Fair Processing Notice

The Headteacher in the name of Bunscoill Rhumsaa as Data controller

The Headteacher, in the name of Bunscoill Rhumsaa, is a data controller for the purposes of the Data Protection Act 2002/General Data Protection Regulation (Isle of Man) Order 2018. The contact details for the Data Controller are Bunscoill Rhumsaa of Lezayre Road, Ramsey, Isle of Man IM8 2PA.

In addition to the information set out in the Isle of Man Privacy Notice, we may also collect the following information about your child as required by the Education Act 2001 and the Registration of Pupils Regulations 2016:

  1. full legal name and where known, any former name or names;
  2. gender;
  3. date of birth;
  4. unique pupil number;
  5. ethnic group and by whom that information was provided;
  6. first language;
  7. date of admission to the school;
  8. year group;
  9. the address and postcode of the pupil's usual residence and any other properties at which the pupil is also known to reside on occasion;
  10. the name and address of every person known to the school to be a parent of the pupil and at least one emergency contact telephone number;
  11. the name and address of any other schools the pupil is known to have attended, if any, and in the case of guest registration, any other schools at which the pupil is registered;
  12. full-time or part-time;
  13. day pupil or boarder;
  14. date of leaving the school;
  15. usual mode of transport to and from school;
  16. for any pupil who is known to the head teacher to be or to have been looked after by an appropriate organisation, the name of that organisation;
  17. (where applicable) that the pupil has been found eligible for free school meals;
  18. Attendance;
  19. Medical information for the vital interests of children where appropriate;
  20. Educational psychologists reports and supporting documents;
  21. Academic achievements;
  22. Skills and abilities;
  23. Educational progress;
  24. Special educational needs information;
  25. Suspension information;
  26. Course information;

The Data Protection Officer for the Department of Education, Sport and Culture is: Andrew Shipley, Department of Education, Sport and Culture, Hamilton House, Douglas. IM1 5EZ. Tel 01624 685828. Email: DPO-DESC@gov.im.

How we will use the information we collect about you

Bunscoill Rhumsaa may use your information to:

  • register your child at the school;
  • record attendance information;
  • produce an educational record containing:
    • Information about your child
    • Personal education plans
    • Educational psychologist's reports and accompanying documents
  • produce a curricular record containing:
    • Academic achievements;
    • Skills and abilities; and
    • Educational progress
  • produce a record of special educational needs and special needs provision, if appropriate detailing:
    • The type of special need;
    • A ranking of the special needs if there is more than one;
    • The special needs provision being made; and
    • Whether teaching is in a special education needs unit or elsewhere
  • record details of suspensions
  • produce a record of the studies undertaken;
  • help prevent and detect crime

Bunscoill Rhumsaa has a statutory obligation to check and verify the data you provide to us on registration documents and on consent forms. This may include checks of publicly available information but in some cases, where it is necessary and relevant, the information you provide may be disclosed or shared with other organisations.

How we will share the information we collect about you

App or Service Details Consent Required


more information

Data Shared: Pupil record

Sharing Basis: No - Public interest +official authority of the DC

Security Protocols:
Arbor uses bank-grade, end-to-end, 256bit SSL encryption to ensure only the authorised user can see school data. Student data is NEVER shared with third parties without a schools’ consent.  Each user is issued with a unique and secure password, with permission-based access ensuring that they can only view the data relevant to them. No data is stored on any device, and Arbor automatically logs out after a period of inactivity.  Arbor is a Data Processor and abides by all of the terms of the Data Protection Act 1998. Arbor are also registered with the UK Government on the G-Cloud VII framework, a Government framework which audits the security of cloud-based providers to ensure they meet government standards. Arbor products have also been approved by the Department for Education list for cloud suppliers.

