OVERVIEW

Our Intent. We are committed to safeguarding the privacy of users who use the Free School Meals Eligibility Checker (FSM) website service and we will only use the information we collect about you lawfully.

Changes to Data Protection Legislation. Data Protection legislation is currently going through a period of change. The introduction of the European Union’s General Data Protection Regulation (GDPR) is the basis of change and has been applied from the 25 May 2018 by The Data Protection Act 2018.

Data Subject’s Privacy Notice. This Privacy Notice should be read by Data Subjects, i.e. “you,” or any identifiable person using the London Grid for Learning (LGfL) FSM Eligibility Checker service.

The Data Controller. On behalf of the data controllers, who are schools (including nurseries and colleges), the LGfL provides an FSM website to enable them to claim additional funding to enhance education and provide free school meals for eligible children.

The Data Processor. This FSM website https://pps.lgfl.org.uk is owned and operated by LGfL. Our contact details are:

• Email: Email: fsm@lgfl.net
• Mail: 9th Floor, 10 Exchange Square, Primrose Street, London, EC2A 2BR.

Data Protection Officer (DPO). Each school (including nurseries and colleges) will have a DPO. LGfL have appointed a DPO who can be reached at dataprotectionenquiries@lgfl.net. All DPOs, including the LGfL’s, fulfil a number of roles one of which is to be the primary and independent point of contact for Data Subjects, namely you. To raise concerns regarding the processing of your personal data by the LGfL, please email or send a letter to our contact details above, at which point the enquiry will be forwarded to the DPO of the Data Controller or respective member of staff for action.

Purpose of Processing Personal Data. We collect personal data on this website primarily to support the process of FSM Eligibility Checker service. The FSM service allows parents/guardians to check their eligibility for free school meals, therefore enabling the school to apply for additional funding to improve children’s education, including the provision of free school meals.

Lawful Basis of Processing Personal Data When Visiting This Website. The lawful basis of processing your personal data when using the FSM checker is assessed to be: Consent. Namely you, the parent or guardian must agree for your details to be submitted into the FSM checker.

Categories of Personal Data Processed by LGfL. The personal data collected during the FSM process is to support the eligibility checking process. Across all the LGfL processes and services we will seek to ensure all personal data is accurate and up to date. The personal data which we hold will be held securely and in accordance with our internal data protection and security policies.

The information required for FSM is:

Parent’s/Guardian’s first name;

Parent’s/Guardian’s last name;

Parent’s/Guardian’s date of birth; and

Parent’s/Guardian’s National Insurance (NI) Number (or National Asylum Seeker Service (NASS) Number).

Category of Recipients of Personal Data. LGfL acts as a Data Processor on behalf of schools (includes nurseries and colleges for the purposes of this Privacy Notice) to enable them to apply for additional education funding for eligible children. This is achieved by parents/guardians, or the school on their behalf, conducting an online check by entering their personal details and the name and school of at least one child.

The FSM checker links to a Department of Education (DfE) portal which links to a Department of Work and Pensions (DWP) database. This enables an immediate decision to be available to the parent/guardian making the check.

Schools that have ‘FSM Administrators’ will be able to see the results of all parents/guardians connected with their school and their children. On occasions, schools may do the FSM check on behalf of parents /guardians who have consented to this.

For parents who are eligible for FSM, schools will be able to submit applications to their respective local authority or if appropriate directly to the DfE, to claim the additional funding.

The results from the FSM eligibility checking service merely provide information to schools that some of the parents are eligible. Local authorities can have FSM Administrators set up also, so that they can see who is eligible at their respective schools. It is up to each school how they work with their local authorities for processing the claims.

Transfer of Personal Data Outside the EEA (European Economic Area). There is no personal data involved in FSM transferred outside the EEA.

Sensitive Personal Data. There is no Sensitive Personal Data collected and processed under the FSM process. However, it is recognised the economic situation of eligible parents/guardians must be handled within strictest confidence, whilst carrying out the claiming of additional funding from the DfE.

