Design note 4 - what do we mean?
In addition to the similarities between our new icon and the real Northern Lights, we particularly liked some of the themes the Northern Lights icon represented, namely:
In addition to the similarities between our new icon and the real Northern Lights, we particularly liked some of the themes the Northern Lights icon represented, namely:
To complement our dynamic new Northern Lights icon, we needed a strong colour pallette and confident, contemporary font.
The contrasting yet complimentary colours in our logo symbolises our value of diversity and unity. We often talk about 'the same but different' at Beckfoot Trust to acknowledge that whilst we have a very clear One Trust identity and clarity on what remarkable means, we also know that one size does not always fit all.
Perhaps the most important part of our new Beckfoot Trust logo is the icon, shown to the right here.
We call it our Northern Lights.
In nature, the Northern Lights are seen as something unique and truly Remarkable that are associated with the North.
Our Northern Lights icon represents The Beckfoot Trust which is also on a constant journey to Remarkable and is strongly associated with the North of England.
As part of our ongoing Journey to Remarkable we felt it was important to give The Beckfoot Trust a strong, confident and contemporary logo and brand that was worthy of an organisation with such high standards and aspirations.
The new Trust logo was a departure from the previous logo style and was definitely designed with the future in mind.
Beckfoot Trust takes its’ duty to protect the personal data of all students and staff seriously, and this includes any biometric data we collect and process.
We collect and process biometric data in accordance with relevant legislation and guidance to ensure the data and the rights of individuals are protected. This policy outlines the procedure the school follows when collecting and processing biometric data.
The purpose of this policy is to set out clearly how we meet our statutory obligation with regards to the storing of biometric data. The policy applies to the storage of all biometric data for staff, student, and visitors. All staff who are involved in storing data are trained.
The policy should be read in conjunction with the following Beckfoot Trust policies.
Biometric data: Personal information about an individual’s physical or behavioural characteristics that can be used to identify that person, including their eight-point identification pattern (fingerprint), facial shape, retina and iris patterns, and hand measurements.
Automated biometric recognition system: a system which measures an individual’s physical or behavioural characteristics by using equipment that operates ‘automatically’ (i.e., electronically). Information from the individual is automatically compared with biometric information stored in the system to see if there is a match to recognise or identify the individual.
Processing biometric data: processing biometric data includes obtaining, recording, or holding the data or carrying out any operation on the data including disclosing it, deleting it, organising it or altering it. An automated biometric recognition system processes data when:
Special category data: personal data which the GDPR says is more sensitive, and so needs more protection where biometric data is used for identification purposes, it is considered special category data.
The school processes all personal data, including biometric data, in accordance with the key principles set out in the GDPR. The school ensures biometric data is:
As the Data Controller, the school is responsible for being able to demonstrate compliance with the provisions outlined in Section 2 (Automated biometric recognition system).
The Headteacher is responsible for:
The Data Protection Officer (DPO) is responsible for:
Prior to processing biometric data or implementing a system that involves processing biometric data, a DPIA will be carried out. The DPO will oversee and monitor the process of carrying out the DPIA.
The DPIA will:
When assessing levels of risk, the likelihood, and the severity of any impact on individuals will be considered. If a high risk is identified that cannot be mitigated, the DPO will consult the ICO before the processing of the biometric data begins.
The ICO will provide the school with a written response (within 8 weeks or 14 weeks in complex cases) advising whether the risks are acceptable, or whether the school needs to take further action. In some cases, the ICO may advise the school to not carry out the processing.
The Trust will adhere to any advice from the ICO.
The obligation to obtain consent for the processing of biometric information of children under the age of 18 is not imposed by the Data Protection Act 2018 or the GDPR. Instead, the consent requirements for biometric information are imposed by section 26 of the Protection of Freedoms Act 2012.
Parents, students, staff members and other relevant adults have the right to not take part in the school’s biometric system(s).
Where an individual objects to taking part in the school’s biometric system(s), reasonable alternative arrangements will be provided that allow the individual to access the relevant service, e.g. where a biometric system uses school’s eight-point identification pattern (fingerprint) to pay for school meals, the student will be able to use cash for the transaction instead.