Access Conditions: N/A

Teacher Access: N/A

Server/Data Location: EEA 

Retention Period: DOB +25 years


DESC Attendance

Data Shared: Name, School, Attendance data if less than 80%

Sharing Basis: Public interest + official authority of the DC

Security Protocols: Secure access or information sent by email password protected

Server/Data Location: EEA

Retention Period: As needed while resolving issues


Education City

more information

Data Shared: first name, last name, username, password and class, with unique ID, academic level, date of birth and gender as optional fields

Sharing Basis: This information is shared to allow for accurate tracking of pupils learning activity and output when using Education City.

Security Protocols:
All remote access to any web applications provided by EducationCity Ltd is conducted over HTTPS, an encrypted web link secured using TLS (Transport Layer Security). This is the same method used by banks and commercial entities to secure sensitive data from interception.

Access Conditions: Supervised (in school) and Unsupervised (at home)

Teacher Access: Yes, to monitor pupil progress and set relevant learning or assessment activities.

Server/Data Location: EducationCity stores data on secure database servers, located in the UK.

Retention Period:
EducationCity stores data for its users. To ensure that EducationCity does not hold user information in perpetuity, it has set criteria for the deletion of unused data. This information will be deleted daily.

EducationCity holds data for Teacher, Student and Admin user accounts. If these accounts are left inactive for two years they will be deleted. The definition of inactive is if the user has not logged in (via any route) for two years.
Any saved score data will be deleted after five years on a rolling basis. Even if the student is still active, we will only hold five years’ worth of results per child; if more is required, the export data feature should be used. If a student is deleted as a result of being inactive for two years, all score data held for that student is also deleted. Data to be deleted includes Activity, Test/Assessment and PlayLive scores, and Revision Journals.
If a Teacher or Admin user is deleted due to being inactive for two years, or a Teacher or Admin user is deleted via the user interface/front end, then their MyCities become ‘un-owned’. Any MyCities that contain no content will be deleted after two years. No MyCities will be deleted for an active user.
Usage Statistics
Usage statistics of EducationCity at school level will be stored in EducationCity’s subscriber management system and will be kept in perpetuity. No personal/user level information can be extracted from this data.



more information

Sharing Basis: To demonstrate children's safety and welfare have been assessed prior to off-site visits to SLT and central DESC staff.

Security Protocols:
Implement additional security measures including advanced firewalls, enterprise-level virus protection on all servers, HTTPS encryption for all communication between our servers and users, regular data backup, username/password/PIN to control access, failed log-in attempt logging, automatic suspicious activity detection and logging etc.

Access Conditions: Staff only

Teacher Access: Yes, to risk assess and evaluate risk assessments for off-site visits.

Server/Data Location: EEA 


Google Docs

more information

Data Shared: No personal information should be stored on Google servers by staff apart from a name, class grouping, email address and information regarding work completed or to be completed.

Sharing Basis: Collaborative learning by children and home learning. Can be shared with teacher and any other child at DESC school on IOM. re consent - No - Public interest +official authority of the DC

Security Protocols: Google adheres to several self regulatory frameworks, including the EU-US Privacy Shield arrangement.

Access Conditions: No

Teacher Access: Limited to areas set up by staff and shared documents

Server/Data Location: Worldwide including the US

Retention Period: DOB + 21 years or 3 years since the last log on



more information

Data Shared: First name, surname and email address (Google for education)

Sharing Basis: To provide a LMS (Learning Management System) so that children can learn how to maintain a digital profile in a safe environment. Also to facilitate independent and self direct learning with reflection and peer assessment.

Security Protocols:
Physical security Data Centres itslearning operates all its customer services from data centres separated from the corporate office work space. Access to data centres are strictly controlled and protected to reduce the likelihood of unauthorised access, fire, flooding or other damage to the physical environment. Physical access to data centres are limited to a small number of employees within itslearning and/or its hosting centre providers. Strict security clearances are required and must be approved by security management prior to entering a data centre. Office work space All of the office work space of itslearning is protected by access control. Only invited visitors and employees can access itslearning’s work space. Multiple measures are in place to avoid security issues due to theft or loss of computer equipment. This includes security guidelines and acceptable use policies, authentication systems and encryption of storage units when applicable.

