Pupil data: Children not in education

The request was successful.

Dear Oldham Metropolitan Borough Council,

This FOI request is for information that is processed about "children not in education".

It is in regards to existing practice on recording and retaining personal data at individual named child level, whether data is collected on a voluntary basis from the person, or otherwise.

For Question one, 1.1 to 1.4 , and in order to make it easy to respond, we expect a yes/no answer only for each scenario. For question 1.5 please explain if necessary in free text.

Question two may be met by providing a copy of a Data Protection Impact Assessment for each relevant dataset.

For Question three, we expect a yes/no answer; and/or the register name.

Question four does not ask for personal details.

If it is helpful to see how this was answered by another council, for reference, please see https://www.whatdotheyknow.com/request/p...

Thank you.
Jen Persson

Child (anyone aged under 18)
Records (data in any digital format, ie. spreadsheets, databases etc)
Educational setting (Any provider of state funded education: nursery, infant, primary, secondary, FE, AP, Hospital school, YOI etc)

Q1. On what grounds is a child’s personal data processed in or on behalf of the Council
1.1 When a child is deregistered
a. To receive an education otherwise than at school
b. Due to permanent exclusion
c. Due to unauthorised and unexplained absence (authorised absence plus ten days or 20 days) for which reasonable enquiries have been unable to resolve
d. To move from state into independent (private) education
e. To move out of independent (private) education to anything else

1.2 When the destination from the following is unknown
f. Nursery
g. Alternative provision
h. Custody
i. Post-16 education

1.3 When the authority becomes aware of
j. A child being educated otherwise than at school
k. A child about whose education there is nothing known
l. A child whose parents the authority considers to be failing to provide a suitable education

1.4 When the authority has children in its geographical area that may be passing through but not in education
m. child born outside England
n. a child of a service family (army, navy etc)
o. a child of a family without permanent address

1.5 Please provide any other circumstances or grounds in which the authority becomes aware of children not in education, about which they may make a record, for any other reason not listed.

Q2. About the databases or registers currently processed.
For each scenario and/or separate records used, please provide
a. the relevant Data Protection Impact Assessment
b. If no DPIA exists, the name/title of the database/spreadsheet used.
c. If no DPIA exists, the field names (ie which data items may be collected)
d. If not listed in the DPIA or none exists, please state on which legislation does each data collection rely? i.e The Children Act 1989, Duty to identify ‘Children Missing Education’ (s436a Education Act 1996), Education (Pupil Registration) Regulations (England) 2006, Children Missing Education Statutory guidance for local authorities 2016, the Elective home education: departmental guidance for local authorities 2019 or state which if something else.)
e. The numbers of individuals in each database as of June 30, 2021.
f. The numbers of individuals in each database who are children on June 30, 2021.
g. The earliest record start date that is still retained by the authority for any of the above (i.e what is the oldest record currently processed includes those who may no longer be children)
h. where children are listed as ‘unknown’ (at any age including post-16 in Youth Employability Services) what data sources are used to create a record or make an intervention? (ie Revenue and Benefits data, Pre 16 Risk of NEET Indicator, UCAs, social media etc)

Q3. Does the Local Authority maintain a record of other parties to whom such data has been distributed or shared?

Q4. Where does responsibility (Job title, Department no personal details requested) for
a) processing and b) the oversight of the above processing sit?

Information Manager, Oldham Metropolitan Borough Council

Ref: FOI 16615

Good afternoon,

We acknowledge with thanks your application for information, which has been considered as a request under the Freedom of Information Act 2000.

As such, this may take up to 20 working days to be processed and has been passed on to an appropriate officer.

Please note as a result of the COVID-19 pandemic, Oldham Council is still currently handling a large volume of business-critical work, aimed towards the continued protection and safeguarding of its residents. As such you may experience a delayed response from the business area handling your request to which we apologise in advance.

Also please be aware that in certain circumstances an exemption may apply to the information that you have requested. This also includes the possible requirement of the statutory period to supply a response, being extended in accordance with the Act.

Should you have any queries, please contact:  [Oldham Council request email]

Kind regards

Information Management Team
Oldham Council
Civic Centre
West Street

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Anne Clark, Oldham Metropolitan Borough Council

2 Attachments

Good Afternoon


Please find attached the response to your recent freedom of information


Kind Regards





Anne Clark

Inclusion Manager

Oldham Council

Level 8




Mobile – 07811720835

0161 770 6630

[email address]



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