Alternative arrangements will not put the individual at any disadvantage or create difficulty in accessing the relevant service, or result in any additional burden being placed on the individual (and the student’s parents, where relevant).
Biometric data will be managed and retained in line with the Trust’s Records Management procedures.
If an individual (or a student’s parent, where relevant) withdraws their consent for their / their child’s biometric data to be processed, it will be erased from the school’s system.
There are appropriate and robust security measures in place to protect the biometric data held by the school. These measures are detailed in the Trust’s GDPR Policy.
Any breach to the school’s biometric system(s) will be dealt with in accordance with the GDPR Policy.
Notification of intention to process biometric information
Dear Parent/Carer
Beckfoot [name of school] wishes to use information about your child as part of an automated (i.e., electronically operated) recognition system. This is for the purposes of [specify e.g. catering, library access]. The information from your child that we wish to use is referred to as ‘biometric information’ (see next paragraph). Under the Protection of Freedoms Act 2012 (sections 26 to 28), we are required to notify each parent of a child and obtain the written consent of at least one parent before being able to use a child’s biometric information for an automated system.
Biometric information and how it will be used.
Biometric information is information about a person’s physical or behavioural characteristics that can be used to identify them, for example, information from their [fingerprint]. The school would like to take and use information from your child’s [fingerprint] and use this information for the purpose of providing your child with [specify e.g. catering, library access].
The information will be used as part of an automated biometric recognition system. This system will take measurements of your child’s [fingerprint] and convert these measurements into a template to be stored on the system. An image of your child’s [fingerprint] is not stored. The measurements taking from your child’s [fingerprint] is what will be used to permit your child to access services.
You should note that the law places specific requirements on schools and colleges when using personal information, such as biometric information, about students for the purposes of an automated biometric recognition system. For example:
Providing your consent/objecting
As stated above, in order to be able to use your child’s biometric information, the written consent of at least one parent is required. However, consent given by one parent will be overridden if the other parent objects in writing to the use of their child’s biometric information. Similarly, if your child objects to this, the school/college cannot collect or use his/her biometric information for inclusion on the automated recognition system.
You can also object to the proposed processing of your child’s biometric information at a later stage or withdraw any consent you have previously given. This means that, if you give consent but later change your mind, you can withdraw this consent. Please note that any consent, withdrawal of consent or objection from a parent must be in writing.
Even if you have consented, your child can object or refuse at any time to their biometric information being taken/used. His/her objection does not need to be in writing. We would appreciate it if you could discuss this with your child and explain to them that they can object to this if they wish.
The school is also happy to answer any questions you or your child may have.
If you do not wish your child’s biometric information to be processed by the school, or your child objects to such processing, the law says that we must provide reasonable alternative arrangements for children who are not going to use the automated system to access [specify e.g. catering, library].
If you give consent to the processing of your child’s biometric information, please sign, date, and return the enclosed consent form to the school.
Please note that when your child leaves the school, or if for some other reason he/she ceases to use the biometric system, his/her biometric data will be securely deleted.
Consent Form for the use of Biometric Information in School
Please complete this form if you consent to the school taking and using information from your child’s [fingerprint] by Beckfoot [name of school] as part of an automated biometric recognition system. This biometric information will be used by the school for the purpose of accessing [catering, library access].
In signing this form, you are authorising the school to use your child’s biometric information for this purpose until he/she either leaves the school/college or ceases to use the system. If you wish to withdraw your consent at any time, this must be done so in writing and sent to the school at the following address:
[insert address]
Once your child ceases to use the biometric recognition system, his/her biometric information will be securely deleted by the school.
_______________________________________________________________________________________
Having read guidance provided to me by Beckfoot [name of school], I give consent to information from the [fingerprint] of my child:
[insert name of child]
being taken and used by Beckfoot [name of school] for use as part of an automated biometric recognition system for accessing [catering, library access]
I understand that I can withdraw this consent at any time in writing.
Name of Parent:
……………………………………………………………………………………………………………………………………………
Signature:…………………………………………………………………….Date:…………….…………………………………………………
Please return this form to: [insert delivery point]