Access Conditions: supervised and unsupervised

Teacher Access: To support learning the teacher has access to pupil pages and their posts

Server/Data Location: EEA

Retention Period: While in education at state school. School attendance plus 1 year


Language link / Speech

more information

Data Shared: Name, DOB. email & telephone number of school

Security Protocols: Encryption, access restriction and physical security

Teacher Access: Yes

Server/Data Location: EEA

Retention Period: 3 years


Microsoft Teams

Data Shared:
Census data: AppName, DeviceModel, OSName, OSVersion, UserLanguage, UserID, DeviceID. Census data DOES NOT contain any information that identifies your organisation or users.

Usage data: includes information such as number of calls made, number of IMs sent or received, number of meetings joined, frequency of features used and stability issues. Usage data DOES NOT contain any information that identifies users.

Anyone in a team can see all members of a team, including guests

Sharing Basis: Public interest to assist with remote education during period of school closures.

Security Protocols: Teams enforces team-wide and organization-wide two-factor authentication, single sign-on through Active Directory, and encryption of data in transit and at rest. Files are stored in SharePoint and are backed by SharePoint encryption.

Access Conditions: Supervised and unsupervised.

Teacher Access: Yes

Server/Data Location: EEA

Retention Period: August after pupil leaves school



more information

Data Shared: Name, email address

Security Protocols: Appropriate and suitable safeguards and technical measures are in place to protect your personal data

Access Conditions: Supervised

Teacher Access: Yes

Server/Data Location: Worldwide

Retention Period: End of use + 12 months



Data Shared:
ParentPay obtain (either from the Customer and/or from you directly) and process the following information:

Data Subject (Who) Data Category (What) Description
Pupil Student Forename This is the forename of the pupil.
Pupil Student Surname This is the surname of the pupil.
Pupil Student Known as This is the name that the pupil is known as.
Pupil Student DOB This is the date of birth of the pupil.
Pupil Student Gender This is the pupil’s gender
Pupil Student Groups Registration group (if any), year, other groups
Pupil Student Salutation This is the pupil’s salutation.
Pupil Student Dietary Requirements This is the pupils special dietary requirements
Pupil Student Postal Address The student’s postal address
Pupil Student Identifiers Roll/Admission number, UPN, management system identifier
Pupil Student Meal Selections and spend history This is a history of a pupil’s meal selections and spends for school meals or non-meal-related items, including free school meals
Pupil Student Trip information Trip details collected from parents, e.g. emergency contacts, medical details, dietary requirements, doctor’s contact, EHIC and Passport
Parents Contacts Title This is the contact’s title (Mr, Mrs, Ms, etc).
Parents Contacts Forename This is the contact’s forename.
Parents Contacts Surname This is the contact’s surname.
Parents Contacts Authentication data Username and password, single-sign-or multi-factor-authentication tokens
Parents Contacts Gender The contact’s gender (Salutation)
Parents Contacts House Name The text entered as the contact’s house name.
Parents Contacts Street The text entered as the contact’s street.
Parents Contacts Locality The text entered as the contact’s locality.
Parents Contacts Town The text entered as the contact’s town.
Parents Contacts Postcode The text entered as the contact’s post code.
Parents Contacts Day Telephone The contact’s daytime telephone number.
Parents Contacts Home Telephone The contact’s home telephone number.
Parents Contacts Mobile Telephone This is the contact’s mobile telephone number used to receive alerts from Parentpay and for school communications
Parents Contacts Email This is the contact’s E-mail address used to receive communications from Parentpay and for school communications.
Parents Contacts Payment History and balances This is the contact’s history of payment transactions, including reversals, refunds and withdrawals of funds.
Parents Contacts Payment card details Payment card details are captured and passed to a 3rd party for authorisation.
Parents Contacts Other This is the contact’s alternative communication method.
Parents Contacts In-app messages Messages sent from parents to school within the ParentPay application
Parents Contacts Trouble ticket data When users submit trouble ticket information, this gets stored.
Parents Contacts Shop information ParentPay can be used as a payment page from externally or internally hosted shop systems. This the information captured as part of that (“shopping basket”).
Parents Contacts Browser Details IP address, cookies, browser information
Parents Contacts Scottish UPRN For users in Scotland who sign up via MyGovScot
School Staff Title This is the staff member’s title (Mr, Mrs, Ms, etc.).
School Staff Forename This is the staff member’s forename.
School Staff Surname This is the staff member’s surname.
School Staff Gender The staff member’s gender
Website Access IP Address The network address of your device or internet connection
Website Access Browser Type and Version The type of Web Browser your device is using
Website Access Cookies Special records in your browser to help the website operate
Website Access Web Analytics Generalised information about browsing behaviour and page statistics

