large-scale video conferencing platforms.
New Biometrics: Introducing fingerprint or facial recognition for school dinners, library access, or registration.
Processing Sensitive Data: Introducing a new system for handling large amounts of special category data (like health or safeguarding information) or data about vulnerable individuals (like children).
New Technology: Using innovative technologies that involve tracking, profiling, or automated decision-making on pupils or staff.
If in doubt, assume a DPIA is required and contact the DPO. The DPO will review your proposal and confirm the necessary steps.