POLICY OWNER
Data Protection Lead
APPLIES TO
DBS records, health and needs information
THE ONE RULE TO REMEMBER
Sensitive data is locked away, seen by the fewest people, and kept for the shortest time.
We hold some special category and criminal offence data: information about students' health, allergies and special educational needs (shared by parents), and DBS check outcomes for staff and specialists. We process it under the safeguarding and employment conditions in Schedule 1 of the Data Protection Act 2018, which require this appropriate policy document.
Principle How we meet it Lawful, fair, transparent Explained in the privacy notice; used only to keep children safe and to meet safer- recruitment duties.
Purpose limitation Health data used only for care and adjustments; DBS data only for recruitment decisions.
Data minimisation We record a DBS certificate number, date and outcome, not a copy of the certificate.
Accuracy Parents asked to update health information each term.
Storage limitation Deleted in line with the retention schedule in Policy 12.
Security Restricted folders, password-protected devices, locked cabinet for paper.
Accountability Reviewed yearly by the Data Protection Lead.
DATA & TECHNOLOGY
Special Category Data Statement The short "appropriate policy document" covering the most sensitive data we hold.
Pass 11 Plus Grammar · Policy 13 JMS Publishers and Providers Ltd · Edgbaston, Birmingham Version 1.1 · October 2026 · Page 1 of 1