Sharing Basis: Schools have signed up for the service and their legal basis is: 'processing is necessary for the performance of a task carried out in the public interest'

Security Protocols:
ParentPay use your personal information, and some of their employees have access to such information, only to the extent required to carry out the services for you and on behalf of the Customer.

ParentPay have introduced appropriate technical and organisational measures to protect the confidentiality, integrity and availability of your personal information during storage, processing and transit.

ParentPay are a Level 1 PCI-DSS certified organisation and are subject to regular and comprehensive security audits. They operate an ISO27001 compliant security programme to help protect your data at all times.

The PPL Products and Services only processes your personal information in the UK.

Some of ParentPay's supporting services (for example ZenDesk), might use cloud platforms that operate from Third Countries outside of the EEA. Where this is the case, they ensure that adequate safeguards are established to protect your data.

Server/Data Location: UK

Retention Period:
ParentPay will only retain information for as long as is necessary to deliver the service safely and securely. They may need to retain some records to maintain compliance with other applicable legislation – for example finance, taxation, fraud and money laundering law requires certain records to be retained for an extended duration, in some cases for up to seven years.

Pupil data will typically be removed or anonymised when the following rules are met:

The pupil has been archived by the School.
The pupil does not have any meal consumption or attendance data within the last 13 months.
The pupil has not received a payment for any payment item within the last 13 months.
The pupil balance is zero.
Payer (Parent) data will usually be removed or anonymised when the following rules are met:

They have not logged in for 13 months.
They have not topped up or spent within the last 13 months.
Parent balance is 0 (zero), and all pupil balances are 0 (zero).
There are no active pupils associated with the account
Manager Accounts that have been disabled and have not logged in for 13 months, will be removed or anonymised. Other school staff accounts are subject to the same rules as pupils (above)

Message attachments will be removed after 24 months.

File area uploads will be purged after 24 months.

Personal information in trip records will be removed 1 month after trip completion

It should be noted that Schools will still retain a complete finance audit trail for their statutory requirements. In unusual cases where specific personal information needs to be retained, then this can be facilitated upon request.


Quesmedia Sites

more information

Data Shared: Website activity, website form submissions and user content.

Sharing Basis: To provide public website services for our school

Security Protocols:
Sites are served over HTTPS using TLS to provide both secure server–server and server–client communication. Accounts are protected from brute force attacks with rate limiting and automated account locking. Passwords are one-way encrypted using bcrypt before being stored and are required to satisfy strong password rules to ensure high-entropy.

Access Conditions: None

Teacher Access: Limited to data provided within the CMS

Server/Data Location: United Kingdom (EEA)

Retention Period: Please view the more information link for data retention policies.


Transition between primary and secondary school

Data Shared: Transition activities / work done in transition lessons / pupil record

Sharing Basis: In the public interest and official authority of the data controller.

