Dear St Ambrose Barlow RC High School, Manchester,
I understand the below response to be a reply to an earlier Freedom of Information Request about St Ambrose Barlow RC High School's biometric system.
St Ambrose Barlow RC High School is the first school that I am aware of, and after speaking to the Information Commissioner's Office they too are not aware of another situation, of a school acting as an agent for a Facility Management provider obtaining parental consent in order for an Facility Management provider to store and process children's biometric data.
Therefore under the Freedom of Information Act 2000 please could you supply the following information within 20 working days.
St Ambrose Barlow RC High School's response to a previous Freedom of Information request:
"I do wish to point out that this school holds no biometric data of the pupils; the system was bought by and is managed by the BSF PPP Facility Management Company.
We neither own the system nor have access to it.
Where we have no recorded information we will only provide the following statement: You can ask for any information you think a public authority may hold. The right only covers recorded information which includes information held on computers, in emails and in printed or handwritten documents as well as images, video and audio recordings.
We are under no obligation to provide information relating to conversations, nor on the biometric system itself, which has been neither gifted to us nor is our property or personal responsibility. We have acted as an agent for the FM provider in obtaining parental/guardian permission for their children to provide their biometric data, whilst respecting their right to opt for the PIN code alternative. This is the only involvement we have has as a school."
1) Please give the name of the Building Schools for the Future (BSF) Private Public Partnership (PPP) Facility Management (FM) Company.
2) In the above text it states that “this school holds no biometric data of the pupils”.
i) if this is meant in a physical context in that no child’s electronic or otherwise biometric data is held on school premises. Please advise yes or no to this question or
ii) advise if a child’s electronic or otherwise biometric data is held on school premises and is not the property of the school.
iii) If the answer to question ii) is that children’s biometric data is held on school premises and is not the property of the school please advise who St Ambrose and Barlow School understands is the owner of the children’s biometric property.
3) Who does St Ambrose Barlow understand to be the Data Controller of the biometric database that the school states is “not our property”? i.e. who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. See http://ico.org.uk/for_organisations/data...
For example who determines if a pupil’s data is removed or added to the system.
4) Who does the school understand to processes the data? The school or the BSF PPP FM Company?
5) Who does the school understand to have access to the biometric system?
6) Please advise when the school informed parents that the school was gaining consent, to process their children’s biometric data, on behalf of the BSF PPP FM Company.
7) Please advise if the school has ever informed parents that their children’s biometric data is not the property of the school, that the school takes no responsibility for children’s biometric data, the school does not manage or have access that the biometric system.
8) Please provide copies of the literature or any communication that has been sent to parents related to the biometric system. Please include any communication detailing that the school was acting in capacity as an agent for the BSF PPP FM Company.
9) Please supply any other databases or data gathering information that St Ambrose and Barlow School act in capacity as an agent of where the school considers that children’s data “nor is our property or personal responsibility”
10) Please supply the privacy impact assessments carried out or any communication or dialogue with the Information Commissioner’s Office St Ambrose and Barlow School have had regarding to the provision as acting s an agent for possible storage, security, liability, communication and processing of children’s biometric data on behalf of third party.
11) Is the Information Commissioner’s Office aware that St Ambrose Barlow school is acting capacity as an agent gaining consent from parents of children attending St Ambrose and Barlow for the BSF PPP FM Company?
12) Does a contract exist for the school’s agency work for the BSF PPP FM Company? If so please provide a copy.
13) Please advise if the school has taken any advice regarding security of the BSF PPP FM Company’s biometric database?
14) Please advise if the school has taken any advise on liability of the situation the school is in with regards to children’s biometric data?
15) Please supply any details of recorded information on computers - including emails, printed or handwritten
documents, images, video or audio recording where any discussion - of the school acting as an agent for the biometric database/collection of children’s biometric data on behalf of the BSF PPP FMC is logged.
i) If there is no recorded information please advise any known verbal conversations on this matter and if St Ambrose Barlow School are able, to provide detail of this.
ii) If the school has no record whatsoever who does the school understand to have made this decision of the school acting as an agent.
16) Please advise how many children are on the school role, as of the date of answering this Freedom of Information request and how many children's biometric data is on the Facility Management provider's biometric database. If you are unable to provide this data please advise why.
If you need further clarification, please contact me by email. My preferred format to receive the information is electronically, but I can accept hard copies.
Some parts of this request may be easier to answer than others and in such case please could you release available data as soon as possible rather than delay the entire request.
If the costs of processing this request exceed the limit in the Act, please advise on what information you are able to supply within the cost limit.
If you are not fully certain of what it is I am asking then I look forward to contact from you as soon as possible to clarify what it is I am requesting in order for you to meet your obligations under the law
I look forward to your response within 20 working days, as outlined by the statute.
Please find our responses below to your FOI request.
We are unable at the present time to provide two pieces of information that you have requested (Literature & Pupils currently on the Biometric Database< until the school re-opens in September 2013.
Malcolm Walker FCMI, MInstAM
St Ambrose Barlow RC High School
37 Ash Drive
Tel: 0161 921 1584
Fax: 0161 921 1590
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