Retention of Personal Data. The data collected to support FSM is held until the Student leaves an LGfL connected school or college. Schools and LAs may hold the data obtained from the FSM Checker for longer due to the requirements of the Finance Act if it is used to apply for the Pupil Premium. This time period is to enable ease of checking by schools to allow the claiming of Pupil Premium as appropriate throughout the duration of a Student’s education, this could be up to 25 years of age.

Data Subject’s Rights. Under data protection legislation you have a number of Rights which we have outlined below:

Right of Access. You are entitled to access your personal data so that you are aware of and can verify the lawfulness of the processing. This should be achieved through submitting a Subject Access Request (SAR) to the Data Controller, which is the school. If you are a data controller of this system and require any assistance, please log this via the LGfL support website at support.lgfl.net. In summary, you have the right to obtain:

• Confirmation that your data is being processed;
• Access to your personal data (a copy); and
• Other supplementary information, which corresponds to the information in this Privacy Notice.

Fees and Timings. This information will be provided without charge; without delay and within one month. If an extension is required or requests are considered manifestly unfounded or excessive, in particular because they are repetitive, LGfL may choose to: charge a reasonable fee taking into account the administrative costs of providing the information; or refuse to respond. The reasons for this will be formally notified to you and your rights to appeal to the UK Information Commissioner’s Office (ICO) https://ico.org.uk will be highlighted.

Identify Verification. To protect your personal data, LGfL will seek to verify your identity before releasing any information, which will normally be in electronic format.

Right of Rectification. You are entitled to have personal data rectified if it is inaccurate or incomplete. This can be achieved directly through logging into the LGfL USO account and amending the details about yourself. LGfL will support your request under instruction from the relevant school or Local Authority or school, so you should have a response within one month of your request. In the unlikely event LGfL does not take action to the request for rectification, LGfL will inform you of your rights to complain or seek judicial remedy.

Right of Erasure. You may request the deletion or removal of personal data where there is no compelling reason for its continued processing. The Right to Erasure does not provide an absolute ‘right to be forgotten,’ especially once the FSM processing has started. However, you do have a right to have personal data erased and to prevent processing in specific circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
• When you withdraw consent (and this is the basis of processing);
• When you object to the processing and there is no overriding legitimate interest for continuing the processing;
• The personal data was unlawfully processed;
• The personal data has to be erased in order to comply with a legal obligation; and
• The personal data is processed in relation to the offer of information society services to a child. However, you should note LGfL provide educational services which may not be considered information society services.

Right to Restrict Processing. When processing is restricted, LGfL is permitted to store the personal data, but not further process it. In this event exactly what is held and why will be explained to you.

Right to Data Portability. You may request to obtain and reuse your personal data for your own purposes across different services. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The Right to Data Portability only applies:

• To personal data you have provided to LGfL;
• Where the processing is based on your consent or for the performance of a contract; and
• When processing is carried out by automated means.

In these circumstances LGfL will provide a copy of your data in CSV format free of charge, without undue delay and within one month. If there is a delay to this, you will be informed.

Right to Object. You have the right to object to:

Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

Direct marketing (including profiling); and

Processing for purposes of scientific/historical research and statistics.

Automated Decision Making and Profiling. The FSM does do automated decision-making with the equivalent of legal effect, i.e. eligibility to claim free school meals and other additional funding for the school that the pupil attends. This is based upon DWP and DfE policy, therefore if a parent or guardian disagrees they should approach the school for an appeal or understanding of how the decision was based.

Cookies. This section outlines the type of cookies we apply to our FSM website https://pps.lgfl.org.uk and the services we offer. By using the website, you agree your personal information will be handled as described in this Privacy Notice. The cookies we may use on our website are described as below:

Strictly Necessary Cookies - These are cookies that allow you to use different parts of our website. Without them different features that you have requested cannot be provided. These are usually set in response to an action performed by the user like clicking on a link or failing to enter the correct password to your account.

First Party Cookies - These are cookies that are set by our website. And only we can read them.

Session Cookies - These are stored while you browse our site and then deleted once you leave.

Performance Cookies - These help us to track how people are using our site. They help us to know what pages people are using most and how users navigate around the site, we use this information to make informed decision about how we can improve the user experience of our site. The information we get using these cookies is completely anonymous and we will make no attempt to identify you or influence your experience of our site while you are on it.

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