Security Protocols: Emails on secure servers; for ‘online.sch.im’ a google service self regulatory frameworks, including the EU-US Privacy Shield arrangement.

Access Conditions: Supervised and unsupervised

Teacher Access: Yes

Server/Data Location: United Kingdom (EEA)

Retention Period: DOB + 21 years or 3 years since the last log on



more information

Data Shared:
Your name, username and email address, or phone number, Cloud recordings, chat / instant messages, files, whiteboards, and other information shared while using the service, voice mails, IP address, MAC address, other device ID (UDID), device type, operating system type and version, client version, type of camera, microphone or speakers, connection type, etc. location, Duration of the meeting / Zoom Phone call, Email address, name, or other information that a participant enters to identify themselves in the meeting, Join and leave time of participants, Name of the meeting, Date / time that meeting was scheduled, Chat status (unless a setting is actively chosen by user), Call data records for Zoom Phone

Sharing Basis: Consent

Security Protocols:
Covid-19 Zoom for remote sessions

In order to facilitate remote working Bunscoill Rhumsaa are using a service called Zoom. Please be aware that there are privacy and security issues at present with this and we understand that you may not want to use this service. There is no obligation to do so. Some of the problems have been highlighted in the press and include:

Information routed through servers based in China – possible review of information;

Sharing of data with facebook – updated software should be used

Zoombombing – suitable passwords should be in place and links should not be shared

Encryption is not end to end - No personal information should be shared during sessions as the service is not properly encrypted.

Non-protected meetings – Only password protected meetings should be held.

Password protection, encryption – not end-to-end, only participants to meetings to be sent links, updates to be installed. Please note there are currently serious issues and no sensitive information should be shared on this platform. Privacy Shield applies.

Access Conditions: Supervised and unsupervised

Teacher Access: Yes

Server/Data Location: Data routed through servers in China. USA

Retention Period: Individual accounts when deleted


For more specific details about retention periods see the Department’s retention schedule

Information obtained or disclosed by third parties will not be used for any other purpose other than supporting the delivery of teaching and learning.

Failure to provide information may impact on support in school, the quality of teaching and learning and in achievement in examinations.

Protecting your information

Bunscoill Rhumsaa will:

  • keep your information safe and secure in compliance;
  • only use and disclose your information as detailed above where necessary
  • Retain the information for no longer than is necessary and your information wll be permanently deleted once the timeframes set out below have been reached (there will need to be an authorisation process, to dispose of this in line with our Records Management Policy and retention periods as outlined below (unless there is an over-riding reason to retain this information).

Transfer of Information outside the EEA

Apps and services that are used in school may require data to be stored on servers outside of the EEA. Information sent to these will be limited and are as detailed above.

More Information

You can find out more information including:

  • Looking at the Isle of Man Government Privacy Policy here https://www.gov.im/about-this-site/privacy-notice/ [Accessed 16/1/18]
  • Contacting our Data Protection Officer who is: Andrew Shipley, DPO. Hamilton House, Peel Road. Douglas. IM1 5EZ. Tel 685828. Email DPO-DESC@gov.im
  • Asking to see your information or making a complaint if you feel that your information is not being handled by contacting the Headteacher as Data Controller for Bunscoill Rhumsaa
  • Making a subject access request which is a request for all of the personal data we hold about you.
  • Obtaining this information in large print, braille, or in an alternative language.

Your rights

You have a right to access your personal data to ensure that it is accurate, and to request that it is rectified, blocked, erased or destroyed if it is inaccurate.

To make any request relating to your data held by us, please contact the Data Protection Officer for the Department of Education, Sport and Culture who is: Andrew Shipley, DPO. Hamilton House, Peel Road. Douglas. IM1 5EZ. Tel 685828. Email DPO-DESC@gov.im

If you are not satisfied with the response you receive, you may also complain to the Information Commissioner, whose details can be found on www.inforights.im, or the relevant supervisory authority. You may have a right to other remedies.