Leavers' Memorabilia
We're already seeing the leavers' hoodies when we're visiting schools and our help desk has received tickets asking about year book administration, so here's some best practice about 'Leaver's Memorabilia'.
🧥Leavers' Hoodies
The school should decide on the legal basis for collecting data - if something has an educational basis then you may not need consent. Strictly speaking, a leavers hoodie is not considered educational, more memorabilia, therefore, 'Legitimate Interests' or 'Public Task' can be hard to argue. Sometimes schools like to do this as a surprise for the children so getting consent might ruin the surprise.
- Lawful Basis - you could ask for consent at the beginning of the school year with all the other consents so the children won't know and the 'surprise' is still there- this may be the best and most appropriate way forward
- Risk mitigation - just use the first name as the risk is low in these circumstances
- Understanding the risk - finally, accept the risk but be aware it exists. The risk is low so some schools choose to accept it because they feel the benefit outweighs the risk.
- Cut-off - have a clear 'opt-out' window before the design is sent.
Consider if a parent or guardian complained or asked for their child's name to be removed and any risk involved.
📚Year Books
Again, the school should decide on the legal basis for collecting the data and it may be easier for a school to argue that a year book is educational.
- The Data Processing Rule - consider who is doing the year book - whether this is the school's reprographics team or an external company. If it is done internally then there is no data sharing taking place. Our new Photos and Videos Policy has two new appendices with a Photo, Video and Celebrations Consent Form and a Model Photo Waiver Form - this covers ongoing use of material beyond the child's attendance at school.
- Access Control - whatever application is used to create the year book, there must be a school account, not a personal one.
- Storage - ensure photos are stored on the school's network or cloud systems - never on staff's personal devices or a parents/volunteers.
📁Records Management
- Delete files - delete working files such as names, sizes and raw image drafts after the return/dispute period.
- Archive copies - you may wish to keep a master copy for the school archive, ensure it is noted in your Record of Processing activities and kept securely.
- Future use - if you want to use yearbook photos for 'Alumni' activities later, ensure your Photo Waiver Form specifically covers use after the student has left the school.