All schools will need to appoint a Data Protection Officer (DPO) by the 25th May 2018. The role should cover the following
- To inform and advise the organisation and its employees about their obligations to comply with the GDPR and other data protection laws.
- To monitor compliance with the GDPR and other data protection laws, including managing internal data protection activities, advise on data protection impact assessments; train staff and conduct internal audits.
- To be the first point of contact for supervisory authorities and for individuals whose data is processed (employees, customers etc).
There are a number of options for filling the roll including creating a specific post, school clustering to share a DPO, including the role within the remit of a member of a School’s SLT or even Governing Body. The Head Teacher could also take on the role.
The one area where the DPO should not be held in, is ICT as this would create independence issues.
I have advised Schools that whilst the role needs to be assigned by the 25th May, I would want to try and keep some flexibility and not commit to significant additional resource, so a temporary arrangement may be appropriate whilst the GDPR beds
Currently the Council will not be providing a DPO role for Schools either permanent or temporary as there is not the resource to do so and a significant financial risk if Schools choose alternative arrangements.
The Information Governance Team does provide a Schools Information Governance Traded Service which about 30 schools subscribe too. We have extended last year’s membership fees to cover advice and further training up until the end of this Summer Term.
We will probably run a further training course on the GDPR including what the DPO needs to do. We are willing to allow other schools to join the Service if they wish to for a fee. Schools are of course free to seek their information governance advice from
other suppliers if they wish to. If the current or new subscribers wanted to continue with this advice service in future years we would be willing to extend this if there were sufficient numbers.
Please see the link below for the toolkit for schools.