Privacy assessment of cashless catering in East Lothian

Dear Sir or Madam,

The "Cashless Catering" leaflet [1] on the East Lothians website
describes the introduction of smartcards for catering in schools.
The leaflet states that most pupils have been issued with
smartcards and then states:

"If you haven’t got a card, or have lost your old one, don’t worry
– you’ll get the chance to apply for one again before cashless
catering is introduced. After that, your Smartcard will be the only
way to pay for food in school."

At the end of the leaflet, readers are referred to a website [2]
for further information, which makes clear that these cards are
part of the Scottish National Entitlement Scheme.

This directly contradicts an answer given by the Cabinet Secretary
for Finance, John Swinney, in the Scottish Parliament [3].

Accordingly, please tell me:

1) whether any legal advice was taken before deciding to implement
this system; 2) whether a privacy impact assessment has been
conducted; and 3) whether the Information Commissioner's Office was
consulted.

I should also be grateful if you would also furnish me with 4) a
copy of any information provided to parents about this scheme.

The requirement that pupils should have a Young Scot card means
that they will have to provide personal data to be uploaded to a
government database. I should therefore be grateful if you would
tell me 5) the minimum amount of personal data that a pupil may
provide to successfully apply for that card, and provide me with 6)
a comprehensive list of every person and/or agency that may then
obtain access to that data.

Yours faithfully,

Dr. Geraint Bevan

NO2ID Scotland

[0] Cashless Catering leaflet:
http://www.eastlothian.gov.uk/documents/...
Catering leaflet-10014.PDF

[2] http://www.eastlothian.gov.uk/smartcards

[3] http://www.scottish.parliament.uk/busine...

Margaret Smith (Edinburgh West) (LD): To ask the Scottish Executive
whether any local authorities or individual schools have made it
compulsory for students to use a Scottish national entitlement card
to access school meals.

(S3W-13320)

John Swinney: The national entitlement card is not compulsory.

Local authorities and schools who use the card to access school
meals must also provide an alternative method to access the service
for those students who do not wish to carry a card. Alternatives
include the use of a PIN number, use of name, class, etc.