Do Schools Need a Data Protection Officer?

Under UK GDPR, all schools must have a designated data protection officer (DPO). This can be achieved by:

• Assigning the responsibility to a current staff member
• Sharing a DPO between a group of schools and academies
• Using an outsourced DPO service

What Is a DPO’s Responsibility In a School?

A DPO in a school is responsible for:

• Monitoring compliance and conducting regular data audits.
• Developing and updating data protection policies and privacy notices.
• Answering data protection enquiries from staff, parents and pupils.
• Advising staff on data protection rules and responsibilities.
• Organising data protection training for staff.

Why Does a School Need a DPO?

Guidance on AI Technology

Tools such as ChatGPT and Microsoft Copilot are increasingly used in most workplaces, but their use in schools remains a grey area. Staff often want to know whether these tools can be used in schools and, if so, what controls need to be in place.

A DPO can carry out a Data Protection Impact Assessment (DPIA) to identify risks before advising schools on how best to implement AI technologies safely and effectively.

Support with Subject Access Requests

Schools often need support with SARs to understand:

• Requests made by parents on behalf of their children.
• When a child is mature enough to exercise their right to access information.
• How to manage requests involving safeguarding information.
• How to handle third-party information within pupil records.
• What information shouldn’t be disclosed.

A DPO supports staff in managing complex SARs, whether they involve pupils, parents, other staff members or safeguarding information. This can include reviewing records, applying appropriate exemptions and advising on what information can be disclosed.

Provide Policies on Photography, Videos and Marketing

The rules around taking photographs and videos in schools are often misunderstood.

Schools must inform parents and guardians how photographs of their children will be used and have a valid ‘lawful basis’ for publishing them. While it is not illegal for parents to film and photograph their own children during school performances and sports days, some schools may have policies restricting this for safeguarding and child protection purposes.

A DPO helps schools create clear privacy policies and processes, establish safe storage rules and define a ‘lawful basis’ for capturing and using images, ensuring these practices comply with UK GDPR and Data Protection Act (DPA) standards.

Why Should a School Outsource a DPO?

Gain Access To Expert Knowledge

Schools rarely have internal data protection expertise. An outsourced DPO brings specialist knowledge without the need to train someone internally. They can also provide staff with the necessary UK GDPR and data protection training.

Eliminate Conflict of Interest

Data protection regulations require a DPO to act independently. Roles such as Headteacher or IT Manager can’t serve as a DPO because they make key decisions about the school’s data processing and systems, meaning they can’t objectively monitor their own practices. An outsourced DPO provides impartial advice and identifies security risks that internal employees might overlook.

Cost-Effective

Employing an internal DPO can be expensive, as most schools rarely require full-time data protection work. Outsourcing DPO services provides access to a wider team of experts while replacing a fixed salary with a predictable service fee tailored to the level of support needed.

Get Expert DPO Support from Data Protection People

At Data Protection People, we provide ongoing data protection support for education organisations. Whether you’re a school, Multi-Academy Trust (MAT), college or university, we can advise on everything from data processes and safeguarding procedures to SAR requests.

Get in touch with our data specialists today.